1 FEDERAL ELECTION COMMISSION

2 FIRST GENERAL COUNSEL’S REPORT

3 RAD REFERRAL 22L-14 

4 DATE OF REFERRAL: May 5, 2022 

5 DATE OF NOTIFICATION: May 9, 2022 

6 LAST RESPONSE RECEIVED: May 18, 2022 

7 DATE ACTIVATED: June 30, 2022 

8 

9 EARLIEST SOL: Dec. 1, 2025 

10 LATEST SOL: Oct. 18, 2026 

11 ELECTION CYCLES: 2020 

12 SOURCE: Internally Generated 

13 RESPONDENT: Brady PAC and Jeanne Connelly in her official 

14 capacity as treasurer

15 RELEVANT STATUTE 

16 AND REGULATIONS: 52 U.S.C. § 30104(b)(8)

17 11 C.F.R. § 104.3(d) 

18 11 C.F.R. § 104.11 

19 11 C.F.R. § 116.10(a) 

20

21 INTERNAL REPORTS CHECKED: Disclosure Reports 

22 FEDERAL AGENCIES CHECKED: None 

23 I. INTRODUCTION

24 The Reports Analysis Division (“RAD”) referred Brady PAC and Jeanne Connelly in her 

25 official capacity as treasurer (the “Committee”) to the Office of General Counsel (“OGC”) for 

failing to disclose a $637,615.00 debt on its 2020 30-Day Post-General Report.1 26 The Committee 

27 acknowledges that it failed to report the debt but contends that the omission was inadvertent, 

resulting from staff transition and miscommunication.2 28 The Committee also notes that the debt 

1

 RAD Referral 22L-14 (Brady PAC) (May 5, 2022) (“Referral”).

2

 Resp. at 1 (May 18, 2022).

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1 is related to a dispute with a vendor and indicates it expects the amount of the debt to decrease as 

a result of ongoing negotiations.3 2 In a recent disclosure report, the Committee disclosed a 

settlement of the debt for a reduced amount.4 3 

4 Based on the available information, we recommend that the Commission open a Matter 

5 Under Review (“MUR”) and find reason to believe that the Committee violated 52 U.S.C. 

6 § 30104(b)(8) and 11 C.F.R. § 104.3(b) by failing to report a debt. We also recommend that the 

7 Commission enter into pre-probable cause conciliation with the Committee. 

8 II. FACTUAL BACKGROUND

9 Brady PAC is a multicandidate hybrid political committee that registered with the 

Commission on March 23, 2018.5 10 In the most recent reporting period, the Committee disclosed 

11 $61,565.72 in receipts, $53,603.89 in disbursements, $177,717.14 cash on hand, and 

12 178,076.68.in total debts owed by the Committee, including a $151,000 balance on the debt at 

issue, 6 13

14 On December 1, 2020, the Committee filed its original 2020 30-Day Post-General 

15 Report, which did not disclose any debt incurred between October 15, 2020, through 

November 23, 2020.7 16 The Committee subsequently amended its Report three times: (1) the first 

3

 Id. at 2.

4

 Brady PAC, 2022 August Monthly Report, Form 99 Miscellaneous Electronic Submission at 798-799 

(Aug. 19, 2022); Amended 2022 August Monthly Report (same) (Sept. 20, 2022).

5

 Brady PAC, Statement of Organization (March 23, 2018). The Committee has subsequently filed multiple 

amended Statements of Organization on September 24, 2018; April 19, 2019; July 31, 2019; August 19, 2020; 

October 2, 2020; December 7, 2020; September 15, 2021; and January 28, 2022.

6

 Brady PAC, 2022 12-Day Pre-General Report at 2, 241-242 (Oct. 27, 2022).

7

 Brady PAC, 2020 30-Day Post-General Report at 2 (Summary Page) (Dec. 1, 2020).

