FEDERAL ELECTION COMMISSION

WASHINGTON, D.C. 20463

 November 3, 2022 

VIA EMAIL

client@bulldogcompliance.com

Charles Gantt, Treasurer

Conservative Action Fund (formerly Wingman PAC) 

c/o Bulldog Compliance 

138 Conant Street, Suite 202 

Beverly, MA 01915 

RE: MUR 8082 

Dear Mr. Gantt: 

The Federal Election Commission (FEC) received a complaint that indicates

Conservative Action Fund (formerly Wingman PAC) and you in your official capacity as 

treasurer may have violated the Federal Election Campaign Act of 1971, as amended (the “Act”). 

A copy of the complaint is enclosed. We have numbered this matter MUR 8082. Please refer to 

this number in all future correspondence. 

 The Act affords you the opportunity to demonstrate in writing that no action should be 

taken against Conservative Action Fund (formerly Wingman PAC) and you in your official 

capacity as treasurer in this matter. If you wish to file a response, you may submit any factual or 

legal materials that you believe are relevant to the Commission’s consideration of this matter. 

Where appropriate, statements should be submitted under oath by persons with relevant 

knowledge. Your response, which should be addressed to the General Counsel’s Office, must be 

submitted within 15 days of receipt of this letter. If no response is received within 15 days, the 

Commission may take further action based on the available information. 

This matter will remain confidential in accordance with 52 U.S.C. § 30109(a)(4)(B) and 

§ 30109(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be 

made public. Please be advised that, although the Commission cannot disclose information 

regarding an investigation to the public, it may share information on a confidential basis with 

other law enforcement agencies.1

If you intend to be represented by counsel in this matter, please advise the Commission 

by completing the enclosed form stating the name, address and telephone number of such 

counsel, and authorizing such counsel to receive any notifications and other communications 

from the Commission. Please note that you have a legal obligation to preserve all documents, 

records, and materials relating to the subject matter of the complaint until such time as you are 

notified that the Commission has closed its file in this matter. See 18 U.S.C. § 1519. 

1

 The Commission has the statutory authority to refer knowing and willful violations of the Act to the 

Department of Justice for potential criminal prosecution, 52 U.S.C. § 30109(a)(5)(C), and to report information 

regarding violations of law not within its jurisdiction to appropriate law enforcement authorities. Id. § 30107(a)(9). 

MUR808200050
Any correspondence sent to the Commission, such as a response, must be addressed to 

one of the following (note, if submitting via email this Office will provide an electronic receipt 

by email):

Mail OR Email 

Federal Election Commission cela@fec.gov

Office of Complaints Examination 

 & Legal Administration 

Attn: Kathryn Ross, Paralegal 

1050 First Street, NE

 Washington, DC 20463 

 As indicated in the FEC’s Notice found at https://www.fec.gov/legalresources/enforcement/complaints-process/how-to-file-complaint-with-fec/, the FEC has largely 

resumed normal mail operations, but please be advised that processing paper correspondence 

may be delayed. Accordingly, we strongly encourage you to file responses and additional 

correspondence via email.

 If you have any questions, please contact Kathryn Ross at (202) 694-1539. For your 

information, we have enclosed a brief description of the Commission’s procedures for handling 

complaints.

Sincerely,

Roy Q. Luckett

Acting Assistant General Counsel

Complaints Examination &

Legal Administration

MUR808200051