A comment on my blog entry about Del. Jeff Frederick’s fundraiser that seems to be have gone unreported to Virginia State Board of Elections got me thinking. It occurs to me that the fundraiser that Rep. Tom DeLay held for him may have been reported. Just really, really badly.
The trouble is that Frederick’s SBE filing is, shall we say, inadequate.
A little background on Virginia campaign finance may help. It’s pretty easy. Under Virginia law, a campaign can take any amount of money from any person or business. Any individual or business that contributes over $100 in a single election cycle must have their contributions reported in one of the campaign’s scheduled filings to the State Board of Elections. Along with the dollar value of the contribution and the date that the contribution came into the possession of the campaign, the donor’s name, address, employer, and occupation must be specified. Likewise, expenses must be reported, though there’s no floor — even a $0.10 expense must be reported to the SBE. The vendor’s information must be provided — their name, address, plus the specific item or service purchased, along with the date of the expense and the name of the person who authorized the expense. Any payments made via an intermediary service (PayPal, credit card, money order, etc.) should treat the intermediary as invisible — a campaign that pays for everything via money order may not list the USPS as their sole vendor, to the tune of $100,000. They may only record the small administrative fee that the USPS charges to provide a money order.
If you read the preceding paragraph, congratulations, you know how 75% of Virginia’s campaign finance law, functionally-speaking. And you are now equipped to understand why Del. Frederick’s SBE filing is problematic.
For example, there’s the Frederick campaign’s payment to American Express on May 5 for $1,157.46 for “wireless service.” What that means that American Express provided the campaign with some sort of wireless something (Television broadcast? WiFi? Cellular telephones? Who knows?), for which they were paid $1,157.46 on May 5. That strikes me as unlikely — American Express is not, to the best of my knowledge, in the business of providing any sort of wireless service. American Express has also sold the campaign postage, event services, and photocopies. A total of $5,050.54 was paid to American Express as a vendor for a variety of services. Over 14% of all of the Frederick campaign’s expenses went to the company. Has American Express diversified? I’m thinking no. I’m thinking that the $5,050.54 of the expenses listed as going to American Express — 14% of all expenses for the filing period — probably went to other companies entirely, just happened to be put on a charge card, and were improperly reported to the SBE. Was American Express paid $344.06 to hold an event for the Frederick campaign on May 17? Maybe. Or maybe the payment went to somebody else entirely for a wholly different date — like, say, a caterer on April 19. With only the dollar value and the service correctly reported, who knows?
Contributions aren’t much better. A surprisingly large number of contributions come from individuals about whom the Frederick campaign professes to know virtually nothing. Sharon Baber, Jennifer Baker, Nona Bear, Michael Bell…the list just keeps right on going. It’s a total of $5,187 worth of “unknowns.” That’s 28 of his 148 contributions in that period, or 12% of his contributors about whom he doesn’t even know what they do for a living, or perhaps is embarrassed to say. Are they all ex-felons? Do they all work for a plant that renders babies into soap? Or perhaps they all run animal shelters for abandoned puppies? Who knows?
Now, to be fair to Del. Frederick, many of those contributors aren’t even supposed to be in the filing — they’ve contributed $100 or less, and so fall below the reporting threshold. Nineteen of them shouldn’t even be include in the filing, and I can’t imagine why they were included, save for a simple lack of familiarity with campaign finance law.
Filings are a real pain. I know that. Del. Frederick has my sympathies. But this filing is unusually convoluted, as if it was done by somebody who is simply unfamiliar with both the letter and the spirit of Virginia campaign finance law.
Did Del. Jeff Frederick properly file for the event that he held with Tom DeLay on April 19? No, not as far as I can tell. Is the expense in there somewhere? Maybe. I hope, for the sake of the sanity of the beleaguered staff of the Virginia State Board of Elections, that Frederick’s campaign staff will file an amended report to correct all of the problems in this one. I look forward to reading it.