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amended report, dated February 8, 2021, disclosed no debts;8 1 (2) the second amended report, 

2 dated September 1, 2021, disclosed $637,615.00 as a newly incurred debt for the reporting 

period;9 3 and (3) the third amended report, dated October 18, 2021, disclosed no change in total 

debt from the previous amendment, but clarified the status of the new debt as disputed10 4 On the 

5 Amended 2020 Year-End Report, the Committee disclosed a payment of $167,615 toward the 

debt, reducing it to $470,000.11 The nature of the debt (purpose) was described as “disputed.”12 6 

7 On January 12, 2022, RAD sent the Committee a Request for Additional Information 

8 (“RFAI”) requesting clarification regarding the increased debt disclosed on the Amended 2020 

9 30-Day Post-General Report, dated October 18, 2021, that had not been disclosed on the original 

report.13 10 On February 4, 2022, the Committee filed a Form 99 Miscellaneous Electronic 

11 Submission acknowledging the omission and stating that it was “due to an inadvertent and 

12 internal miscommunication between the committee staff and the compliance firm that prepares 

13 the report,” adding that the debt reported to the vendor (Mothership Strategies) was incurred on 

November 1, 2020, in the amount of $637,615.00, and that $470,000 remained in dispute.14 14 The 

Committee continued to report the $470,000 as a disputed debt in subsequent reports.15 15 On the 

8

 Brady PAC, Amended 2020 30-Day Post-General Report at 2 (Summary Page) (Feb. 8, 2021).

9

 Brady PAC, Amended 2020 30-Day Post-General Report at 7483 (Sept. 1, 2021).

10 Brady PAC, Amended 2020 30-Day Post-General Report at 7483 (Oct. 18, 2021). 

11 Amended 2020 Year-End Report at 2, 3139 (Oct. 18, 2021). 

12 Id. at 3139.

13 Brady PAC, RFAI at 1 (Jan. 12, 2022).

14 Referral at 2 (quoting Brady PAC, Form 99 Miscellaneous Electronic Submission (Feb. 4, 2022). 

15 Starting with the Amended 2020 Year-End Report (Amendment 3) through the 2022 July Monthly Report, 

the Committee reported the $470,000 debt on the Schedule D, Debts and Obligations Mothership Strategies as 

“Donor Acquisition Advertising – disputed”: Brady PAC, Amended 2020 Year-End Report at 3139 (Oct. 18, 2021); 

Brady PAC, Amended 2021 April Quarterly Report at 2208 (Oct. 18, 2021); Brady PAC, Amended 2021 

Pre-Special Report at 1313 (Oct. 18, 2021); Brady PAC, Amended 2021 July Quarterly Report at 1683 (Oct. 18, 

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1 2022 August Monthly Report, the Committee disclosed a credit of $277,000 to the $470,000 

debt, and a closing balance of $193,000.16 2 The Report included a miscellaneous text stating: 

3 “This adjustment reflects a legal settlement of a disputed debt between the committee and the 

vendor.”17 4 

5 In response to the Referral, the Committee acknowledges its failure to properly report the 

6 debt to the vendor and contends that the omission was inadvertent and due to an oversight due to 

7 staff transition at the time, a miscommunication between the Committee staff and the compliance 

8 firm retained by the Committee to prepare reports, and the disputed nature of a large portion of 

the debt disclosed to the vendor.

18 9 It further contends that the omission was discovered during 

10 an internal review of the dispute between the Committee and the vendor, that they are engaged in 

11 negotiations to resolve the debt and that any potential violation amount “should be reduced to 

reflect the final debt, once the amount is determines.”19 12 Finally, the Committee asserts that 

13 given its “impressive compliance record” and the significant resources it devoted to review and 

2021); Brady PAC, 2021 Year-End Report at 7194 (Jan. 28, 2022); Brady PAC, 2022 February Monthly Report at 

151 (Feb. 18, 2022); Brady PAC, 2022 March Monthly Report at 262 (Mar. 18, 2022); Brady PAC, 2022 April 

Monthly Report at 386 (Apr. 19, 2022); Brady PAC, 2022 May Monthly Report at 523 (May 20, 2022); Brady PAC, 

2022 June Monthly Report at 760 (Jun. 17, 2022); and Brady PAC, 2022 July Monthly Report at 151 (Jul. 20, 2022).

16 Brady PAC, 2022 August Monthly Report at 798 (Aug. 19, 2022); Brady PAC, Form 99 Miscellaneous 

Electronic Submission at 799 (Feb. 4, 2022). The 2022 August Monthly Report and subsequent reports (Amended 

2022 August Monthly Report, 2022 September Monthly Report, and 2022 October Monthly Report) reflect 

payments to the adjusted amount ($193,000) but continue to describe the debt as “Donor Acquisition Advertising – 

disputed.”

17 Brady PAC, 2022 August Monthly Report, Form 99 Miscellaneous Electronic Submission at 798-799 

(Aug. 19, 2022); Amended 2022 August Monthly Report (same) (Sept. 20, 2022). 

