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Small political groups' compliance with public disclosure authorities: a gap analysis

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SMALL POLITICAL GROUPS’ COMPLIANCE WITH PUBLIC DISCLOSURE
AUTHORITIES: A GAP ANALYSIS

by

Marvin Rosete

A Dissertation Presented to the
FACULTY OF THE USC ROSSIER SCHOOL OF EDUCATION
UNIVERSITY OF SOUTHERN CALIFORNIA
In Partial Fulfillment of the
Requirements for the Degree
DOCTOR OF EDUCATION

August 2023

Copyright 2023 Marvin Rosete

ii
ACKNOWLEDGEMENTS
Thank you to my chair, Dr. Courtney Malloy and my committee, Dr. Kathy Stowe and
Dr. Chris Roberts, for serving with me on this journey.
Great thanks to the many friends and mentors that helped shape the study and inspired me
to press forward, especially Lloyd Ball, M.Ed., Tetsuden Kashima, Ph.D., Cynthia del Rosario,
M.Ed., Erin Jones, Annabel Garcia-Andresen, M.Ed., Third Andresen, Ph.D., Mario Brown, Erin
Chevront, M.S., Karl deJong, Kelly Drake, Ian Jacobsen, Jeanne Legault, Ph.D., Tiffany
McVeety, M.B.A., Julie Pham, Ph.D., Bill Phillips, Noel Renggli, Laura Williams, Maria Kolby-
Wolfe and Michael Wolfe.
Additional thanks to the treasurers who participated in this study as well as the officers
from the grassroots organizations that make up the Washington State Democrats and the local
Democratic Party organizations. I see the hard work and personal dedication you do for our
neighbors every day. You are my inspiration.
Special thanks to the people of Washington State’s Public Disclosure Commission for
their assistance, quiet dedication to the election process, and unwavering commitment to
protecting the public. You are the heroes in this story.

iii
TABLE OF CONTENTS
Acknowledgements ......................................................................................................................... ii
List of Tables ...................................................................................................................................v
List of Figures ................................................................................................................................ vi
Abstract ......................................................................................................................................... vii
Chapter One: Introduction ...............................................................................................................1
Background of the Problem .................................................................................................2
Importance of the Study .......................................................................................................5
Organizational Context of the Problem: Washington State Democrats ...............................5
Description of Stakeholder Groups ......................................................................................6
Stakeholder Group for the Study: Local Party Treasurers ...................................................7
Purpose of the Study and Questions ....................................................................................9
Overview of the Conceptual and Methodological Framework ............................................9
Definitions..........................................................................................................................10
Organization of the Project ................................................................................................11
Chapter Two: Review of the Literature .........................................................................................12
Background of American Campaign Disclosure Laws ......................................................12
Effects of Campaign Finance Laws in Washington State ..................................................20
Knowledge Influences .......................................................................................................24
Motivation Influences ........................................................................................................28
Organizational Influences ..................................................................................................32
Conceptual Framework ......................................................................................................35
Summary ............................................................................................................................37
Chapter Three: Methodology .........................................................................................................38
Interview Sampling and Recruitment ................................................................................38
iv
Data Collection ..................................................................................................................39
Data Analysis .....................................................................................................................41
Ethics..................................................................................................................................41
Chapter Four: Findings ..................................................................................................................43
Participating Stakeholders .................................................................................................43
Research Question 1 ..........................................................................................................45
Research Question 2 ..........................................................................................................65
Comparisons and Successes ...............................................................................................68
Chapter Five: Recommendations ...................................................................................................71
Factual Knowledge Recommendations..............................................................................71
Organizational Recommendations .....................................................................................77
The Kirkpatrick Model ......................................................................................................80
Limitations and Delimitations ............................................................................................81
Future Research .................................................................................................................82
Conclusion .........................................................................................................................82
References ......................................................................................................................................83
Appendix: Democratic Party Treasurer Study Interview Questions ..............................................93

v
LIST OF TABLES
Table 1: Knowledge Influencers 28
Table 2: Motivational Influencers 32
Table 3: Organizational Influences 34
Table 4: Participating Stakeholders 44
Table 5: Knowledge Findings 45
Table 6: Procedural Knowledge Gaps 52
Table 7: Metacognitive Knowledge Gaps 54
Table 8: Motivational Self-Efficacy Gaps 59
Table 9: Motivational Influences and Goal Orientation Gaps 62
Table 10: Organizational Influence Gaps 65

vi
LIST OF FIGURES
Figure 1: PDC Complaints 3
Figure 2: Common PDC Violations 23
Figure 3: Conceptual Framework 36

