RAD Referral 22L-14

Brady PAC

Page 1 of 2

22L-14

REPORTS ANALYSIS DIVISION REFERRAL

TO

OFFICE OF GENERAL COUNSEL

DATE: May 5, 2022

ANALYST: Andrea Chamorro

I. COMMITTEE: Brady PAC

C00674093

Jeanne Connelly, Treasurer

600 Pennsylvania Ave SE #15180

Washington, DC 20003

II. RELEVANT STATUTE: 52 U.S.C. § 30104(b)

 11 CFR §104.3

III. BACKGROUND:

Failure to Provide Supporting Schedules (Failure to Disclose All Financial Activity)

Brady PAC (“the Committee”) amended its 2020 30-Day Post-General Report to 

disclose a debt totaling $637,615.00 which was not disclosed in the original report 

(Attachment 1).

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

Report covering the period from October 15, 2020 through November 23, 2020. The report 

disclosed no debts on Schedule D, Line 10 (Debts and Obligations Owed by the 

Committee) of the Summary Page (Attachment 1).

On September 1, 2021, the Committee filed an Amended 2020 30-Day PostGeneral Report. The report disclosed a $637,615.00 debt on Schedule D, Line 10 of the 

Summary Page. The entire $637,615.00 was disclosed on Schedule D as newly incurred 

debt for the reporting period.

On October 18, 2021, the Committee filed an Amended 2020 30-Day Post-General 

Report. The report disclosed no change in total debt from the previous amendment, but 

clarified the status of the new debt as disputed (Attachment 1).

MUR809400001
RAD Referral 22L-14

Brady PAC

Page 2 of 2

On January 12, 2022, a Request for Additional Information (RFAI) was sent to the 

Committee referencing the Amended 2020 30-Day Post-General Report, received October 

18, 2021. The RFAI requested clarification regarding the substantial increase in debts 

disclosed in the Amended 2020 30-Day Post-General Report, which were not disclosed in 

the original filing.

On February 4, 2022, the Committee filed an FEC Form 99 (Miscellaneous 

Electronic Submission) in response to the RFAI referencing the Amended 2020 30-Day 

Post-General Report. In part, the Committee stated:

“The additional debts were added to the original reports after it was 

discovered that these were omitted due to an inadvertent and internal 

miscommunication between the committee staff and the compliance firm 

that prepares the reports. Please note that the debt amount reported to 

Mothership Strategies incurred on 11/1/2020 for $637,615.00 (with 

$470,000 remaining) is in dispute.” 

Since February 17, 2022, RAD logged four (4) communications with a 

representative of the Committee which reflect efforts to help the Committee voluntarily 

comply with the Act. RAD was able to connect with the committee on one (1) of these 

occasions and notified Jacqueline Davy, the Committee's Compliance Manager, the matter 

would be referred to another office at the Commission for further review (Attachment 2).

Filings and correspondence related to the Committee can be found here: Brady 

PAC. To date, no further communications have been received from the Committee 

regarding this matter. 

MUR809400002
Brady PAC (C00674093) 

2020 30-Day Post-General Repo1i /Amended 2020 30-Day Post-General Repo1i 

Overview of Additional Debt 

ount IncmTed This 

eriod (Schedule D) 

$0.00 $637,615.00 $637,615.00 $637,615.00 

utstanding Balance 

eginning This Period $0.00 $0.00 $0.00 

Schedule D) 

ayments This Period $0.00 $0.00 $0.00 

Schedule D) 

utstanding Balance at 

lose of This Period $0.00 $637,615.00 $637,615.00 

Schedule D) 

ine 10: Debts and 

bligations Owed by the $0.00 $637,615.00 $637,615.00 

ommittee 

Attachment 1 

MUR809400003
Brady PAC (C00674093) 

Amended 2020 30-Day Post-General Repo1t, received 10/18/2021 

Overview of New Debts Incmred 

Outstanding Amount Increase in 

Vendor Beginning Incurred Payments Debt Incurred Balance 

Mothership Strategies $0.00 $637,615.00 $0.00 $637,615.00 

Total: $0.00 $637,615.00 $0.00 $637,615.00 

Attachment 1 

MUR809400004