18 Resp. at 1. 

19 Id. at 2.

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1 improve its internal processes, as well as the disputed nature of the debt, the Commission should 

take no action or refer this matter to Alternative Dispute Resolution Office (“ADRO”).

20 2 

3 III. LEGAL ANALYSIS

4 Under the Act and Commission regulations, political committees must disclose the 

amount and nature of outstanding debts and obligations until those debts are extinguished.21 5 

6 Debts of $500 or less must be reported no later than 60 days after the obligation is incurred, 

while debts of more than $500 must be reported as of the date the obligation is incurred.22 7 If the 

8 exact amount of a debt or obligation is not known, the report shall state that the amount reported 

is an estimate.23 9 Once the exact amount is determined, a political committee must either: 

10 (1) amend the report(s) containing the estimate; or (2) indicate the correct amount on the report 

for the reporting period in which such amount is determined.24 11

12 Where there is a “disputed debt,” the political committee must report the disputed debt if 

the creditor has provided “something of value” to the political committee.25 13 Until the dispute is 

14 resolved, the political committee must disclose any amounts paid to the creditor, any amount the 

political committee admits it owes, and the amount the creditor claims is owed.26 15 

20 Id. 

21 52 U.S.C. § 30104(b)(8); 11 C.F.R. §§ 104.3(d), 104.11(a). 

22 11 C.F.R. § 104.11(b).

23 Id.

24 Id. 

25 11 C.F.R. § 116.10(a). A “disputed debt” is “an actual or potential debt or obligation owed by a political 

committee, including an obligation arising from a written contract, promise or agreement to make an expenditure, 

where there is a bona fide disagreement between the creditor and the political committee as to the existence or 

amount of the obligation owed by the political committee.” Id. § 116.1(d). 

26 Id. § 116.10(a). 

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1 The Committee acknowledges incurring a debt, related to “something of value” provided 

2 by the vendor to the Committee, in the amount of $637,615.00 on November 1, 2020, with 

$470,000 as disputed.27 3 The Committee was required to but did not disclose the debt on its 

original 2020 30-Day Post-General Report that it filed on December 1, 2020.28 4 The debt was not 

5 disclosed until nearly a year later, on the Amended 2020 30-Day Post-General Report, filed on 

September 1, 2021.29 6 Further, because the debt was in dispute, the Committee was required to 

7 disclose any amounts paid to the creditor, any amount the Committee admits it owes, and the 

amount the creditor claims is owed until the dispute is resolved.30 8 The Committee did not fully 

9 disclose the nature of the debt as disputed until February 4, 2022, after it had received an RFAI 

inquiring about the previously undisclosed debt.31 10 

11 The Committee failed to report a $637,615.00 debt and disputed debt in multiple reports. 

12 While the failure to report appears to be an oversight and the Committee states that it has made 

13 efforts to improve its compliance, the Committee’s disclosure reports remained inaccurate for 

14 over a year. Although the Committee requests that the Commission take no further action on the 

Referral or refer the case to ADRO,

32 15 such a result would be inconsistent with how the 

16 Commission has treated prior respondents in similar circumstances. Instead, in similar matters, 

17 the Commission has found reason to believe and authorized pre-probable cause conciliation, 

27 Brady PAC, Form 99 Miscellaneous Electronic Submission (Feb. 4, 2022). 

28 Brady PAC, 2022 October Monthly Report at 2 (Summary Page) (Oct. 20, 2022).

29 Brady PAC, Amended 2020 30-Day Post-General Report at 7483 (Sept. 1, 2021).

30 11 C.F.R. § 116.10(a). 

31 Brady PAC, Form 99 Miscellaneous Electronic Submission (Feb. 4, 2022). 

32 See Resp. at 2. 

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1 taking the self-reported nature of the reporting violations into account when calculating the civil 

penalty.33 2 

3 This matter was appropriately referred to OGC under Standard 7 of RAD’s Review and 

Referral Procedures.34 4 The amount in violation reflects the amount of the original debt that the 

5 Committee should have disclosed on its original 2020 30-Day Post-General Report, including 

6 any disputed debt. 

7 Accordingly, we recommend that the Commission find reason to believe the Committee

8 violated 52 U.S.C. § 30104(b)(8) and 11 C.F.R. § 104.3(d) by failing to report its debt. 

