The Public Disclosure
Commission (PDC) completed its review of the complaint filed by Conner Edwards on
July 18, 2025. The complaint alleged violations of: RCW 42.17A.235 and .240 for
failure to timely disclose expenditures on Receipts & Expenditure
Summary (C-4) reports
in election year 2025.
Applicable Laws and Rules
A committee that selects the Full Reporting option on
their C-1pc report is required to report contributions and expenditures to the
PDC on Cash Receipts, Monetary Contributions (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
- Since 2017, the Electrical
Workers 46 PAC (the Committee) has operated as a continuing committee
registered with the PDC under the Full Reporting option.
- The Committee participated in
the 2024 primary and general elections and in the primary
election of 2025 by contributing funds to candidate
committees.
- During 2024, the Committee received $14,489.90
and expended $18,478.50. All the C-3 reports
were submitted timely. The C-4 reports
were submitted as follows:
- January through
May reports were submitted timely on a monthly
schedule.
- The Committee failed
to convert to the reporting schedule for 21-day reporting so
the report for the period of June 1 through July 15, 2024, due July
16, 2024, was not timely submitted. A report for the
month of June was submitted late on August 5, 2024, and
a report for the period of July 1 through July 15, 2024,
was also submitted late on August 8, 2024. Total late
reported expenditures were $27.
- The 7-day report, due
on July 30, 2024, for the period July 16 through July
29, was submitted a week late on August 8, 2024. There were
no late reported expenditures.
- The post-primary report
was submitted timely.
- The 21-day pre-general
report was submitted timely.
- The 7-day pre-general
report, due October 29, 2024, was submitted on November 7, 2024,
a week late. It contained one late-reported expenditure totaling
$9.
- The post-general and
December reports were submitted timely.
- For the 2025
primary election, as reported for January 1, 2025, through the
post-primary period ending August 31, 2025, the
PAC received $33,262.50 and expended $13,263. All C-3
reports were submitted timely. The C-4 reports
were submitted as follows:
- January through
May reports were submitted timely on a monthly
schedule.
- The Committee failed
to convert to the reporting schedule for 21-day reporting, so the
report for the period of June 1 through July 14, 2025, due July 15, 2025, was
not timely submitted. A report for the month of
June was submitted timely on July 10, 2025. A report
for the period of July 1 through July 14, 2024, was submitted late
on July 31, 2025, for expenditures totaling $7,209. All but $9
of the late reported expenditures were for contributions to
candidates.
- The 7-day report, due on
July 29, 2025, for the period July 15 through July
28, was submitted 2 days late on July 31,
2025. There were no late reported expenditures.
- The post-primary report,
due September 10, 2025, was submitted twelve days late on
September 22, 2025. It contained one
late-reported expenditure totaling $9.
- In September 2024, the Committee
signed a Statement of Understanding in PDC Case #153421 acknowledging
violations of RCW 42.17A.235 and .240 for a first occasion of late
filed Cash Receipts, Monetary Contributions (C-3)
reports and C-4 reports for 2019, 2020, 2021, and 2022; and for
a second occasion of late filed C-4 reports in 2023 that went unreported until
2024. The PAC paid a $450 civil penalty to resolve PDC
Case #153421.
Summary and Resolution
The Respondent completed a Statement of Understanding (SOU) and paid a $600 civil penalty in
accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), for an acknowledged
third occasion of a violation of RCW 42.17A.235 and RCW 42.17A.240 for: failing
to timely submit Receipts & Expenditure Summary (C-4) reports identifying
expenditures during the 2024 election and the primary election period of 2025.
The $600 penalty assessed resolves the allegations listed in this case.
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. The executive director
must report at each regular Commission meeting all complaints dismissed.
Based
on this information, the PDC has dismissed this matter in accordance with RCW
29B.60.020(1).