IAFF Local 2781 PAC: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately disclose contribution & expenditure information (AUG'23, EY'18-EY'23)

Case

#141813

Respondent

IAFF Local 2781 PAC

Complainant

Glen Morgan

Description

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on August 26, 2023. The complaint alleged that IAFF Local 2781 PAC, a political committee registered with the PDC, may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) for calendar years 2018 to 2023, disclosing contributions and expenditures, including an incorrect carry forward balance, and missing address information for contribution recipients.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by legal counsel, Derek Schoonmaker, on behalf of the Respondent; the applicable PDC reports filed by the Respondent; queried the Respondent’s data in the PDC contribution and expenditure database; and other relevant information, to determine whether the record supports a finding of one or more violations.

It appears that the late reporting was due to the oversight of the former volunteer treasurer and not done intentionally to conceal the PAC’s activities from the public. Staff noted that the Respondent began the work of completing all missing campaign reports prior to the receipt of the complaint. The Respondent worked with PDC Filer Assistance staff to complete reports disclosing campaign activity as required under the “Full Reporting” option, including activity from 2018, most of which is beyond the statute of limitations for enforcement action. Staff found no evidence that the Respondent purposely filed late or inaccurate reports to mislead or otherwise keep information from the public.

Based on our findings staff has determined that, in this instance, failure to timely and accurately file campaign reports for calendar year 2018 forward, including an incorrect carry forward and missing address information for contribution recipients resulting in necessary amendments, does not amount to a finding of a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), however, the Respondent will receive a formal written warning concerning failure to timely and accurate disclosure of all contribution and expenditures. The formal written warning will include staff’s expectation that IAFF Local 2781 PAC timely files all future required reports of contributions and expenditures, including accurate carry forward balances and the inclusion of all required contact information on C-4 reports. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

Disposition

Case Closed with Written Warning

Date Opened

September 05, 2023

Areas of Law

RCW 42.17A.235, RCW 42.17A.240

Documents

• 141813 IAFF Local 2781 PAC Warning - Respondent.pdf
• 141813 IAFF Local 2781 PAC Complaint.pdf
• 141813 IAFF Local 2781 PAC Response.pdf