Office & Professional Employees Int'l Union Local No 8 PAC: Alleged violations of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures (EY25 JUL25)

The Public Disclosure Commission (PDC) completed its review of the complaint filed by Conner Edwards on July 1, 2025. The complaint alleged violations of: RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures in election year 2025.

Applicable Laws and Rules 

A committee that selects the Full Reporting option on their C-1 report is required to report contributions and expenditures to the PDC on Cash Receipts Monetary Contributions reports (C-3 reports) and Campaign Summary Receipts & Expenditures reports (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 candidate’s election participation, and their financial activity.

Background and Findings

• The Office & Professional Employees Int’l Union Local No 8 PAC (the Committee) is a Continuing Committee registered under the Full Reporting option.

• The Committee participated in the 2024 and 2025 elections. 

• A complaint received on July 10, 2025, identified that in 2024 the Committee’s final Receipts & Expenditure Summary (C-4) report had an ending balance of $6,304 and the first C-4 report for 2025 had an opening balance of $5,576.54. This carryforward difference indicated something was either missing or in error in the reporting. The Committee audited their 2024 and 2025 reports and made amendments to the C-4s from both years. The corrections were completed by August 11, 2025, and are as follows: 

o The Committee received contributions in February 2024 that were not reported to the Public Disclosure Commission (PDC). A Cash Receipts, Monetary Contributions (C-3) report was filed on July 30, 2025, showing a deposit of $175. The Committee reported contributions totaling $56.46 received in October 2024 that were amended on August 1, 2025, that removed the previously reported $56.46 in contributions. Additionally, there was an expenditure of $1,000.00 to John Traynor on June 28, 2024, for travel costs that was not reported until July 30, 2025. Subsequently, to ensure accurate carryforward balances, multiple C-4s were amended, starting with February 2024 and continuing through July 2025. 

o A C-3 report submitted timely on February 4, 2025, reported $849.48 in contributions received on January 24, 2025. This report was amended on August 1, 2025, to change the contributions received to $813.48. A C-3 submitted five months late on August 6, 2025, for a deposit made on February 4, 2025, showed $625 in contributions received. The C-4 submitted on June 26, 2025, for the period of January 1, 2025, to May 31, 2025, originally showed receipts of $4,423.75 and expenditures of $600, and was amended on August 11, 2025, to reflect a change in receipts to $5,012.75 and expenditures of $1,821.55. 

o The carryforward issue alleged in the complaint, between the 2024 and 2025 elections, was addressed by the audit and subsequent filing and amending of multiple reports as described above. 

• In January 2025, the Committee exceeded the financial activity threshold of $750 in a period, at which time a monthly report became due. The Committee did not submit C-4 reports for the January, February, March, or April reporting periods until June 26, 2025. The corresponding C-3 reports were filed timely. The Committee continued a monthly reporting schedule through August 2025 resulting in the 21- and 7-day pre-primary reports, and the post-primary report, required for committees participating in an election, not being submitted. The August monthly report was submitted two weeks late.

• The Committee continued a monthly reporting schedule, following the primary election, even though it participated in the general election. The 21- and 7-day pre-general election reports, and the post-general report, were not submitted but the monthly reports were submitted timely. The C-3 report for contributions deposited on October 14, 2025, due October 20, 2025, was submitted one week late. In this instance, the Committee did not have the benefit of having resolved the earlier allegations and is being warned for failing to submit reporting on the required schedule for a committee participating in an election. Staff expect that the Committee will timely file all future required reports of contributions and expenditures. 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 Committee has no prior violations of related PDC rules or regulations. 

Summary and Resolution

The Committee completed a Statement of Understanding (SOU) and paid a total $300 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a first occasion of a violation of late and inaccurate reporting on the Cash Receipts, Monetary Contributions (C-3) reports and Receipts & Expenditure Summary (C-4) reports in 2024 and a second occasion of a violation for late and inaccurate filed C-3 reports and late filed C-4 reports during election year 2025. The $300 penalty assessed resolves the allegations listed above.

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).