FEDERAL ELECTION COMMISSION

Washington, D.C. 20463 

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of

Aftab Pureval

Aftab for Ohio and Evan Nolan in his official capacity 

as treasurer

Friends of Aftab Pureval 

Drenko Pureval

)

) 

) 

) 

) 

) 

MUR 7507 

STATEMENT OF REASONS OF 

CHAIR SHANA M. BROUSSARD AND COMMISSIONER ELLEN L. WEINTRAUB

This matter involves allegations that Aftab Pureval spent non-federal funds from his Ohio 

local political committee, Friends of Aftab Pureval, (“County Clerk Committee”) to pay for 

various polling and campaign expenses properly attributed to his 2018 federal congressional 

campaign committee, Aftab for Ohio and Evan Nolan in his official capacity as treasurer 

(“Federal Committee”).

The Complaint alleged that between January 2018 and June 2018, the County Clerk 

Committee made payments to five vendors totaling $22,464.58 for obligations of the Federal 

Committee.1

 Based on the available information, the First General Counsel’s Report

recommended finding reason to believe that Aftab Pureval, the County Clerk Committee, and the 

Federal Committee violated the Act and Commission regulations in connection with these 

payments.2

 

We voted twice to approve the Office of General Counsel’s recommendations to find 

reason to believe that the County Clerk Committee transferred, and the Federal Committee and 

1

 Compl. at 4-5.

2

 First Gen. Counsel’s Report at 18. We agreed with the Office of General Counsel that there was also reason 

to believe that Drenko Pureval, Aftab Pureval’s mother, violated the Act and Commission regulations in connection

with contributions she made to the County Clerk Committee. Because her liability depended on whether she knew 

that her non-federal contributions would be used to support a federal race, we thought the appropriate course of 

action would be to authorize an investigation so that we could ask a few simple questions and resolve the matter. 

Our motion to do so did not garner the necessary four votes. First Gen. Counsel’s Report at 14-16; Certification, 

MUR 7507 (Aftab for Ohio, et al.) (July 13, 2021).

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MUR 7507 (Aftab for Ohio, et al.) 

Statement of Reasons of Chair Shana M. Broussard and Commissioner Ellen L. Weintraub

Page 2 of 3 

Aftab Pureval received, non-federal funds totaling $22,464.58 in connection with Pureval’s 

election for federal office in violation of 52 U.S.C. § 30125(e)(1)(A) and 11 C.F.R. § 110.3(d).3 

Several of our colleagues, however, elected not to approve the recommendations of our 

Office of General Counsel, and instead moved to dismiss the allegations relating to payments to 

three of the five vendors, representing $17,727.42 or 79 percent of the total amount at issue.4 By 

way of explanation, our colleagues offer several unpersuasive arguments. 

The lion’s share of the County Clerk Committee’s vendor payments – $16,427.79 – went 

to pay for a poll conducted by GBA Strategies in January 2018. Our colleagues describe the poll 

as “focused on a general survey of the political landscape of Ohio’s 1st Congressional District”5

and asserted that the poll’s information would “doubtlessly” and “significantly benefit [Aftab’s]

County Clerk Committee.”6 By starting with that conclusion, they find it perfectly reasonable 

that the poll’s costs could be allocated between federal and non-federal funds.

They must not have read the same poll that we did – it was attached to the supplemental 

complaint and makes short but compelling reading.7

 The FEC’s Office of General Counsel 

accurately described it as follows:

The poll survey focuses exclusively on Pureval’s viability in the first congressional 

district, and how he compares to the incumbent in federal office. There is no mention of a 

potential run for re-election of his county office. The “Key Findings” detailed in the first 

two pages of the poll survey includes statements in bold noting that “[t]he Republican 

Brand Under Trump Is Weak,” “Pureval Can Build On A Strong Foundation” 

(highlighting that Pureval’s average favorability is higher than Chabot [Pureval’s likely 

opponent in the federal race]), “The Race Begins Very Competitive,” “There Are Strong 

Preliminary contrasts On Taxes, Healthcare & Women,” and “Chabot’s Support Is Soft & 

Persuadable.”8

OGC accurately concluded that this poll, with its “exclusively” federal focus, should have 

been paid for with exclusively federal funds. 

3

 See Certification, MUR 7507 (Aftab for Ohio, et al.) (July 13, 2021).

4

 See Certifications, MUR 7507 (Aftab for Ohio, et al.) (July 13 and 15, 2021).

5

 Statement of Reasons of Vice Chair Allen Dickerson and Commissioners Sean J. Cooksey and James E. 

“Trey” Trainor, III at 3 (Aug. 27, 2021), MUR 7507 (Aftab For Ohio, et al.).

6

 Id. 

7

 See Supplemental Complaint at 3 (Oct. 16, 2018), MUR 7507 (Aftab for Ohio, et al.), found at

https://www.fec.gov/files/legal/murs/7507/7507_6. 

8

 First Gen. Counsel’s Report at 11-12.

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Statement of Reasons of Chair Shana M. Broussard and Commissioner Ellen L. Weintraub

Page 3 of 3 

Our colleagues went on to state that the dismissal of these allegations “was warranted as 

an exercise of prosecutorial discretion in light of the . . . relatively small amounts at issue.”9 

Perhaps somewhat incongruous to the apparent concern over agency resources, they included in 

that same motion a reason to believe finding with respect to the payments to the two remaining 

vendors totaling a mere $4,737.16 and a direction to the Office of General Counsel to enter into 

pre-probable cause conciliation with the Respondents.10 We agree with our colleagues that 

declining to move forward and expend Commission resources on a “relatively small amount” is 

an appropriate exercise of prosecutorial discretion. For that reason and because we did not 

support dismissing the allegations involving nearly 80 percent of the funds at issue, we did not 

vote in favor of their motion. 

____________________ __________________________ 

Date Shana M. Broussard 

Chair

____________________ __________________________ 

Date Ellen L. Weintraub 

Commissioner

9 Statement of Reasons of Vice Chair Allen Dickerson and Commissioners Sean J. Cooksey and James E.

“Trey” Trainor, III at 4, MUR 7507 (Aftab for Ohio, et al.). This matter is distinguished from MUR 6216 (Coakley 

for Senate), cited by our colleagues, where the timing of $21,716 in payments to consultants was at issue. Unlike in 

that matter, the evidence before the Commission in this matter includes a poll that unambiguously and exclusively

referred to and benefited Pureval’s congressional campaign. 

10 Certification, MUR 7507 (Aftab for Ohio, et al.) (July 15, 2021).

August 27, 2021

August 27, 2021

MUR750700153