vii
ABSTRACT
The purpose of this study was to uncover the knowledge, motivation, and organizational factors
required for treasurers in Washington state to improve compliance measures with campaign
disclosure authorities and reduce infractions and complaints at the federal and state levels.
Numerous studies revealed that campaign finance regulations are complex, confusing, and
burdensome. Specifically, amateur or grassroots organizations were negatively affected by the
large learning curve in conforming to all reporting procedures and laws. Following Clark and
Estes’s method of organizational analysis, party treasurers were selected to uncover knowledge,
motivation, and organizational performance gaps from local Democratic Party organizations.
Treasurers were chosen because of their unique role in the daily administration and maintaining
the financial compliance for the organization. The study applied qualitative research
methodology by collecting data from interviews of active treasurers who were recruited from
local Washington State Democratic Party organizations. The analysis of the interviews revealed
several inconsistencies in training, help-seeking, confidence, setting performance goals, and
organizational behavior. Knowledge, motivation, and organizational recommendations were
offered based on findings to reduce campaign disclosure violations.

1
CHAPTER ONE: INTRODUCTION
Small political organizations in the United States have difficulty following public
disclosure regulations in their jurisdiction. Overcoming this issue is the responsibility of
volunteers from these grassroots organizations, which often leads to complaints and infractions
levied by compliance authorities (Gais & Malbin, 1997). The purpose of this study was to
uncover the knowledge, motivation, and organizational factors required for treasurers in
Washington to improve compliance measures with campaign disclosure authorities and reduce
infractions and complaints at the federal and state levels. Uncovering the knowledge, motivation,
and organizational factors can allow the organization to overcome performance deficiencies. The
deficiencies can also be known as “performance gaps.” Overcoming these deficiencies may
reduce violations and deter those seeking to bring complaints against an organization.
Enforcing these laws is the responsibility of several government agencies. At the national
level, the Federal Election Commission (FEC) is the government agency that oversees publicly
funded federal political campaigns and enforces campaign finance and disclosure laws. To
enforce these laws, the FEC can impose penalties on campaign organizations that violate these
regulations. At the state level, political campaigns with smaller operations operate under local
statutes, which can be complex and ambiguous to ordinary citizens. Yet, citizens are expected to
master all applicable laws for their campaigns (Barr & Klein, 2014).
The consequences of the infractions can differ based on levels of severity. Substantive
infractions include making excessive campaign contributions of $50,000 or more (Lochner &
Cain, 2000) and acts of corruption like direct cash exchanges for political favors (Carpenter &
Milyo, 2012). Enforcement can also be contingent on the publicity of the violation, limited only
to the attention span of the media’s interest (Huckshorn, 1985).
2
However, many cases result from small infractions such as clerical errors or
misunderstanding regulations. For example, from 2001 to 2005, the FEC showed that 63.55% of
the disclosure violation cases it closed were due to improper filing requirements (FEC, 2005).
Infractions also include a failure to file accurately or on time (Lochner & Cain, 2000).
Background of the Problem
In the 1970s, reform for national elections was consolidated in the Federal Election
Campaign Act (1971/1976) with the intent to involve more people to participate in the elections
process at the grassroots level (Alexander, 1980). By 1984, every state adopted a form of
reporting provision requiring disclosure by publicly funded campaigns, candidates seeking
public office or laws governing ethical behavior in politics (Huckshorn, 1985).
Increased Complexity to Comply
The same reforms, designed to deal with campaign abuses, increased the complexity of
how campaigns are run. Numerous studies revealed that campaign finance regulations are
complex, confusing, and burdensome (Alexander, 1980; Barr & Klein, 2014; Milyo, 2007).
Specifically, amateur or grassroots organizations were negatively affected by the learning curve
in conforming to all reporting procedures and laws (Gais & Malbin, 1997). Grassroots
organizations or individuals new to politics produce a disproportionate number of issues
regarding compliance for regulators (Gais & Malbin, 1997).
Problems in Washington State Compliance
Prior to 2016, the number of compliance violations of Washington state campaign
finance law was less than 126 a year (Figure 1). However, by the end of 2016, the number rose to
263 and 831 in 2017, a 315.96% overall increase in 3 years (Public Disclosure Commission
3
[PDC], 2020). The trend of high volumes of violations continued with a 10-year high of 1147
violations by 2021 (PDC, 2022a).

