Things the FEC doesn't like - And they're going after another troon for

[AnOminous]

The FEC griefs Brad over some of his contributors' occupations:
http://docquery.fec.gov/pdf/759/201806100300011759/201806100300011759.pdf
This is proof that someone (besides us) is actually reading this stuff. Over in the Brianna Wu campaign there are tons of entries like the ones they're complaining about here, but no one gives a damn.

The moral: "The List" absolutely exists, and using the UCMJ as toilet paper and then trooning your way out of Leavenworth is a great way to get on it.

As @Kosher Dill points out, the Wu scampaign has a lot of similar noncompliant crap in it.

The FEC has a procedure for reporting this kind of thing. If anyone doesn't care about being doxed or is already doxed, and thinks it's worth their while, that's this:
https://transition.fec.gov/pages/brochures/complaint_brochure.pdf

 

[Kosher Dill]

Anyone trying this should crack the books to find out exactly what the rules are. They dinged Brad for some really petty stuff - an occupation of "Not Employed/Not Employed" is OK but "None/None" is citable.

There are some math errors we could complain about too; if anyone's actually going to file a complaint I could dig them up again.

 

[Null]

If you give me a comprehensive list of things to report I'll file it

 

[AnOminous]

Anyone trying this should crack the books to find out exactly what the rules are. They dinged Brad for some really petty stuff - an occupation of "Not Employed/Not Employed" is OK but "None/None" is citable.

There are some math errors we could complain about too; if anyone's actually going to file a complaint I could dig them up again.

Math errors would be nice.

Also, the specific rule is thoughtfully listed in the FEC's letter to Manning. The language can be something like this:

Commission Regulations require that a committee discloses the identification of all individuals who contribute in excess of $200 in an election cycle. (11 CFR § 104.3(a)(4)(i)) Identification for an individual is defined as the full name (initials for first or last name are not acceptable), complete mailing address, occupation, and name of employer. (11 CFR § 100.12) Wu's report discloses contributions from individuals for which the identification is not complete.

[Insert list here.]

Literally cribbed directly from the letter, so you might want to change wording.

If you give me a comprehensive list of things to report I'll file it

I'll at least dig up the identification things some time today or tonight.

[. . .a little bit later. . .]

Oh, well, that was a dud. While there are a number of entries like that, they're all for people with aggregate donations of less than $200 who Frank doxed despite not needing to do that. Since they weren't required to be disclosed anyway, irregularities in those are meaningless.

The only interesting thing I noted was the last couple quarters have had very few small individual donors.

http://docquery.fec.gov/cgi-bin/forms/C00633669/1223997/sa/ALL
http://docquery.fec.gov/cgi-bin/forms/C00633669/1222054/sa/ALL

However, of the few donors there are, there are a couple $1,000 and $2,000 donations.

John has apparently run out of small donors, or isn't seeking them any more, and is milking a couple whales for his Potbelly budget.

 

[Kosher Dill]

The only interesting thing I noted was the last couple quarters have had very few small individual donors.

No, he just stopped doxing them. Small donors now go under "unitemized contributions" as they would in a normal campaign. As far as I can tell, his take from small donors has been more or less steady over hte past couple quarters.

 

[Dorsia.Reservation]

Bringing this over from the warren thread...

She took a lot of initiative, and paid my friends to help me, and came out with us, and Frank did too. We really wanted to get all the signatures on our own. But we were all too new at it. I think the 800 figure would be accurate had we not found Alex. But at least we tried, unlike the other 2 campaigns.

That's interesting, because none of this is declared in her FEC accounts.
Did you just confess in writing that Wu is spending undeclared money on her campaign? Do you realise that's a crime?

 

[nets_awesome]

As someone mentioned on the main thread, she used scampaign funds to travel to a tall which she was paid for personally (not for the campaign). She disclosed the payment for her talk on the form she published to the house clerk, and she claimed the expenses for the trip on her FEC documents.

 

[Sissy Galvez]

He’s used campaign funds to travel to talks and cons as well as to pick up the first Porsche. She coneveniently labeled them “campaign fundraisers” and “meeting with voters”.

Not sure how you meet with MA-8 voters in Virginia, New York, and San Francisco.

 

[AnOminous]

As someone mentioned on the main thread, she used scampaign funds to travel to a tall which she was paid for personally (not for the campaign). She disclosed the payment for her talk on the form she published to the house clerk, and she claimed the expenses for the trip on her FEC documents.

The disbursements may be a good target, but I’d need to know more than I do about what kinds of nonsense are actually legally acceptable. I know “real” campaigns get away with a lot of shenanigans, though.

