AMERICAN INSTITUTE OF ARCHITECTS WASHINGTON COUNCIL PAC: Alleged violation of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures (EY24 JUL25)

Case

#175523

Respondent

AMERICAN INSTITUTE OF ARCHITECTS WASHINGTON COUNCIL PAC

Complainant

Conner Edwards

Description

Allegation: Violation of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures

The Public Disclosure Commission (PDC) reviewed the complaint filed by Conner Edwards on July 1, 2025 and dismissed this matter in accordance with RCW 42.17A.755(1).

The complaint alleged that American Institute of Architects of Washington Council PAC (AIAWA PAC) may have violated RCW 42.17A.235 and .240 by failing to timely and accurately report contributions and expenditures. The complaint alleged that the PAC participated in the 2024 elections as early as August 2024 but filed monthly reports instead of the required 21- and 7-day pre-election C-4 reports, and that expenditures in October that were contributions to candidates were not reported until after the election.

Applicable Laws and Rules

RCW 42.17A.235 and .240 - A committee that selects the Full Reporting option on their C-1pc report is required to report contributions and expenditures to the PDC on C-3 reports and 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 committee’s election participation, and their financial activity.

Background and Findings

American Institute of Architects Washington Council PAC has been a registered political committee since at least 2002. AIAWA PAC participated in the 2024 general election by making contributions to 17 candidates, totaling $11,200.
Because of its participation in the 2024 general election, AIAWA PAC was required to file the 21- and 7-day pre-general election and post-general election C-4 reports, rather than monthly C-4 reports, as follows:
21-day C-4 report covering Sep. 1 – Oct. 14, 2024; due by Oct. 15, 2024
7-day C-4 report covering Oct. 15 – Oct. 28, 2024; due by Oct. 29, 2024
Post-general C-4 report covering Oct. 29 – Nov. 30, 2024; due by Dec. 10, 2024
AIAWA PAC filed a July 2024 C-4 report of contributions and expenditures on Aug. 2, 2024, reporting no expenditures.
AIAWA PAC filed an August 2024 C-4 on Sep. 10, 2024, reporting three expenditures totaling $2,350, that were contributions to candidates. The expenditures were made on Aug. 8, 16, and 20, 2024, and although they were required to be reported on a post-primary election C-4 report, they were timely filed on the August 2024 C-4 report.
AIAWA PAC filed a C-4 report covering September 2024 on October 15, 2024, the same day the 21-day pre-general election C-4 report was due. The September 2024 C-4 included $7,850 in expenditures, that included 12 contributions to candidates. Although the contributions were required to be reported on the 21-day pre-general election C-4, they were timely filed.
AIAWA PAC filed a C-4 report covering October 2024 on Nov. 11, 2024. The report included two $500 contributions to candidates made on Oct. 10 and 21, 2024. The contributions were required to be reported on the 21-day and 7-day pre-general election C-4 reports, respectively, that were due Oct. 15 and Oct. 29, 2024, respectively, but were reported 27 and 13 days late, respectively, and six days after the general election.

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.

PDC staff reminded the committee that when it is participating in an election, it is required to follow the accelerated reporting schedule, which includes switching from monthly C-4 reports to reports filed 21 and 7 days before the election and a post-election C-4 report.

Disposition

Dismissed by Executive Director

Date Opened

July 11, 2025

Areas of Law*

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