Figure 1
PDC Complaints

Note. 2016 was the first year of increased third-party complaints directed at local Democratic
Party organizations. 2020 was the first year of the COVID-19 pandemic. Statewide lockdown
initiated after March 2020. Adapted from Cases by Public Disclosure Commission, 2022a.
(https://www.pdc.wa.gov/rules-enforcement/enforcement/enforcement-cases)

Around 2018, local Democratic Party organizations faced unexpected legal costs or fines
because of the complaints from their violations (Connelly, 2018; Hill, 2018). The typical kinds
of violations in 2018 brought for enforcement actions were failure to file timely and accurate
contributor reports (182 violations, or 19.80%), failing to register as a political committee (85
cases or 9.25%), and failure to display sponsor identification on political advertising (82 cases,
4
8.92%; PDC, 2022a). Unless experts are utilized, or unskilled volunteers can be made experts in
campaign compliance law, small campaigns and grassroots citizen groups will continue to be
affected (Primo, 2011).
Differences Between Political and Other Nonprofit Organizations
To understand political organizations’ oversight, it is important to understand the
differences between volunteer-run political organizations and other nonprofit organizations also
run by volunteers. Political and other nonprofit organizations are both subject to government
oversight. However, the U.S. federal government and the Internal Revenue Service defined this
difference in greater detail.
The Internal Revenue Service (IRS, 2022a) has the mission to help U.S. taxpayers
understand and meet their tax obligations under the law. Certain organizations are exempt from
paying taxes to the federal government. These include charitable, religious, or education-based
organizations. They can include nationally based nonprofits with a local impact, such as the
United Way (United Way, 2022) or Rotary International (2022).
However, political organizations differ in that political organizations must be organized
and operated for the primary purpose of carrying on activities for influencing, or attempting to
influence, the election of an individual for public office (IRS, 2022c). Depending on the
complexity of the political organizations, these must also file with the Federal Elections
Commission and may be required to pay taxes on their income (IRS, 2022d)
These organizations contrast with charitable organizations, which are restricted in how
much elections or lobbying activity they can conduct. Charitable or other nonprofits may not be
operated to benefit an individual, which certain political campaigns could. Individuals
contributing to a tax-exempt charitable organization may also receive a personal tax deduction
5
(IRS, 2022b). Those contributing to political organizations do not receive this same deduction.
Also, state and local jurisdictions may add extra layers of governance over nonprofit and
political organizations reflecting the local values of the community.
Importance of the Study
This study is important because when the ordinary citizen does not understand the
complexity of campaign finance rules, failure to comply can result in substantial penalties and
fines by enforcement agencies intended to bring violators into line (Huckshorn, 1985). These
penalties also deter the average citizen from participating in the political process (Primo, 2011).
To fulfill their mission of inspiring, recruiting, and coordinating voters, local party
legislative districts (LDs) must avoid or reduce campaign finance violations by complying with
the state’s PDC. If violations continue to occur, any organization caught out of compliance can
be subject to costly PDC fines of up to $10,000 per violation (Washington State Legislature,
1989/2019), risk further penalties and fees if violations run in conjunction with the state attorney
general (Washington State Office of the Attorney General, 2020), and risk a negative reputation
as a fiscally irresponsible organization (Lochner & Cain, 2000).
Organizational Context of the Problem: Washington State Democrats
The Washington State Democrats (WSD) is an organization that provides numerous
examples of volunteers who encounter the challenges of operating small political organizations
in the face of complex regulations. The WSD is part of the Democratic National Committee, one
of the two major political parties in the United States. The mission of the WSD is to nominate
and assist in the election of candidates at all levels of government who support the party’s goals.
1

