New: GOP state parties helped funnel millions to the RNC last year in a tried-and-true, bipartisan method of circumventing donation limits. Some indicate, in comments to Axios and FEC filings, that they weren't aware of these transfers until after the fact https://www.axios.com/republicans-state-gop-trump-campaign-cd16bae3-ebf9-4ed5-94de-98a85d23e06c.html?utm_source=newsletter&utm_medium=email&utm_campaign=newsletter_axiossneakpeek&stream=top

This storyline gets a bit into the weeds, so I’m going to break it down here and provide some additional background/data points, including some that didn’t make it into the story but that, I think, illustrate just how interesting this effort appears to have been.

First, the basics: a joint fundraising committee basically “stacks” contribution limits. A JFC that benefits three campaigns, for instance, can accept triple the max individual contribution, and that money can be distributed evenly between the three. This is common practice.

Trump’s JFC was called Trump Victory. The participants were his campaign, the RNC, and 46 state parties. Stack the contrib limits to those and you get a max Trump Victory donation of $817,800, which can be divided among those 48 committees according to standard donation limits.

In 2020, Trump Victory made 260 disbursements to those 46 state parties, totaling more than $75 million. ALL OF THAT MONEY was subsequently—usually on the same day—transferred from the state parties to the RNC. Literally down to the cent. State parties didn’t keep any.

In effect, that meant the RNC was getting not just its own share of JFC cash, but also the states’ shares. In other words, high-dollar Trump Victory donors were giving way more to the RNC via Trump Victory than they could directly by routing the money through state parties first.

That’s become a common maneuver since SCOTUS struck down “aggregate” donation limits in 2015. Hillary pioneered it. Biden did it to a smaller extent. Trump did it in 2016. The ever-deadlocked FEC has never agreed to investigate, despite recommendations by its own general counsel.

But here’s what makes the Trump Victory example so weird: multiple state parties have now indicated, in comments to Axios or filings with the FEC, that they weren’t aware of these six- and seven-transfers—from Trump Victory and to the RNC—at the time they took place.

The chair of the Vermont GOP even asked me to send her the FEC records showing these transfers. She appeared to have no idea what I was talking about. "We have not interfaced with...the national RNC on fundraising," she told me.

The New Mexico GOP belatedly disclosed receiving $559k from Trump Victory last year and immediately transferring that exact same sum to the RNC. The FEC asked about it, and the state party indicated they weren’t even aware of the transfers until about six weeks after the fact.

The Hawaii GOP in Feb belatedly disclosed *1.7M* in transfers from Trump Victory that were immediately sent to the RNC, down to the penny. But it was the other stuff in the HI GOP filing that made it really interesting, and could explain how state parties have been caught unaware

Prior to Feb, the HI GOP had never acknowledged in FEC paperwork, as required, that it was a party to the Trump Victory JFC. It added that info months after getting/transferring that $1.7M. It also noted it had a previously undisclosed bank account—not in HI, but in McLean, VA.

The account was at Chain Bridge Bank, the same one that Trump Victory, the RNC, and other state parties benefitting from the JFC use. The HI GOP told the FEC that the account was “associated” with Trump Victory. Its acting chair refused to elaborate. Here's why that's significant

How could these state parties not be aware that they were receiving and subsequently disbursing six- and seven-figure sums? One possible answer is that the money was flowing through bank accounts "associated" with the national party or its JFC. Control of the accounts is key.

This JFC maneuver is legal, as long as the state parties actually control of the funds before steering them to the national party. But if state party officials weren’t even aware they were receiving/disbursing that money, it's reasonable to ask whether they really controlled it.

The RNC says: "We only accept and disburse contributions in accordance with the law, and the RNC was proud to have invested more in our state parties last cycle than ever before.” And it did! $ funneled back to the RNC were then distributed according to its own funding priorities

But those priorities are different than a predetermined JFC allocation formula that steers as much money to politically noncompetitive states as competitive ones. A national party has an interest in directing that cash in ways that may not align with ordinary contribution limits.

Now, the info above is all in the story, which I implore you to read https://www.axios.com/republicans-state-gop-trump-campaign-cd16bae3-ebf9-4ed5-94de-98a85d23e06c.html?utm_source=newsletter&utm_medium=email&utm_campaign=newsletter_axiossneakpeek&stream=top But there are additional data points that suggest questionable interactions between Trump Victory, the RNC, and the state parties. I’ll go through some of them here.

Four state parties (NC, RI, MD, and GA) reported receiving Trump Victory $, passing along the precise sums they received to the RNC, and itemizing the latter as “JFC transfer” or “JFC distribution.” That suggests the RNC was understood to be the eventual recipient of the money.

Trump Victory made two transfers to the CO GOP in Nov totaling $427,972.11. On the same days, the RNC reported receiving identical contribs from the state party. But the CO GOP never reported disbursements of those funds, perhaps suggesting they weren’t aware of the disbursements

The Alabama GOP reported transferring $920.917.35 to the RNC on Oct 22, 2020. That was *the day before* Trump Victory reported sending the state party that exact sum. How did the state party know to transfer exactly that amount if it hadn’t arrived from the JFC yet?

Anyway, I know this is all very convoluted. The upshot is that both parties have found a really brazen way to circumvent donation limits using their state parties as intermediaries to pocket millions in excess of what the law says they should be able to take from their top donors

Now back to the Masters.