Progress Alliance of Washington: Alleged violation of RCW42.17A.205, .235, and .240 for failure to register as a political committee and failure to timely and accurately report contributions and expenditures (JUN25)

Case

#174306

Respondent

Progress Alliance of Washington

Complainant

Conner Edwards

Description

Allegation: Violation of RCW42.17A.205, .235, and .240 for failure to register as a political committee and failure to timely and accurately report contributions and expenditures

The Public Disclosure Commission (PDC) reviewed the complaint filed by Conner Edwards on June 11, 2025.

There was no evidence to support a finding that Progress Alliance of Washington is required to register and report as a political committee and the PDC dismissed this matter in accordance with RCW 42.17A.755(1).

mplaint alleged that Progress Alliance of Washington (Washington Progress Alliance or WPA) may be an unregistered political committee based on the definitions of "Political Committee" and "Person" in RCW 42.17A.005(41) and (39), respectively, and on the "Primary Purpose Test" in the Commission's Interpretation 07-02.

Interpretation 07-02 is the Commission’s Primary Purpose test to determine whether an entity is a political committee based on whether one of its primary purposes is to affect governmental decision-making by supporting or opposing candidates or ballot propositions.

Background and Findings

According to its website, Washington Progress Alliance includes: “Washington Progress Fund, a 501(c)(3) charitable organization that invests in non-partisan civic engagement and leadership development; and Washington Progress Alliance, a 501(c)(4) social welfare organization, that invests in movement building, issue advocacy, and political engagement.”
During the period 2010-2025, candidates and political committees reported receiving contributions from Washington Progress Alliance totaling $490,457.53. However, contributions reported by recipients as received from 2020 to 2025 totaled $42,918.98 and of that amount, three contributions totaling $35,000 were misreported by recipients as coming from Progress Alliance of Washington when they were actually expenditures made and reported by Voter Action, the political committee established by WPA in 2018.
After removing the $35,000 in misreported contributions, candidates and political committees properly reported receiving contributions from Progress Alliance of Washington from 2020 - 2025 totaling $7,918.98 which included a $4,100 contribution to Citizens in Support of Yelm Community Schools (Citizens for Yelm) on April 21, 2025 and $3,818.98 in small in-kind contributions to various candidates on 28 occasions.
Progress Alliance of Washington stated it does not solicit, accept, or have an expectation of receiving contributions for the purpose supporting candidates or ballot propositions in election campaigns.

Application of PDC Interpretation 07-02 (Primary Purpose Test) to Progress Alliance of Washington

The Primary Purpose test looks at: (1) the content of the stated goals and mission of the organization; (2) whether the organization's actions further its stated goals and mission; (3) whether the stated goals and mission of the organization would be substantially achieved by a favorable outcome in an upcoming election; and (4) whether the organization uses means other than electoral political activity to achieve its stated goals and mission.
Staff also considers whether an organization spends more than 30 percent of its budget supporting candidates or ballot propositions in election campaigns.
Between 2020 and 2025, election-related expenditures for WPA totaled $7,918.98, less than one percent of its $5,267,310 operating budget during that same period.
The vast majority of WPA’s expenditures are for grants and donations to other non-profit organizations. Progress Alliance of Washington does not have election financing as one of its primary purposes.
Staff also asked Progress Alliance of Washington about the First Mile Circle program described on its website and found that WPA does not solicit or accept donations for the First Mile Circle program. Rather, WPA selects potential candidates and connects them with potential donors. WPA staff communicates with donors but not with the candidates, WPA does not accept contributions on behalf of candidates and does not provide any monetary contributions to candidates through its First Mile program.

Disposition

Case Closed with No Evidence of Violations

Date Opened

June 17, 2025

Areas of Law*

RCW 29B.25.020/42.17A.205, RCW 29B.25.090/42.17A.235, RCW 29B.25.100/42.17A.240

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