Silong Chhun: Alleged violations of RCW 43.17A.235, .240 & .700 for failure to timely and accurately file contribution and expenditure reports & Personal Financial Affairs Statement (F-1) report within two weeks of candidacy (EY25; MAY25)

Case

#171656

Respondent

Silong Chhun

Complainant

Conner Edwards

Description

The complaints alleged violations of RCW 42.17A.235, and .240 for failure to timely and accurately file contributions and expenditure reports and RCW 42.17A.700 for failure to file a Personal Financial Affairs Statement (F-1) report within two weeks of candidacy.

Applicable Laws and Rules

RCW 42.17A.235 requires each treasurer of a candidate or political committee, or an incidental committee, to file with commission a report of all contributions received, and expenditures made as a political committee on the next reporting date pursuant to the timeline established in the statute.
RCW 42.17A.240 requires each treasurer of a candidate or political committee, or an incidental committee, to file with the commission a report including/depicting the name and address of each person who has made one or more contributions during the period, together with the money value and date of contribution and the aggregate value of all contributions received from each person during the campaign, or in the case of a continuing political committee, the current calendar year.
RCW 42.17A.700 (2): requires candidates for political office to file with the commission a statement of financial affairs for the preceding twelve months within two weeks of becoming a candidate.

Background and Findings

On January 27, you, Silong Chhun, filed a candidate registration with the PDC as a 2025 candidate for the position of City Council Member, Position 4 in the City of Tacoma.

The complaint alleged that you, Silong Chhun, as a candidate registered with the PDC and selected the “Full Reporting” option, failed to timely and accurately file contributions and expenditures reports in the 2025 election year.
The staff also noted that your campaign failed to timely file six separate C-3 reports for the month of March 2025 as noted in the complaint. All five C-3 reports were due no later than April 10, 2025, and were filed 18 days late on April 28, 2025. The same applies to one other C-3 where the campaign deposited a contribution on June 18, 2025, but filed the report late on July 7, 2025.
Regarding the allegation about inadequate expenditure detail/descriptions, the staff reviewed the pertinent report(s) and noted that there were some expenditures for which a more detailed description of the expenditure should have been provided. For example, the campaign failed to include the number/quantity of “yard signs” for the $861.15 expenditure made by the campaign.
Lastly, regarding the allegation about the failure to file a F-1 report within two weeks of candidacy as required by the statutory scheme, the staff noted that you failed to file the F-1 report timely. Since your first contribution was received on January 12, 2025, as noted on the C-3 report filed on February 10, 2025, officially making you a candidate in the 2025 election year, you were required to file your F-1 report within two weeks of receiving the January 12, 2025, contribution. As such, the F-1 report was required to be filed no later than January 26, 2025, and was filed 106 days late on May 12, 2025.
On July 15 and 24, 2025, your campaign amended the pertinent C-4 report(s) at issue in this matter to better depict and correct the issues raised in the complaint regarding the lack of proper description to include the number/quantity of the materials/items purchased by your campaign.

Summary and Resolution

Based on our findings, the staff has determined that, in this instance, the failure to timely and accurately file the C-4 reports at issue in the matter does not amount to a violation that warrant further investigation.

Pursuant to WAC 390-37-060(1)(d), however, The Committee is receiving a formal written warning concerning the failure to file timely and accurate C-3 and C4 reports and the failure to timely file a F-1 report, as required by the statutory scheme. The PDC staff expects The Committee to file timely and accurate C3/C-4 and F-1 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.

Any allegations regarding reporting by The Committee for the first seven months of 2025 election year that are not otherwise addressed are hereby dismissed.

Accordingly, the PDC dismissed this matter in accordance with RCW 42.17A.755(1).

Disposition

Case Closed with Written Warning

Date Opened

May 07, 2025

Areas of Law*

RCW 29B.25.090/42.17A.235, RCW 29B.25.100/42.17A.240, RCW 29B.55.010/42.17A.700

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