Pierce County Democratic Central Committee: Alleged violation of RCW 42.17A.205 for failure to timely report changes to Political Committee Registration (C-1pc) within 10 days of the change. (Jan 2019)

Case

#44695

Respondent

Pierce County Democratic Central Committee

Complainant

Glen Morgan

Description

The Public Disclosure Commission (PDC) has completed its review of the complaints filed by Glen Morgan on October 23, 2018 and January 3, 2019. The complaints alleged that the Pierce County Democratic Central Committee (PCDCC), a bona fide political party committee may have violated: (1) RCW 42.17A.235 and .240 by failing to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; and (2) RCW 42.17A.205 by failing to timely file an amended Committee Registration (C-1pc report) within ten days disclosing any material change in the committee information.

PDC staff reviewed the allegations listed in the two complaints filed; the applicable statutes, rules, and reporting requirements; the response provided by Dominick Bergeron, former Treasurer for Pierce County Democratic Central Committee; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on staff’s review, the alleged late and incomplete filed C-3 and C-4 reports cited in the two complaints were primarily caused by a Committee reorganization and changes in officers, but we noted that the Committee implemented additional internal controls to ensure compliance by creating an oversight committee, by conducting an internal audit, and additional training.  These steps were taken, in part, by the Pierce County Democratic Central Committee to comply with the provisions of the settlement agreement. 

Based on these findings staff has determined that, in this instance, failure to timely and accurately file 19 filed C-3 and C-4 reports, including amendments, mostly disclosed little monetary activity, or were filed as a result of an internal audit process conducted by PCDCC, and therefore does not warrant further investigation or enforcement action.

Pursuant to WAC 390-37-060(1)(d), the PCDCC received a formal written warning concerning failure to timely and accurately file Monetary Contributions reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing contribution and expenditure activities and failure to timely file an amended Committee Registration (C-1pc report) disclosing material changes. The formal written warning included staff’s expectation that PCDCC timely file accurate and complete C-3, C-4 and C-1pc reports in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
 

Disposition

Case Closed with Written Warning

Date Opened

January 07, 2019

Areas of Law

RCW 42.17A.205

Documents

• 44695 Pierce Co Democratic Central Committee Complaint.pdf
• 42704 & 44695 Pierce Co Demo Cent Comm Formal Warning Ltr_0.pdf