Public Disclosure Commission finds GOP Women did not violate guidelines

PORT ANGELES — The state Public Disclosure Commission found that a complaint filed against the Republican Women of Clallam County did not violate election guidelines in two recent election years.

Filed with the PDC on Aug. 10 by Lisa Ann Dekker, the complaint alleged the RWCC failed to register as a committee and report contributions and expenditures during calendar years 2018 and 2020, a violation of RCW 42.17A.205.

“Washington law defines a political committee as any person, group, club, organization, or collection of individuals (except a candidate or individual dealing with his or her own funds) expecting to receive contributions or make expenditures in support of or in opposition to any candidate or ballot proposition,” PDC staff wrote in its summary of the case.

“Based on staff findings, PDC staff has determined that, in this instance, the failure to register as a committee and report contributions and expenditures during calendar years 2018 and 2020, does not amount to a violation warranting further investigation.”

PDC Interpretation 07-02, state officials said, provides guidance in determining whether an entity that participates in elections by making campaign contributions — but whose campaign activities are only one aspect of an organization’s overall work, is required to register and file reports with the PDC as a ‘political committee.’

“Staff is reminding the RWCC to review PDC Interpretation 07-02 and evaluate if ongoing election activity meets the primary purpose test to register as a political committee,” PDC staff wrote.

In the original complaint, Dekker asserted that RWCC never filed a statement of organization with the PDC nor disclosed its contributions or expenditures.

“The public is entitled to know who is contributing to the Republican Women of Clallam County (RWCC) and how those funds are spent,” Dekker wrote. “The officers of the RWCC have hidden years of activity and thousands of dollars of contributions and expenditures. The PDC must act to ensure that the RWCC follow the law by fully disclosing their organizing information, their contributions, and their expenditures to the public.”

Sarah Kincaid, RWCC president and a candidate for Sequim City Council, wrote in response to the complaint on Aug. 30 that RWCC pays dues as a social club but has no other outside funding source.

She said the club did not solicit contributions from members in 2020 or 2021 to contribute funds to candidates or political committees.

“We do not allocate or budget for contributions to candidates,” Kincaid wrote. “Any donations to candidates come from reserve funds after any obligations have been met.”

See the complaint, response and PDC finding here: pdc.wa.gov/browse/cases/97535.

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