The Georgia Government Transparency & Campaign Finance Commission voted Dec. 4 to find reasonable grounds that the Georgia Republican Assembly, Inc., and linked entities engaged in activity requiring registration and disclosure under state campaign‑finance law.After a two‑hour staff presentation of subpoenas, vendor records and advertising materials, the commission approved motions to refer the matter to the Office of State Administrative Hearings for further proceedings.

Staff attorney Sean Baywell told commissioners investigators began reviewing GRA Pack LLC’s filings after receiving information about large donor activity and traced payments to vendors including American Campaign Services, Print Source and Minuteman Press. "We were just trying to trace the money," Baywell said, describing subpoenas to vendors and a review of mailers and electronic advertising that he said matched checks coming from a PAC account.

The presentation argued GRA Pack LLC operated as a hybrid organization — both a political action committee and an independent committee — and that the combined activity required separate registration and repeated reporting. Baywell cited emails, website material and bylaws that he said showed the pack was repeatedly described in GRA communications as "our GRA pack," and he pointed to overlapping memberships and communications as evidence of association or control.

Counsel for Georgia Republican Assembly, Derek C. Bernard, appeared by special appearance and disputed jurisdiction. Bernard said the nonprofit and the PAC were separate corporate entities with distinct bank accounts, that GRA Inc. did not expend funds to influence elections, and that the commission has no legal mechanism by which to force GRA Inc. to file the disputed reports. "We deny jurisdiction as to Georgia Republican Assembly, Inc.," Bernard said.

Commissioners pressed both sides on the legal standard for control and on whether evidence of shared messaging and overlapping personnel met the statutory test for an "association, partnership or other group of persons" under OCGA §21‑5‑3. Baywell said staff also would advance an alter‑ego theory if necessary and sought equitable tolling where earlier records predated the complaint. He told the panel he had reviewed roughly 1,000 pieces of evidence and that the combined financial records showed roughly $360,000 in activity in 2022, including substantial donations from entities staff identified in their slides.

After questions and debate, the commission voted to find reasonable grounds that GRA Inc. violated statutes requiring registration as an independent committee and multiple reporting obligations, and that it failed to itemize dozens of independent expenditures. The chair moved the motions and they were approved by voice vote.

The commission’s finding does not constitute a final determination of liability. The matters will be referred to the Office of State Administrative Hearings, which will preside over formal adjudication. Counsel for GRA Inc. preserved the objection that the amended complaint lacked proper sworn verification by staff in the format they contended the statute requires.

The commission’s action follows a stipulation by GRA Pack LLC that reasonable grounds existed for violations as to the LLC; staff emphasized the referral for GRA Inc. addresses additional legal theories and the corporate‑control question.

The hearing record does not list a monetary sanction at this stage; any penalties would be determined following OSA proceedings. The commission clerk said parties have 30 days to address the referral process and coordinate next steps.