Jaralee Anderson: Alleged violations of RCW 42.17A.235 & .240, and .490 for failing to disclose vendor name and address for in-kind goods/services; and failing to identify contributors who approved contribution transfers for different office (EY25 MAY25)

Case

#172489

Respondent

Jeralee Anderson

Complainant

Conner Edwards

Description

The Public Disclosure Commission (PDC) completed its review of a complaint filed with the PDC.

Applicable Laws and Rules

Per RCW 42.17A.235 and .240, a candidate that selects the Full Reporting option on their registration report is required to report contributions and expenditures to the PDC on Cash Receipts Monetary Contributions reports (C-3 reports) and Campaign Summary Receipts & Expenditures reports (C-4 reports) pursuant to RCW 42.17A.235 & RCW 42.17A.240. The due dates for these reports are based upon the election cycle, the candidate's election participation, and their financial activity.

Pursuant to RCW 42.17A.240(7), expenditures are disclosed on C-4 reports, which must include, but are not limited to: 1) the name and address of each person to whom an expenditure was made in the aggregate of more than $750 during the period covered by the report; 2) the amount, date, and purpose of each expenditure; and 3) the total sum of all expenditures. Purpose details should state the goods or services provided by the vendor, including the number of items purchased, identify any candidates or ballot propositions supported or opposed by the expenditure, and the name & address of any sub-vendors used. For advertising expenditures, campaigns should describe the type and number of ads, where they appeared or were broadcast, and when (e.g., run dates). An in-kind contribution is disclosed like an expenditure on the PDC’s Online Reporting of Campaign Activity (ORCA) software.

Pursuant to RCW 42.17A.490, (1) Except as provided in subsection (2) of this section, a candidate for public office or the candidate's authorized committee may not use or permit the use of contributions, whether or not surplus, solicited for or received by the candidate or the candidate's authorized committee to further the candidacy of the individual for an office other than the office designated on the statement of organization. A contribution solicited for or received on behalf of the candidate is considered solicited or received for the candidacy for which the individual is then a candidate if the contribution is solicited or received before the general election for which the candidate is a nominee or is unopposed. (2) With the written approval of the contributor, a candidate or the candidate's authorized committee may use or permit the use of contributions, whether or not surplus, solicited for or received by the candidate or the candidate's authorized committee from that contributor to further the candidacy of the individual for an office other than the office designated on the statement of organization. If the contributor does not approve the use of his or her contribution to further the candidacy of the individual for an office other than the office designated on the statement of organization at the time of the contribution, the contribution must be considered surplus funds and disposed of in accordance with RCW 42.17A.430. Also see PDC Interpretation No. 23-01.

Background and Findings

On April 14, 2024, the Respondent submitted a C-1, under the Full Reporting option, for City Council Member, Position 6, in the City of Redmond. The C-1 was amended April 1, 2025, to the Mini Reporting option.
Regarding the alleged violation of RCW 42.17A.490 for not identifying contributors for the transfer of funds from a previous campaign for a different office, PDC staff reviewed the reporting, and the Respondent's response to the allegations, and found there was a transfer of funds from the 2024 to the 2025 committee account and that both campaigns were self-funded by the candidate. C-3, #110260029, submitted on November 11, 2024, identified a transfer of funds for $381.11 and the report initially identified the contributor as “Committee for Jeralee Anderson.” On July 11, 2025, at the request of PDC staff, the reporting was amended to read “Committee for Jeralee Anderson Surplus from 2024 Candidate’s Self-Funded Campaign.” Short of the candidate indicating in their reporting that they gave themselves permission to transfer their own funds from a previous campaign for a different office, the reporting was done technically correct. There are no PDC RCW, WAC or guidance that specify when a campaign is self-funded they need to identify their own permission to transfer funds, but the candidate agreed for clarity to amend the reporting. This allegation is dismissed as unfounded.

Regarding the alleged violations of RCW 42.17A.235 & .240 for missing reporting, PDC staff found the following:

For 2021, the last C-4 report, 110074429, shows $0 COH, $0 Liabilities, and $0 Balance.
For 2023, the first C-4 report, 110210294, shows $62 on line #1. The last C-4 report, 110210298, shows $0 COH, $0 Liabilities and $0 Balance. The Respondent worked with PDC staff to determine that the start date of the 2023 campaign was the cause of the reporting discrepancy. On August 22, 2025, the start date of the 2023 campaign was adjusted to account for an in-kind contribution from the candidate for a POB rental, of $62.00. The expenditure occurred on May 15, 2023, and was reported timely. The starting balance of the committee now shows a zero balance and corresponds to the ending balance of the prior campaign. Also, the original C-1 was submitted on May 19, 2023, and the adjusted campaign start date is within the required timeline to submit a registration following the start of campaign activity.
There were no missing reports identified in 2024.
For 2025, the evidence provided by the Complainant was not the committee’s opening C-4 for the 2025 campaign. The actual first C-4 report, #110215146, for the period April 1, 2024 – April 30, 2024, submitted May 10, 2024, shows $0 on line #1. The second C-4 report, 110268394, for the period May 1, 2024, to November 30, 2024, submitted November 11, 2024, reported the $381.11 transfer from the previous campaign. This C-4 identified financial activity below the $750 threshold for monthly reporting and was submitted timely. The corresponding C-3 report, 110260029, for the $381.11 transfer of funds, also filed on November 11, 2024, was filed timely because the activity is below the $750 monthly reporting requirement.
This allegation is dismissed as unfounded.

Regarding the alleged violations of RCW 42.17A.235 & .240 for missing vendor name and address for in-kind contributions made by the candidate in their 2025 reporting, PDC staff found the following:

The description field for line items related to the candidate's in-kind contributions did not include the name and address of the vendor. On June 13, 2025, all the C-4 were amended to identify the vendor and address for in-kind contributions from the candidate.

The Respondent has not received a warning, been issued a violation, or admitted to a violation of PDC regulations and rules during the 2025 election.

Summary and Resolution

Having reviewed the complaint and the supporting evidence, PDC staff has determined that the Respondent appears to have violated RCW 42.17A. After consideration of all the circumstances, further proceedings would not serve the purposes of the Fair Campaign Practices Act. Under WAC 390-37-070, the executive director, at any time prior to consideration by the Commission, may dismiss a complaint which on its face, or as shown by investigation, provides reason to believe that a violation has occurred, but also shows that the respondent is in substantial compliance with the relevant statutes or rules, or shows that formal enforcement action is not warranted.

Based on this, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and WAC 390-37-060(1)(d). PDC staff has reminded the Respondent about the importance of accurately reporting vendor name and address for in-kind contributions. They are expected to comply with PDC statutes and rules in the future.

Disposition

Case Closed with Reminder

Date Opened

May 21, 2025

Areas of Law*

RCW 29B.25.090/42.17A.235, RCW 29B.25.100/42.17A.240, RCW 29B.40.220/42.17A.490

*On January 1, 2026, RCW 42.17A was recodified to RCW 29B