 

[stets]

I’ll try to give a more detailed reply tomorrow, but here are a few starting ideas.

Anyone trying this should crack the books to find out exactly what the rules are. They dinged Brad for some really petty stuff - an occupation of "Not Employed/Not Employed" is OK but "None/None" is citable.

There are some math errors we could complain about too; if anyone's actually going to file a complaint I could dig them up again.

Yes, basic math errors are definitely something that will draw the FEC’s attention. Look for totals that don’t add up, numbers that are incorrectly carried over to subsequent reports, etc.

Also make sure that all of the disbursements and loans that Frank made and were later repaid are correctly notated with memos. As you noticed from Brad’s RFAI, the FEC really loves to find minor autistic shit to complain about, and it’s something that they’ll pay attention to.

That's interesting, because none of this is declared in her FEC accounts.
Did you just confess in writing that Wu is spending undeclared money on her campaign? Do you realise that's a crime?

I’d wait until the July report to see if paid canvassers are on the report. They should either be on there as a disbursement and/or a debt owed. She tweeted about getting on the ballot in mid-April, which means the expenses would likely be on the upcoming report. Now that we’ve mentioned it, there’s a 99.9% chance they’ll be on there.

The disbursements may be a good target, but I’d need to know more than I do about what kinds of nonsense are actually legally acceptable. I know “real” campaigns get away with a lot of shenanigans, though.

Ignore all of the tech purchases and unused office rental shit that we like to laugh about.

If you’re looking at expenses, focus on travel expenses that appear to have no legitimate campaign purpose. Check her reports to verify that no money was raised at that location during that time. Cross reference it with social media activity showing what she was actually doing. It has to look painfully obvious that the trip was for personal benefit to get public attention. The Porsche thing, if true, would be fucking perfect.

You can also search the FEC complaint database to see what past complaints have looked like. This will show how to structure a complaint and how the FEC acts on them.

You will have to make this really solid with multiple, crystal clear violations to make the FEC care. You can always tack on things she’s already been cited for in the complaint.

Remember that nothing will likely legally happen as a result of this. Look up Duncan Hunter or Quico Canseco for how bad things have to get before people start to pay attention.

The only real reason to do this, in my opinion, is so there is something formally in the public record about how poorly Wu ran a shitty campaign. It’s more ammo to show how this person is just a perennial loser and grifter. I think that this in and of itself is a noble goal, but it’s not my name going on the complaint.

 

[Kosher Dill]

The only real reason to do this, in my opinion, is so there is something formally in the public record about how poorly Wu ran a shitty campaign.

The reason to do this is to troll Frank by making him write apology letters and re-file old reports yet again.

 

[Richard Stabone]

I don't know the laws on this but I feel like the "reimbursements to Frank Wu" are awfully sketchy. A couple of them say they're for video and travel, but the others are for "campaign expenses". We're talking thousands of dollars here.

Everything they report is a "campaign expense". So classifying reimbursement for them doesn't sound like it'd satisfy the purpose. Otherwise you could just have someone else throw all the expenses on their credit card and never have to say what you're spending money on (since you'd just claim it's a reimbursement).

Frank received $9,308 in reimbursements last year. $2,250 was for a campaign ad. $959 was for travel and a training class. The rest has no actual purpose listed. That's sketchy as fuck.

 

[Richard Stabone]

Sorry for the double post but I think I found something. I looked it over and I can't believe we missed this (or maybe it was brought up). Please correct me if I'm reading this wrong.

Exhibit A
Over the course of 2 days, Brianna traveled to give a speech and attend a candidate workshop. The costs for this were exactly $929. Frank Wu was reimbursed 9 days later for the exact same amount and for the exact same purpose listed.

Exhibit B
Brianna spent $2,250 for the production of a campaign video. It included 2 payments to a company called Runaway Pen Productions. 5 days later Frank Wu was reimbursed for $2,250 for the production of a campaign video.

Now I don't see any loans or other receipts given to the campaign that would offset this. They both are expenditures on the campaign financial filings.

I may be a complete moron and getting this wrong, but it sure looks like double-dipping on expenses. A common form of expense fraud.

Mind you, matching these up was easy since it's one of the two reimbursements that Frank gets that list a purpose. He has a bunch of other reimbursements that don't. Makes me wonder if you added up certain expenses if they'd match his reimbursements.

 

[Kosher Dill]

I may be a complete moron and getting this wrong, but it sure looks like double-dipping on expenses. A common form of expense fraud.

We covered this back when the financials came out, the "reimbursements" are legit. Frank paid for stuff on his credit card and then the campaign paid him back for it. Maybe they technically should have registered a counterbalancing donation from Frank or something, and the paperwork is wrong, but I don't think any actual fraud occurred.
They did get the math wrong on one reimbursement which I'll get to later.

