On three separate occasions the Federal Election Commission (FEC) sent official government oversight inquiries to Mind The Gap Treasurer Graham Gottlieb in response to his ‘secret’ SuperPAC’s failure to properly file information on donors and disbursements.

On February 18, 2019, Maureen Benitz , a Senior Campaign Finance & Reviewing Analyst at Federal Election Commission, wrote to Gottlieb:

“Your amended report discloses an increase in disbursements totaling $18,784.18 from the amounts disclosed on your original report. Please amend your report [again] or provide clarifying information as to why this activity was not disclosed on your original report.”

Benitz transmitted another letter to Gottlieb, a junior staffer in the Obama White House and current Stanford Fellow at The Center for Advanced Study in the Behavioral Sciences, on November 3, 2019.

In this second letter, the United States’ election regulator highlighted the PAC’s failure to properly identify donors:

“Commission Regulations require that a committee discloses the identification of all individuals who contribute in excess of $200 in a calendar year. (11 CFR § 104.3(a)(4)(i)) Identification for an individual is defined as the full name (initials for first or last name are not acceptable), complete mailing address, occupation, and name of employer. (11 CFR § 100.12) Your report discloses contributions from individuals for which the identification is not complete. The following employer name and occupation entries appear on your report and are not considered acceptable: ‘IAS / Executive’ and ‘None / None.'”

The Federal Election Commission’s latest publicly available outreach occurred on November 19, 2019.

In this instance, the Federal Election Commission highlighted mistakes with regard to itemized disbursements:

“Itemized disbursements must include a brief statement or description of why each disbursement was made. Please amend Schedule B supporting Line 21(b) of your report to clarify the following description(s): “Consulting fee” and “Consulting fees.” For further guidance regarding acceptable purposes of disbursement, please refer to 11 CFR 104.3(b)(3)(i).”

“Schedule B of your report discloses disbursements to “ADP Inc.” for “Payroll and associated administrative expenses.”Please be advised that when itemizing disbursements to companies for payroll services, if the payment to the salary recipient aggregates in excess of $200 in a calendar year, a memo entry including the name and address of the individual receiving the salary, as well as the date, amount, and purpose of the original disbursement must be provided.Please amend your report to include the missing information or provide clarifying information if memo items are not required. (11 CFR § 104.9)”

Mind The Gap, led by a longtime ally of George Soros, prides itself on secrecy by not publicly highlighting which Democratic candidates it plans to support in an effort not to prompt conservative PACs from countering their expenditures. Notable figures who have contributed to it’s war-chest coffers include Facebook co-founder Dustin Moskovitz, San Francisco power broker Ron Conway, and former Google executive Shona Brown. A major Joe Biden fundraiser and corporate lobbyist for Comcast, David Cohen, is also a financial backer of Mind the Gap.

Surprisingly, as Vox reported, Mind The Gap’s leadership is comprised of political novices yet they have been able to convince high net worth liberals and Democratic power brokers to bankroll their relatively new SuperPAC; they plan to spend up to $140 million to impact the 2020 elections.

These campaign finance errors reflect the PAC leadership’s lack of political experience. Now that Mind The Gap is on the radar of the Federal Election Commission more mishaps are likely to deter future Democratic donors from teaming up with an organization riddled with amateur campaign finance errors.

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