I Spy a 30-Day Out Report Problem (UPDATED)

I'm looking at the 30-day out campaign finance reports from the Houston municipal candidates. Several things on C.O. Bradford's report caught my eye (he's running in At-Large 4).

One very interesting thing to note is that while Bradford raised $112,945 in contributions, $73,950 of that is in-kind. In other words, 65% of his contributions were donated goods and services and 35% of it was cash. There's nothing wrong with that, except . . .

You Can't Accept More Than $5000 From One Individual

There are contribution limits for City of Houston elections - $5000 for individuals and $10,000 for PACS. This applies to any contribution - cash or in-kind (see Texas Ethics Commission rules - look under "Campaign Contributions".) And, it applies across the whole election period - from the first day you start raising money until Election Day. A cursory look at the reports (the 30-day out and the July 15th report) shows a a couple of violations:

Wendy Richard 3/31/09 $1500 in-kind Consulting/Clerical Services

Wendy Richard 4/30/09 $1500 in-kind Consulting/Clerical Services

Wendy Richard 5/31/09 $1500 in-kind Consulting/Clerical Services

Wendy Richard 6/30/09 $1500 in-kind Consulting/Clerical Services

Wendy Richard 7/1/09 $2000 in-kind Consulting Services

Wendy Richard 8/1/09 $1500 in-kind Consulting Services

Wendy Richard 9/1/09 $1500 in-kind Consulting Services

Richard's principal occupation is business consultant with Richard MGMT, Group, LLC. She donated $11,000 in services to Bradford's campaign - $6000 over the limit.

Here's another apparent violation:

T. Piper Media 7/1/09 $1000 in-kind Social/Media Campaign

T. Piper Media 8/1/09 $3500 in-kind Social/Media Campaign

T. Piper Media 9/1/09 $3500 in-kind Social/Media Campaign

Total contributions were $8000 - $3000 over the limit.

I caught these at first glance, so I'm not sure if there are others like these.

And, There Is An In-Kind That Is Odd

I've looked at a lot of campaign finance reports. If I told you how many, you'd have to tell me I'm weird, and I know you don't want to do that. I've never seen this (and believe me, I thought I'd seen everything):

9/24/09 James Evans $3000 use of personal vehicle/gas for campaign purposes

9/24/09 Dawn Bradford $1800 use of personal vehicle/gas for campaign purposes

9/24/09 Shandina Gay $1500 use of personal vehicle/gas for campaign purposes

9/24/09 C.O. Bradford $4000 use of personal vehicle/gas for campaign purposes

9/24/09 Joe Mitchell $500 use of personal vehicle/gas for campaign purposes

9/24/09 Syed Hashimi $2000 use of personal vehicle/gas for campaign purposes

9/24/09 Larry Payne $2000 use of personal vehicle/gas for campaign purposes

I've never seen use of personal cars - particularly for the candidate - show up as an in-kind donation to a campaign. I'm not sure why you would want to do this - for transparency or to make your "Total Political Contributions" number look larger.

(Note that Sept. 24th was the last day to make a contribution that would show up on the 30-day out report. That's why you will see that date repeatedly on the reports - lots of last minute donations.)

There are other interesting in-kinds on the report. Check them out. What's the remedy for the violations of accepting contributions over the limit? My understanding is that Bradford is going to have to write a check to Wendy Richard for $6000 and one for $3000 to T. Piper Media. The sooner the better, so that if a complaint is filed with the TEC, he can say he's already remedied the situation. (And, no, I am not filing a complaint.) As a matter of fact, I believe there is a TEC rule that if you catch your own mistake within a certain time period (10 days?) - and correct it - a complaint will not be accepted. The Bradford campaign might want to check on that, although I think it would mean moving some of that in-kind to an expense, which would affect the cash on hand to $9,000 less than it is now.

All I can say is that paying real money for real fundraising and compliance expertise is always worth it.

Has anyone spotted anything else in a report that looks odd? Let us know in the comments.

UPDATE: I found more. Looks like Bradford needs to write checks to a couple more people:

James Evans, III & Associates	5/31/09	$500	in-kind	use of office space
James Evans, III & Associates	6/30/09	$500	in-kind	use of office space
James Evans	6/30/09	$3000	in-kind	use of vehicle for vehicle/ gas campaign use
James Evans, III & Associates	4/30/09	$500	in-kind	use of office space
James Evans, III & Associates	3/31/09	$500	in-kind	use of office space
James Evans	9/24/09	$3000	in-kind	use of vehicle for vehicle/ gas campaign use
James Evans, III & Associates	7/1/09	$500	in-kind	office space
James Evans, III & Associates	8/1/09	$500	in-kind	office space
James Evans, III & Associates	9/1/09	$500	in-kind	office space
	Total	$9500
Peter Rene	4/1/09	$5000	in-kind	website design/management
Peter Rene	9/24/09	$5000	in-kind	photography & video services/website
	Total	$10,000

Even if you argure that James Evans and James Evans, III & Associates are two different donating entities, Bradford still needs to cut two checks worth $6000 from his cash - and possibly $9500.