Coalition for a Better Northwest Washington: Alleged violations of Chapter 42.17A RCW for failure to timely deposit and report contributions and pledges, and for accepting over-limit contributions within 21 days of an election




Coalition for a Better Northwest Washington


Alexander Ramel


The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 23, 2019. The complaint alleged that Coalition for a Better Northwest Washington (CBNWA), a political committee registered in 2019 making contributions to Whatcom County Council candidate, Ben Elenbaas, and independent expenditures opposing Whatcom County Executive candidate, Satpal Sidhu, may have violated: (1) RCW 42.17A.220 for failure to deposit monetary contributions within five business days of receipt; (2) RCW 42.17A.235 and .240 for failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing a monetary pledge; and (3) RCW 42.17A.420 for accepting contributions exceeding $5,000 from a single source within twenty-one days of an election.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Dan Brady on behalf of his client CBNWA; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database], to determine whether the record supports a finding of one or more violations.

During its review, staff found no evidence showing that the contributions from Phillips 66 and Marathon Petroleum Corp. were deposited late, reported on a C-3 or C-4 report late, or were received during a restricted time period for contributions exceeding $5,000 on the aggregate. It appears that CBNWA is aware that pledges are included in the statutory definition of a contribution and that it has a general understanding of filing deadlines, including “last minute contributions” (LMCs) disclosing contributions of $1,000 or more in the aggregate received before a general election.

Although the pledge from Marathon was timely reported October 22, 2019 on a C-3 report within 48 hours of being redeemed, staff found that the $5,000 pledge received by CBNWA on October 15, 2019, as described in Mr. Brady’s response, should have been disclosed within 48 hours of the pledge being made, or by no later than October 17, 2019. 

Based on our findings staff has determined that, in this instance, failure to timely file a report disclosing the receipt of a pledge of $1,000 or more within 48 hours does not amount to a violation that warrants further investigation.

PDC staff reminded CBNWA about the importance of the timely disclosure of all contributions, including pledges, received during the time period and dollar amount described in RCW 42.17A.265 and the timely filings of all future PDC reports in accordance with the statutes and 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).


Case Closed with Reminder

Date Opened

October 23, 2019

Areas of Law

RCW 42.17A.220, RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.420

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