Electrical Workers 46 PAC

Electrical Workers 46 PAC: Alleged violations of RCW 42.17A.235 & .240 for failure to timely disclose expenditures on reports (EY25 JUL25)

Case Details

Case Number

176626

Respondent

Electrical Workers 46 PAC

Complainant

Conner Edwards

Date Opened

July 18, 2025

Case Status

Resolved through Statement of Understanding (SOU)

Respondent admitted violation and possibly paid penalty.

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Area(s) 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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Description

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: 
  1. January through May reports were submitted timely on a monthly schedule. 
  2. 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. 
  3. 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. 
  4. The post-primary report was submitted timely. 
  5. The 21-day pre-general report was submitted timely. 
  6. 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. 
  7. 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: 

  1. January through May reports were submitted timely on a monthly schedule. 
  2. 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. 
  3. 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. 
  4. 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).

Penalties

$600

Total Penalties

$0

Balance Due

Penalty

$600 (SOU)

Payments

  • $600 on 10/03/2025 (SOU)