9 

10

11

12

13

14

15

33 See, e.g., MUR 8000 (Jim Jordan for Congress) (finding reason to believe and authorizing pre-probable 

cause conciliation where, in response to a RAD referral, respondent stated that reporting errors stemmed from an 

inadequate accounting system); MUR 7054 (Oakland County Democratic Party) (finding reason to believe and 

authorizing pre-probable cause conciliation where, in response to a RAD referral, respondent stated that reporting 

errors stemmed, in part, from accounting software problems); MUR 7603 (Wyoming Republican Party, Inc.)

(finding reason to believe and authorizing pre-probable cause conciliation where, in response to a RAD referral, 

respondent stated that reporting errors stemmed from miscommunications between two vendors and requested that 

matter transfer to ADRO).

34 RAD REVIEW AND REFERRAL PROCEDURES FOR THE 2019-2020 ELECTION CYCLE at 85

(non-public) (OGC referral if the amendment is more than business days after the due date of the original

report, which discloses an increase or decrease in receipts or disbursements or debts of or more and, for

non-election sensitive reports, is in excess of when a determination has been made during the OGC

Review and Concurrence Process that the matter(s) in question is better suited for standard processing in OGC.). 

 

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7 

8 V. RECOMMENDATIONS

9 

10 1. Find reason to believe that Brady PAC and Jeanne Connelly in her official 

11 capacity as treasurer violated 52 U.S.C. § 30104(b)(8) and 11 C.F.R. § 104.3(d) 

12 by failing to report a debt; 

13

14 2. Approve the attached Factual and Legal Analysis; 

15 3. Enter into conciliation with Brady PAC and Jeanne Connelly in her official 

16 capacity as treasurer prior to a finding of probable cause to believe;

17

18 4. Approve the attached proposed Conciliation Agreement; and 

19

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1 5. Send the appropriate letters. 

2 Charles Kitcher

3 Associate General Counsel for Enforcement 

4 ___________________ _______________________________________ 

5 Date Jin Lee

6 Deputy Associate General Counsel for Enforcement

7 _______________________________________ 

8 Peter G. Blumberg

9 Assistant General Counsel

10 _______________________________________ 

11 Dominique Dillenseger 

12 Attorney

13 Attachments

14 1.Factual and Legal Analysis 

15

October 27, 2022

T)~ue,, T)~e-r 

MUR809400019
Attachment 1

1 FEDERAL ELECTION COMMISSION

2 

3 FACTUAL AND LEGAL ANALYSIS

4 

5 Respondent: Brady PAC and Jeanne Connolly MUR _____ 

6 in her official capacity as treasurer

7 

8 I. INTRODUCTION

9 The Reports Analysis Division (“RAD”) referred Brady PAC and Jeanne Connelly in her 

10 official capacity as treasurer (the “Committee”) to the Office of General Counsel (“OGC”) for 

failing to disclose a $637,615.00 debt on its 2020 30-Day Post-General Report.1 11 The Committee 

12 acknowledges that it failed to report the debt but contends that the omission was inadvertent, 

resulting from staff transition and miscommunication.2 13 The Committee also notes that the debt 

14 is related to a dispute with a vendor and indicates it expects the amount of the debt to decrease as 

a result of ongoing negotiations. 3 15 In a recent disclosure report, the Committee disclosed a 

settlement of the debt for a reduced amount.4 16 

17 Based on the available information, the Commission finds reason to believe that the 

18 Committee violated 52 U.S.C. § 30104(b)(8) and 11 C.F.R. § 104.3(d) by failing to report a debt. 

19 II. FACTUAL BACKGROUND

20 Brady PAC is a multicandidate hybrid political committee that registered with the 

Commission on March 23, 2018.5 21 In the most recent reporting period, the Committee disclosed 

22 $61,565.72 in receipts, $53,603.89 in disbursements, $177,717.14 cash on hand, and 

1

 RAD Referral 22L-14 (Brady PAC) (May 5, 2022) (“Referral”).

2

 Resp. at 1 (May 18, 2022).

3

 Id. at 2.

4

 Brady PAC, 2022 August Monthly Report, Form 99 Miscellaneous Electronic Submission at 798-799 

(Aug. 19, 2022); Amended 2022 August Monthly Report (same) (Sept. 20, 2022).

5

 Brady PAC, Statement of Organization (March 23, 2018). The Committee has subsequently filed multiple 

amended Statements of Organization on September 24, 2018; April 19, 2019; July 31, 2019; August 19, 2020; 

October 2, 2020; December 7, 2020; September 15, 2021; and January 28, 2022.

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Attachment 1

1 178,076.68.in total debts owed by the Committee, including a $151,000 balance on the debt at 

issue.