Makes me wonder if you added up certain expenses if they'd match his reimbursements.

All of them can be matched up that way if you know which ones he paid for.

 

[stets]

The reason to do this is to troll Frank by making him write apology letters and re-file old reports yet again.

A proper complaint would take significantly more time than their refiling and explanatory letter time. Who’s trolling who?

All of them can be matched up that way if you know which ones he paid for.

Honestly, it’s pretty surprising how they managed to not screw up Frank’s expenses/reimbursements. You wouldn’t believe how many campaigns can’t get that right. I’m still interested in what numbers you found that didn’t add up.

 

[Richard Stabone]

We covered this back when the financials came out, the "reimbursements" are legit. Frank paid for stuff on his credit card and then the campaign paid him back for it. Maybe they technically should have registered a counterbalancing donation from Frank or something, and the paperwork is wrong, but I don't think any actual fraud occurred.
They did get the math wrong on one reimbursement which I'll get to later.

All of them can be matched up that way if you know which ones he paid for.

Thanks. I figured it was something I wasn't getting right. That would be way too obvious. Probably easier to just charge trips, meals, and whatever electronics you want on Amazon.

I still don't understand how they spent $9,380 for campaign videos. The videos they made are shit high school kids do for A/V class as homework.

 

[Kosher Dill]

Attached a CSV with all the "questionable" donations, though only two of them are over the $200 threshold.
I could have sworn there was a donation from someone in Copenhagen, but I just can't find it anywhere.
99% of this is petty shit like people who wrote "none" instead of whatever the FEC wants, but there were a few people who didn't use their full names, or gave fake addresses.

As for their math errors: in Q2 2017 they spent $959.79 on the Emerge candidate training ($550 for the training itself, $159.09 for Residence Inn, $250.71 at Courtyard by Marriott). Then they reimbursed Frank for the expenditure, but dropped the expenditure completely off their totals. So their reported spending total was $959.79 less than it really should have been, and this error carries through to the "cash on hand" totals on all their subsequent reports.

Then in Q4 2017 everything just gets completely out of whack and their claimed total expenditures are just a couple thousand dollars off from the sum of their itemized expenditures (this time overstating their outlay), and I have no idea how they got there.

EDIT: also I found the rules on "reimbursement" entries.
https://www.fec.gov/updates/interpr...-payees-of-political-committee-disbursements/
Mostly what they're doing looks right, but it seems like combining reimbursements to multiple destinations isn't allowed, it should be one "Reimburse Frank" item for every vendor he bought stuff at, tagged with which it was.

 

[stets]

@Kosher Dill thanks; good work.

I am more than happy to draft a ready-to-file FEC complaint if someone can post or PM me proof of the Porsche trip and/or other documents related to personal trips, and @Null or someone else is willing to publicly file it. While I know election law, I’m not an attorney, so it probably wouldn’t hurt to have @AnOminous or another law fag scan my work as well.

 

[AnOminous]

@Kosher Dill thanks; good work.

I am more than happy to draft a ready-to-file FEC complaint if someone can post or PM me proof of the Porsche trip and/or other documents related to personal trips, and @Null or someone else is willing to publicly file it. While I know election law, I’m not an attorney, so it probably wouldn’t hurt to have @AnOminous or another law fag scan my work as well.

I'll look at it. I think any report should literally be about one page, two at most, possibly with some attachments. It should also be limited to clear violations of actual election law. You don't want to flood them with every little quibble, because they're good at quibbling themselves. There just needs to be at least one thing that demands attention. Once you have their attention, they'll find the other things.

 

[Kosher Dill]

Here's the short-short version:
On the Q2 report, they claim total expenditures of $11311.08 on FEC Form 3 line 22 but the itemized disbursements on Schedule B sum to $12270.87 (because of dropping the Emerge costs)

On the Year-End report, they claim $13544.22 of expenditures on FEC Form 3 line 22 but the itemized disbursements on Schedule B sum to $11834.93 (can't figure out why)

On the Q1 report, reimbursements VTD7E9XN825, VTD7E9XN841, VTD7E9XN8F8, and
VTD7E9XN8H4 to Frank Wu aggregate together multiple ultimate payees.

On the Q2 report, reimbursement VTD7EA174M7 to Frank Wu aggregates together multiple ultimate payees.

Itemized contribution VTE6PDHN9B2 (from Q1) for $500 lists an invalid employer "N/a".

Itemized contribution VTE6PM0VZ40(from Q3) for $500 lists an invalid employer "self".