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PDC staff outlines uniform penalty approach for late C4 filings: $150 per missed report recommended
Summary
PDC staff told commissioners it had emailed reminders and overdue notices for missing 2025 pre‑primary C4 reports and recommended a standard penalty formula — "we're recommending a $150 per report" — to encourage future compliance across many cases.
Jordan Campbell, a PDC staff member, opened the enforcement portion of the Sept. 23 proceeding by summarizing staff's allegations and explaining the recommended penalty approach for late or missing pre‑primary C4 reports. Campbell said staff sent reminders and overdue notices and that the recommended penalties "might appear higher than usual" because the goal was to encourage compliance for both post‑primary reporting and for candidates who proceed to the general election.
"With all the recommended penalties, it is a—we're recommending a $150 per report," Campbell told the commission. The recommendation provided a baseline that staff used repeatedly in the calendar that followed and informed the fines commissioners entered for the dozens of respondents whose cases were heard that day.
Campbell also explained the administrative steps taken before enforcement — reminder emails before reports were due and overdue notices after deadlines passed — and that staff would follow up with individual respondents about missing reports so they could file within the 30‑day window set out in the orders.