6

 2 

3 On December 1, 2020, the Committee filed its original 2020 30-Day Post-General 

4 Report, which did not disclose any debt incurred between October 15, 2020, through 

November 23, 2020.7 5 The Committee subsequently amended its Report three times: (1) the first 

amended report, dated February 8, 2021, disclosed no debts;8 6 (2) the second amended report, 

7 dated September 1, 2021, disclosed $637,615.00 as a newly incurred debt for the reporting 

period;9 8 and (3) the third amended report, dated October 18, 2021, disclosed no change in total 

debt from the previous amendment, but clarified the status of the new debt as disputed.

10 9 On the 

10 Amended 2020 Year-End Report, the Committee disclosed a payment of $167,615 toward the 

debt, reducing it to $470,000.11 The nature of the debt (purpose) was described as “disputed.”12 11 

12 On January 12, 2022, RAD sent the Committee a Request for Additional Information 

13 (“RFAI”) requesting clarification regarding the increased debt disclosed on the Amended 2020 

14 30-Day Post-General Report, dated October 18, 2021, that had not been disclosed on the original 

report.13 15 On February 4, 2022, the Committee filed a Form 99 Miscellaneous Electronic 

16 Submission acknowledging the omission and stating that it was “due to an inadvertent and 

17 internal miscommunication between the committee staff and the compliance firm that prepares 

6

 Brady PAC, 2022 12-Day Pre-General Report at 2, 241-242 (Oct. 27, 2022).

7

 Brady PAC, 2020 30-Day Post-General Report at 2 (Summary Page) (Dec. 1, 2020).

8

 Brady PAC, Amended 2020 30-Day Post-General Report at 2 (Summary Page) (Feb. 8, 2021).

9

 Brady PAC, Amended 2020 30-Day Post-General Report at 7483 (Sept. 1, 2021).

10 Brady PAC, Amended 2020 30-Day Post-General Report at 7483 (Oct. 18, 2021). 

11 Amended 2020 Year-End Report at 2, 3139 (Oct. 18, 2021). 

12 Id. at 3139.

13 Brady PAC, RFAI at 1 (Jan. 12, 2022).

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Attachment 1

1 the report,” adding that the debt reported to the vendor (Mothership Strategies) was incurred on 

November 1, 2020, in the amount of $637,615.00, and that $470,000 remained in dispute.14 2 The 

Committee continued to report the $470,000 as a disputed debt in subsequent reports.15 3 On the 

4 2022 August Monthly Report, the Committee disclosed a credit of $277,000 to the $470,000 

debt, and a closing balance of $193,000.16 5 The Report included a miscellaneous text stating: 

6 “This adjustment reflects a legal settlement of a disputed debt between the committee and the 

vendor.”17 7 

8 In response to the Referral, the Committee acknowledges its failure to properly report the 

9 debt to the vendor and contends that the omission was inadvertent and due to an oversight due to 

10 staff transition at the time, a miscommunication between the Committee staff and the compliance 

11 firm retained by the Committee to prepare reports, and the disputed nature of a large portion of 

the debt disclosed to the vendor.

18 12 It further contends that the omission was discovered during 

13 an internal review of the dispute between the Committee and the vendor, that they are engaged in 

14 Referral at 2 (quoting Brady PAC, Form 99 Miscellaneous Electronic Submission (Feb. 4, 2022)). 

15 Starting with the Amended 2020 Year-End Report (Amendment 3) through the 2022 July Monthly Report, 

the Committee reported the $470,000 debt on the Schedule D, Debts and Obligations Mothership Strategies as 

“Donor Acquisition Advertising – disputed”: Brady PAC, Amended 2020 Year-End Report at 3139 (Oct. 18, 2021); 

Brady PAC, Amended 2021 April Quarterly Report at 2208 (Oct. 18, 2021); Brady PAC, Amended 2021 

Pre-Special Report at 1313 (Oct. 18, 2021); Brady PAC, Amended 2021 July Quarterly Report at 1683 (Oct. 18, 

2021); Brady PAC, 2021 Year-End Report at 7194 (Jan. 28, 2022); Brady PAC, 2022 February Monthly Report at 

151 (Feb. 18, 2022); Brady PAC, 2022 March Monthly Report at 262 (Mar. 18, 2022); Brady PAC, 2022 April 

Monthly Report at 386 (Apr. 19, 2022); Brady PAC, 2022 May Monthly Report at 523 (May 20, 2022); Brady PAC, 

