Jordan Gustafson

The complaint alleged that Valley Professional Firefighters (VPFF), a Political Action Committee (PAC) established in 2011, may have violated RCW 42.17A.405 by making an over-limit contribution, and RCW 42.17A.235 by (1) failing to timely file several Monetary Contributions reports (C-3) and Campaign Summary Receipts and Expenditures reports (C-4); and (2) failing to report contributions.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the C-3 and C-4 reports filed by VPFF PAC, the response from Jordan Gustafson, current volunteer treasurer for VPFF PAC, and the response from Danielle Franco-Malone, legal counsel for VPFF PAC, submitted to the Washington State Attorney General’s Office (AGO), to determine whether the record supports a finding of one or more violations.

Staff determined in this instance, the failure to timely file C-3 and C-4 reports timely does not amount to an actual violation warranting further investigation. However, pursuant to WAC 390-37-060(1)(b), VPFF PAC will receive a formal written warning concerning its failure to timely file all C-3 and C-4 reports. The formal written warning will include staff’s expectation that VPFF PAC will file timely C-3 and C-4 reports in the future. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).