King County Republican Party Complaint, Nov. 27, 2006
| Some additional King County GOP
Expenditure Reporting Issues in 2005-2006
From: RPope98155@aol.com Dear KCRCC Executive Board Members: I have spent some additional time trying to make heads or tails of King County GOP finances, including why there is a discrepancy (i.e. apparent sudden disappearance) of $30,000 between 12/31/2005 and 01/01/2006. There may be some unreported expenditures by the KCRCC, which made the 2005 year end "Cash on Hand" balance on the PDC forms look larger than it was. For example, Items 1, 2 and 4 below are donations that candidates reported receiving in 2005 from the KCRCC, but which the KCRCC didn't report making. These total $1,300.00. In Items 1 and 3, there is another $1,450.00 that candidates reported getting in 2006 from the KCRCC, which the KCRCC also doesn't report making. I looked at the different items of expense in 2005 and 2006, and what they were for. There appear to be some reporting issues regarding independent expenditures and candidate support that may not have been complied with. For example, on 10/20/2006, $18,763.68 was paid to IQ Direct on 10/20/2006 with the notation "Independent Expenditure". No C6 independent expenditure form appears to have been filed by KCRCC regarding this item. The C6 form has to be filed for all independent expenditures (except those of very small amounts). Filing the C6 has to be done very quickly -- within 24 hours -- for independent expenditures made within 21 days of the general election (i.e. 10/17/2006 and later). And the C6 form requires a fairly detailed description of the independent expenditure -- not only what candidate(s) it was for or against, and the date and amount, but also a pretty good description of exactly what it was being spent on. $22,300.00 was paid to Minnick & Minnick on 10/20/2006 with the notation "Candidate Support". But no indication of which candidates were being benefitted by this in-kind donation(s). Nor did any candidates report this as an in-kind contribution from the KCRCC. Nor was any LMC last minute contribution form filled out by KCRCC -- which is required for any contribution of $1,000 or more within 21 days of the general election (i.e. 10/17/2006 and later). The KCRCC spent $2,100.00 independent expenditures to attack Deb Eddy (presumably the "recovered stolen property" property tax signs) and $9,110.00 to either benefit Donna Watts or hurt her opponent -- both through Madison Communications in October 2006. At least, the KCRCC said these were independent expenditures in some correspondence to the PDC. However, the KCRCC did not file the required C6 independent expenditure forms for these expenditures -- in spite of acknowledging the need to do so in their correspondence with the PDC. There are some reporting concerns for 2005 for monies paid to these same two firms. In 2005, the KCRCC paid $31,576.71 to Minnick & Minnick and $25,509.10 to IQ Direct. Presumably, this $57,085.81 (or at least a major portion thereof) was either an in-kind donation to KCRCC-supported candidates, or an independent expenditure to either benefit Republican candidates or disadvantage their opponents. I could be mistaken, of course, but I cannot understand why the KCRCC would have spent $57,085.81 with these two firms in 2005, unless at least part of the objective was to affect elections that were important to the KCRCC. However, the KCRCC did not file any C6 forms in 2005 showing that independent expenditures were being made. Nor did any candidates in 2005 report receiving any in-kind contributions from the KCRCC that would correspond to any portion of this $57,085.81. Nor does the KCRCC say which candidates were supported by or attacked by this $57,085.81. I have attached an e-mail I sent to Mike Young and Ross Marzolf about this issue, which contains 12 numbered items I was concerned about, and additional detail on each of them. I will make sure this matter gets to the attention of the PDC, as part of their investigation of the formal complaint that I filed yesterday. However, I intend to hold off bringing this up to the PDC for the next 14 days, so that KCRCC staff can make any necessary reporting and/or corrections to existing reports to address the concerns that I have listed. Sincerely, There are several candidates during 2005-2006 who have reported receiving contributions from the King County Republican Central Committee, but the KCRCC does not report making these same contributions (from either the Non-Exempt Account or the Exempt Account): 1. Jane Hague reports receiving $350.00 on 04/26/2005 and another $100.00 on 04/15/2006 from the KCRCC. There does not appear to be any corresponding expenditures by the KCRCC reported to the PDC in relation to these items. 