2022 June Monthly Report at 760 (Jun. 17, 2022); and Brady PAC, 2022 July Monthly Report at 151 (Jul. 20, 2022).

16 Brady PAC, 2022 August Monthly Report at 798 (Aug. 19, 2022); Brady PAC, Form 99 Miscellaneous 

Electronic Submission at 799 (Feb. 4, 2022). The 2022 August Monthly Report and subsequent reports (Amended 

2022 August Monthly Report, 2022 September Monthly Report, and 2022 October Monthly Report) reflect 

payments to the adjusted amount ($193,000) but continue to describe the debt as “Donor Acquisition Advertising – 

disputed.”

17 Brady PAC, 2022 August Monthly Report, Form 99 Miscellaneous Electronic Submission at 798-799 

(Aug. 19, 2022); Amended 2022 August Monthly Report (same) (Sept. 20, 2022).

18 Resp. at 1.

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Attachment 1

1 negotiations to resolve the debt and that any potential violation amount “should be reduced to 

reflect the final debt, once the amount is determines.”19 2 Finally, the Committee asserts that 

3 given its “impressive compliance record” and the significant resources it devoted to review and 

4 improve its internal processes, as well as the disputed nature of the debt, the Commission should 

take no action or refer this matter to Alternative Dispute Resolution Office.

20 5 

6 III. LEGAL ANALYSIS

7 Under the Act and Commission regulations, political committees must disclose the

amount and nature of outstanding debts and obligations until those debts are extinguished.21 8 

9 Debts of $500 or less must be reported no later than 60 days after the obligation is incurred, 

while debts of more than $500 must be reported as of the date the obligation is incurred.22 10 If the 

11 exact amount of a debt or obligation is not known, the report shall state that the amount reported 

is an estimate.23 12 Once the exact amount is determined, a political committee must either: 

13 (1) amend the report(s) containing the estimate; or (2) indicate the correct amount on the report 

for the reporting period in which such amount is determined.24 14 

15 Where there is a “disputed debt,” the political committee must report the disputed debt if 

the creditor has provided “something of value” to the political committee.25 16 Until the dispute is 

19 Id. at 2.

20 Id. 

21 52 U.S.C. § 30104(b)(8); 11 C.F.R. §§ 104.3(d), 104.11(a). 

22 11 C.F.R. § 104.11(b).

23 Id.

24 Id. 

25 11 C.F.R. § 116.10(a). A “disputed debt” is “an actual or potential debt or obligation owed by a political 

committee, including an obligation arising from a written contract, promise or agreement to make an expenditure, 

where there is a bona fide disagreement between the creditor and the political committee as to the existence or 

amount of the obligation owed by the political committee.” Id. § 116.1(d). 

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Attachment 1

1 resolved, the political committee must disclose any amounts paid to the creditor, any amount the 

political committee admits it owes, and the amount the creditor claims is owed.26 2 

3 The Committee acknowledges incurring a debt, related to “something of value” provided 

4 by the vendor to the Committee, in the amount of $637,615.00 on November 1, 2020, with 

$470,000 as disputed.27 5 The Committee was required to but did not disclose the debt on its 

original 2020 30-Day Post-General Report that it filed on December 1, 2020.28 6 The debt was not 

7 disclosed until nearly a year later, on the Amended 2020 30-Day Post-General Report, filed on 

September 1, 2021.29 8 Further, because the debt was in dispute, the Committee was required to 

9 disclose any amounts paid to the creditor, any amount the Committee admits it owes, and the 

amount the creditor claims is owed until the dispute is resolved.30 10 The Committee did not fully 

disclose the nature of the debt as disputed until February 4, 2022.31 11 Accordingly, the 

12 Commission finds reason to believe that Brady PAC violated 52 U.S.C. § 30104(b)(8) and 

13 11 C.F.R. § 104.3(d) by failing to report a debt.

26 Id. § 116.10(a). 

27 Brady PAC, Form 99 Miscellaneous Electronic Submission (Feb. 4, 2022). 

28 Brady PAC, 2022 October Monthly Report at 2 (Summary Page) (Oct. 20, 2022).

29 Brady PAC, Amended 2020 30-Day Post-General Report at 7483 (Sept. 1, 2021).

30 11 C.F.R. § 116.10(a). 

31 Brady PAC, Form 99 Miscellaneous Electronic Submission (Feb. 4, 2022). 

MUR809400024