FEDERAL ELECTION COMMISSION

Washington, DC 20463

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of 

AB PAC and Rodell Mollineau in his official capacity as 

treasurer (f/k/a American Bridge 21st Century)

Correct the Record and Elizabeth Cohen in her official

 capacity as treasurer 

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MUR 7284 

STATEMENT OF REASONS OF CHAIR SHANA M. BROUSSARD

This matter involves various 2015 transactions between three related entities – 

 independent expenditure only political committee AB PAC and Rodell Mollineau in his official 

capacity as treasurer (formerly known as American Bridge 21st Century) (“AB PAC”), hybrid 

political committee Correct the Record and Elizabeth Cohen in her official capacity as treasurer

(“CTR”) and Section 501(c)(4) corporation American Bridge 21st Century Foundation (“AB 

Foundation”) – that were not properly reported on AB PAC and CTR’s 2015 Year End Reports. 

In April 2019, the Commission found reason to believe that AB PAC violated 52 U.S.C. 

§ 30104(b) by: (1) failing to report a $610,800 debt to the related AB Foundation in connection

with its pre-payment of shared salary and overhead expenses, (2) failing to report an in-kind 

contribution from AB Foundation in connection with its expenditure of $150,000 to lease an 

email list that was provided to AB PAC, and (3) misreporting the purpose of a transfer to AB 

PAC from CTR to compensate AB PAC for the transfer of the email list; and that CTR violated 

52 U.S.C. § 30104(b) by misreporting the purpose of its payment to AB PAC for the email list.1

 

1 Certification, MUR 7284 (American Bridge 21st Century et al.) (Apr. 24, 2019), and Factual and Legal 

Analyses, MUR 7284.

MUR728400380
MUR 7284 (AB PAC/Correct the Record)

Statement of Chair Shana M. Broussard

Page 2 of 3 

The Commission’s Office of General Counsel (“OGC”) investigated this matter between 2019 

and 2020, seeking information as to the circumstances of these transactions and whether there 

was a wider pattern of similar unreported transactions. 

On December 23, 2020, OGC sent AB PAC and CTR separate General Counsel’s Briefs 

indicating it was prepared to recommend that the Commission find probable cause to believe that 

AB PAC violated 52 U.S.C. § 30104(b) by failing to report debt totaling $610,800 owed to 

AB Foundation, failing to report the receipt of the mailing list valued at $150,000 from AB 

Foundation, and misreporting $150,000 of a $400,000 payment Correct the Record made to 

obtain the mailing list; and that the now-defunct CTR violated 52 U.S.C. § 30104(b) by 

misreporting the purpose of the payments it made to AB PAC obtain the mailing list. 

On January 7, 2021, Respondents filed a Joint Reply Brief arguing, among other things, 

that the information pertaining to the mailing list allegation originated from materials “illegally 

obtained by Russian military intelligence and provided to Wikileaks.”2 

Notwithstanding the apparent violation of the Act’s reporting requirements with regard to 

the mailing list transactions, I had equitable concerns about the use of illegally obtained 

WikiLeaks information by the Complainant. Thus, I joined with my colleagues in voting to 

dismiss the allegations relating to the mailing list transactions pursuant to Heckler v. Chaney, 

470 U.S. 821 (1985).3 

2 Id. at 4.

3 Certification, MUR 7284 (AB PAC) (Mar. 11, 2021); Certification, MUR 7284 (Correct the Record) (Mar. 

11, 2021) (recording the Commission’s vote to dismiss the matters as to all Respondents and close the file. 

MUR728400381
MUR 7284 (AB PAC/Correct the Record)

Statement of Chair Shana M. Broussard

Page 3 of 3 

May 18, 2021______ _________________________ 

Date Shana M. Broussard 

Chair

MUR728400382