2. Kathy Lambert reports receiving $350.00 on 04/20/2005 from the KCRCC. There does not appear to be any corresponding expenditure by the KCRCC reported to the PDC in relation to this item. 3. Norm Maleng reports receiving $1,350.00 on 01/09/2006 from the KCRCC. There does not appear to be any corresponding expenditure by the KCRCC reported to the PDC in relation to this item. 4. Lynn Rehn reports receiving $450.00 on 10/21/2005 and another $150.00 on 11/11/2005 from the KCRCC. There does not appear to be any corresponding expenditures by the KCRCC reported to the PDC in relation to these items. Some other questions came to my mind when looking at the expenditures (in the cases below, from the KCRCC Non-Exempt account): 5. $2,100.00 was paid to Madison Communications on 10/20/2006, apparently for the Deb Eddy Property Tax signs. This was initially reported as an Last Minute Contribution to the Bret Olson campaign on the LMC forms. Later, an amended LMC form was filed, saying this was in error, and that a C6 independent expenditure form would be filed. No C6 independent expenditure form appears to have been filed regarding this item. 6. $1,760.00 was paid to Madison Communications on 10/20/2006 and another $7,350.00 on 10/30/2006, for a total of $9,110.00, apparently for something to help Donna Watts or hurt her opponent. This was initially reported as an Last Minute Contribution to the Donna Watts campaign on the LMC forms. Later, an amended LMC form was filed, saying this was in error, and that a C6 independent expenditure form would be filed. No C6 independent expenditure form appears to have been filed regarding these items. 7. $18,763.68 was paid to IQ Direct on 10/20/2006 with the notation "Independent Expenditure". No C6 independent expenditure form appears to have been filed regarding this item. 8. $22,300.00 was paid to Minnick & Minnick on 10/20/2006 with the notation "Candidate Support". Your Schedule A does not indicate which candidates are being supported by this expenditure and in what monetary amounts. This is within 21 days of the 11/07/2006 general election. If any candidate was being supported by $1,000.00 or more, you would have had to file a LMC form showing a Last Minute Contribution (presumably in-kind), with the candidate's name, amount and date within 48 hours with the PDC. I could not find any candidate who reported receiving anything from the KCRCC that would correspond with any portion of this $22,300.00. If this was an independent expenditure, instead of an in-kind donation to candidates, no C6 independent expenditure form appears to have been filed regarding this item. 9. Mark Griswold was paid $352.54 on 08/03/2006 as reimbursement for a filing fee. This is the legislature filing fee amount for 2006. However, Griswold was not a candidate for legislature in 2006. Whose filing fee was Griswold being reimbursed for paying? 10. In 2005, substantial sums were paid to Minnick & Minnick: "Professional services" for $1,000.00 on 06/29/2005, $2,000.00 on 09/23/2005, $3,500.00 on 09/27/2005, and $2,410.84; and "General Operation and Overhead" of $13,682.39 on 10/12/2005, $4,839.10 on 10/20/2005, $2,571.13 on 10/27/2005, and $1,573.25 on 11/11/2005; all for a grand total of $31,576.71. Was this money actually for some sort of candidate support and/or independent expenditure? No candidates have reported any corresponding in-kind donations from the KCRCC, nor did the KCRCC file any C6 independent expenditure forms in 2005. 11. In 2005, substantial sums were paid to IQ Direct: "General Operation and Overhead" of $18,130.87 on 10/12/2005, $6,676.19 on 10/20/2005, $2,571.13 on 10/27/2005, and $702.04 on 11/11/2005; all for a grand total of $25,509.10. Was this money actually for some sort of candidate support and/or independent expenditure? No candidates have reported any corresponding in-kind donations from the KCRCC, nor did the KCRCC file any C6 independent expenditure forms in 2005. 12. Conrad Lee was given a contribution of $455.00 on 07/21/2005 from the KCRCC EXEMPT account. (Fortunately, this appears to be the only candidate contribution made from the EXEMPT account.) Is this proper? I thought the EXEMPT account couldn't be used to donate to candidates, since it includes "soft money" contributions from business and other organizations (which are restricted to $3,500 per year or so in contributions to political parties). Hopefully, the KCRCC will do a thorough inspection of its finances over the last two years. All of the problems I have complained about could have been avoided by simply keeping the books up-to-date. If the so-called "checkbook" can be balanced and reconciled, then so can the PDC reports. Sincerely, |