Clinton Campaign Illegally Purchased “Research” from pro-Democrat Super PAC

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Clinton Campaign Illegally purchased “Research” from American Bridge 21st Century, a pro-Democrat Super PAC, then Lied in their reporting to the Federal Election Commission in an effort to sweep it under the rug


Highlights

  • American  Bridge 21st Century is a Super PAC.  They are prohibited from making coordinated expenditures with Political Candidates
  • Despite this, the Clinton Campaign paid American Bridge 21st Century $22,211 for “Research” on December 4th, 2o15
  • This has gone unnoticed because the transaction was improperly filed as a payment to a “non-political organization”

Note: Hillary for America is the principle campaign committee for Hillary Clinton.  “The Clinton Campaign” and “Hillary for America” are one and the same.

American Bridge 21st Century is registered with the Federal Election Commission (FEC) as an Independent Expenditure-Only Committee, more commonly referred to as a Super PAC.

American Bridge Information

In their own words, “American Bridge 21st Century is a progressive research and communications organization committed to holding Republicans accountable for their words and actions and helping you ascertain when Republican candidates are pretending to be something they’re not.”

 

The Payment

On December 4th, 2015, the Clinton Campaign paid American Bridge 21st Century $22,211 for the purpose of “Research”.

Clinton Payment to American Bridge

On December 4th, 2015, American Bridge 21st Century recorded a receipt from the Clinton Campaign – $22,211 for the purpose of “Research Services”.

American Bridge Receipt

These records have been pulled straight from the FEC’s website and should be viewed as irrefutable facts.  The Clinton Campaign purchased Research from a Super PAC devoted to opposition research on December 4th, 2015.  It happened.

 

Is there a loophole that allowed the Clinton Campaign to do this?

No.

Remember, American Bridge 21st Century is officially classified as an “Independent Expenditure-Only Committee”.

Regarding Independent Expenditures, US Law (52 U.S.C. 30101(17)) provides that

“(c) No expenditure shall be considered independent if the person making the expenditure allows a candidate, a candidate’s authorized committee, or their agents, or a political party committee or its agents to become materially involved in decisions regarding the communication as described in 11 CFR 109.21(d)(2), or shares financial responsibility for the costs of production or dissemination with any such person.”

In English: If a political candidate shares any financial responsibility for the costs of production, the expenditure shall not be considered independent.

Super PACs are allowed to accept unlimited donations under the assumption they refrain from engaging in paid coordination with Political Campaigns.  American Bridge 21st Century is a Super PAC devoted to providing opposition research.  They illegally sold opposition research to the Clinton Campaign over 9 months ago.

 

How has this gone unnoticed for so long?

Note: This gets a bit technical.  

To answer this question, we will need to dig deeper into the data provided on the FEC’s website.  Before doing so, it’s important to point out that American Bridge 21st Century and the Clinton Campaign are registered as Political Committees, and are linked to specific Committee IDs within the FEC.

Hillary for America: C00575795

American Bridge 21st Century: C00492140

In addition, every transaction logged with the FEC is assigned a Transaction ID.  The two IDs associated with the Clinton Campaign’s purchase of Super PAC Research are:

Disbursement from Hillary for America: D79302 

Receipt from American Bridge 21st Century:  VR0E2EF5X91 


Detailed files about Candidates, Parties and other Committees can be found here on the FEC’s website.  Almost all transactions associated with any organization registered with the FEC are dumped into one of these 7 Data Files.

FEC Data Files

Since the Clinton Campaign and American Bridge 21st Century are both registered as Political Committees, this transaction should show up in the “Any Transaction from One Committee to Another” data file.

Transaction from One Committee to Another

But they don’t.  How can this be?  Both the Clinton Campaign and American Bridge 21st Century are registered as Committees. These Transaction IDs should show up in this data file.  What went wrong?


The Clinton Campaign logged their payment to American Bridge 21st Century as an Operating Expenditure.  Let’s look into the “Operating Expenditures” data file.

FEC Operating Expenditures

When we search for the Transaction ID, D79302, in the “Operating Expenditures” data file, we get the following match:

C00575795 |A |2015 |YE |201607059020165524 |23 |F3P |SB |AMERICAN BRIDGE 21ST CENTURY |WASHINGTON |DC| 200012774 |12/04/2015| 22211| P |RESEARCH ||||| ORG |4070720161305465435 |1081052 |D79302 ||

By using Metadata Description provided by the FEC, we can translate this mess into the following.  Most of this can be ignored, save for line 21:

  1. Filer Identification Number: C00575795 (Hillary for America’s FEC Number)
  2. Amendment Number: A (amendment)
  3. Report Year: 2015
  4. Report Type: YE (Year End)
  5. Image Number: 201607059020165524
  6. Line Number: 23
  7. Form Type: F3P (Form 3P for Presidential authorized campaign committees)
  8. Schedule Type: SB
  9. Transfer Name: AMERICAN BRIDGE 21ST CENTURY
  10. City: WASHINGTON
  11. State: DC
  12. Zip Code: 200012774
  13. Transaction Date: 12/04/2015
  14. Transaction Amount: 22211
  15. Primary General Indicator: P (Primary)
  16. Purpose: RESEARCH
  17. Disbursement Category Code: (Blank)
  18. Disbursement Category Code Description: (Blank)
  19. Memo Code: (Blank)
  20. Memo Text: (Blank)
  21. Entity Type: ORG (ORG = Organization (not a committee and not a person))
  22. FEC Record Number: 4070720161305465435
  23. File Number: 1081052
  24. Transaction ID: D79302
  25. Back Reference Transaction ID: (Blank)

Entity Type has been highlighted for a very specific reason.  Metadata Description provides the following options for Entity Type:

  • CAN = Candidate
  • CCM = Candidate Committee
  • COM = Committee
  • IND = Individual (a person)
  • ORG = Organization (not a committee and not a person)
  • PAC = Political Action Committee
  • PTY = Party Organization

See what happened here?  It should be clear by now that American Bridge 21st Century is a Political Committee, a Super PAC.  The Clinton Campaign lied to the FEC by deliberately reporting this as a transaction to an Organization that is NOT a Political Committee.

If the Clinton Campaign properly reported this as a transaction to a PAC, this would have been flagged as a transaction from one Committee to another, and you wouldn’t be reading this report right now.  But here we are.

 

What about the Receipt from American Bridge 21st Century?

This is far less glamorous.  Unfortunately, we can’t verify the other end of this transaction, because American Bridge 21st Century recorded this receipt as an “offset to Operating Expenditure”.  Offsets are typically reserved for refunds, rebates, and returns of deposits.

Regarding Offsets to Operating expenditures, the Sunlight Foundation reports that, “the FEC doesn’t count this money as a contribution (in that it it’s excluded from line 11D)”.  Since the FEC reportedly doesn’t pay much attention to Offsets, should it really be a surprise to anyone that American Bridge 21st Century utilized that bucket to hide their receipt from the Clinton Campaign?

 

Summary

The Clinton Campaign illegally purchased Research Services from American Bridge 21st Century, a pro-Democrat opposition research Super PAC, on December 4th, 2015.  This has gone unnoticed for over 9 months because:

  1.  The Clinton Campaign improperly recorded their disbursement as one to a non-political Organization.
  2.  American Bridge 21st Century recorded their receipt as an Offset to Operating Expenditure, which the FEC reportedly doesn’t monitor.

 

If you have any questions, please let us know in the comments below.

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