Washington Collectors Association - PAC: Alleged violations of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions & expenditures in election years 2024 and 2025 (JUL 25)

Case

#176584

Respondent

WASHINGTON COLLECTORS ASSOCIATION – PAC

Complainant

Conner Edwards

Description

The complaint in this case alleged that Washington Collectors Association - PAC (the “Respondent”) violated RCW 42.17A.235 and .240 by failing to timely and accurately report contributions and expenditures in 2024 and 2025.


Specifically, the complaint alleged the following:

  • The committee’s January 2025 C-4 report was filed late and their 21-day pre-Primary C-4 report (covering 6/1/25-7/14/25) had not been filed;
  • A reimbursed expenditure on the Respondent’s February 2025 C-4 report did not include the name and address of the vendor;
  • Reporting was inaccurate based upon a discrepancy between the campaign’s starting balance for 2025 and their ending balance for 2024; and
  • The committee’s 2024 post-Primary C-4 report (covering 7/30-8/31) was filed late.
Based on the attached findings noncompliance appeared to be the result of good-faith errors or omissions. Delays in receiving financial records from the committee's bank contributed to late reporting, which the committee has since taken steps to remedy.

Three late pre-election C-4 reports for 2025 were received one day before or on the day of the election, which is an aggravating factor because it deprived the public of information during a time-sensitive period in the election cycle. However, these reports were also partially mitigated by minimal or no expenditure activity and other mitigating factors that minimized their impact on the public. The committee’s total expenditures for 2025 were relatively modest overall, which is also mitigating.

However, pursuant to WAC 390-37-060(1)(d), the Respondent received a formal written warning concerning their failure to timely disclose all contributions and expenditures on C-3 and C-4 reports in 2024 and 2025. PDC staff expect the committee to timely and accurately file all required of contributions and expenditures in the future. The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

The Respondent also made a minor or ministerial error on a required C-4 report, which did not materially harm the public interest. They made the necessary technical correction to amend the committee’s carryforward starting balance for 2025 to match their ending balance for 2024 within 2-14 days of being notified by PDC staff, as required for a matter resolved as a technical correction. See WAC 390-37-060.

PDC staff reminded the committee about the importance of including complete expenditure description details on C-4 reports, including vendor name and address, in accordance with the PDC laws, rules or guidance. 

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).

Disposition

Case Closed with Written Warning

Date Opened

July 29, 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

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