1
Information regarding the organization originates from information on organizational websites and documents
available in the public domain.
6
State democrats are organized at the local level, including the LDs and county jurisdictions in the
state of Washington. Those involved with the WSD are individuals of legal voting age from one
of the 49 LDs and 39 county organizations.
Volunteers in formal nonprofit associations manage local LD and county organizations.
Where some groups may have paid-staff in a limited capacity, the work (50% or more) is largely
done by the party’s member-volunteers and these groups are considered grassroots organizations
(Smith, 2000). The ultimate authority of the local organizations rests in its body of members.
Members elect officers and decide upon the business of the local party organization. Each party
organization (county and LD) has its own by-laws, officers, and procedures for serving the
unique needs of voters in their jurisdiction.
All elected officers are also non-paid volunteers. At the LD and county organizations, the
officers are generally responsible for the organization’s daily financial accountability and
operations. However, the organizations’ elected chairs or treasurers are the volunteer officers
ultimately submitting reports to the PDC. Other officers are called on to assist in compliance, as
necessary. These compliance duties can require knowledge of bookkeeping and public disclosure
law. The elected volunteers serving as officers might not have specific required knowledge,
expertise, or interest in required compliance practices.
Description of Stakeholder Groups
A stakeholder in an organization is any group or individual who can affect or is affected
by the achievement of the organization’s objectives (Freeman, 2010). Within the Democratic
Party, three distinct stakeholder groups can make appropriate changes to the organization’s
current practices. These are party members, supporters of the organization, and the treasurers of
the organization.
7
Party Members
Party members are local citizens who participate in party activities and are granted direct
benefits from the organization, such as voting rights on party leadership. Members volunteer
with the organization, pay dues, and help raise funds to benefit their local party organization.
Additionally, members elect the officers and leaders at the LD and county levels. All party
members who are at least 18 years old are eligible voters.
Party Supporters
Party supporters include political groups allied with the Democratic Party’s values. These
groups could be civic organizations, labor unions, or businesses. Supporters offer monetary and
non-monetary resources to the Democratic Party to achieve shared political goals. Additionally,
some supporters are located outside the territory of the local organization. Finally, individual
voters are also party supporters. These are voters, who are not members of the organization, but
support the democrats with resources and their votes on election day.
Treasurers
Treasurers, and deputy treasurers, are officers of the local organizations e and can be
elected or appointed. Each treasurer also has specific and assigned roles within the organization.
For example, the treasurers of an organization are specifically responsible for the financial
reporting to the PDC and have enumerated financial obligations in state law (Washington State
Legislature, 1973/2019a).
Stakeholder Group for the Study: Local Party Treasurers
Treasurers of the local party organization were selected as the stakeholders’ group for
this study. Treasurers have a unique role in the daily administration and maintaining the
organization’s financial compliance. Treasurers, like other party officers, must be registered with
8
the agency assigned to regulate the political organization. Registration is particularly important if
the party organization desires to receive political contributions or make expenditures in any
election-based campaign law (Washington State Legislature, 1977/2020a).
Treasurers have unique responsibilities to the law in terms of compliance. For example,
state law requires the treasurer to submit financial records to the state or appropriate local
compliance agency law (Washington State Legislature, 1973/2019). This is especially true in the
United States under FEC laws, where the treasurer is personally responsible for the timely and
complete filing of any required statement and report (Sproul, 1980).
Treasurers are currently recruited from among LD members who are willing to serve.
Treasurers at the county level are selected from among those qualified to vote at county party
meetings. The transition, training and qualifications are also varied among the treasurers. As
state law prescribes, all LD and county organizations still file required financial filings to the
PDC through the online reporting of campaign activity (ORCA) software.
Should treasurers have questions about their filing reports, or clarifications of rules or
law, the PDC was available to be contacted by phone or email. Treasurers could and did contact
each other as their information is available through the state, county and LD parties or in the
public domain on the internet. Additional resources about the law, filing via ORCA or PDC
training are also available at the PDC website.
Along with their compliance obligations under the law, treasurers must attend to other
duties, such as monitoring the organization’s finances, authoring and producing monthly status
reports, and attending regular officer meetings and monthly membership meetings. Typically,
only the treasurer files regular PDC reports on behalf of the organization with some oversight by
the organization’s chair. Where the PDC would sometimes provide some additional training
9
through the internet or in person, there were no programs provided by the organization to
enhance or improve the skills of a treasurer.
Purpose of the Study and Questions
The purpose of this study was to apply Clark and Estes’s (2008) gap analytical
framework to evaluate and understand the areas of knowledge, motivation, and organizational
(KMO) resources necessary to reach the goal of local Democratic Party organizations to reduce
PDC violations. While a complete gap analysis would focus on all stakeholders, for practical
purposes, the stakeholder to be focused on in this analysis are the treasurers or assistant
treasurers of local Democratic Party organizations in Washington. The goals of the study were to
determine the following:
1. What stakeholder knowledge and motivation are required for local Democratic Party
organizations to reduce or eliminate public disclosure violations?
2. What are the organizational factors required to reduce campaign finance violations?
Overview of the Conceptual and Methodological Framework
This study utilized Clark and Estes’s (2008) gap analytical framework to identify and
diagnose performance gaps surrounding KMO challenges and deficiencies. To close
performance gaps, it was important to identify the causes, diagnose the human problems, and
identify appropriate solutions (Clark & Estes, 2008). The gap analysis is a systematic analytical
method to identify deficiencies between the current and targeted performance of the organization
(Clark & Estes, 2008). This analysis was adapted for the needs of local Democratic Party groups
using assumed KMO influencers emerging from the literature. These needs are validated by
using a qualitative study. Interviews were conducted with treasurers; a semi-structured protocol
with open-ended questions was utilized.
10
Definitions
For this study, the following key terms or acronyms were often used among political
organizations with the state of Washington and the state’s Democratic Party. The application of
the terminology would not be unfamiliar to other party organizations in the United States.
Grassroots associations, or organizations, are locally based, volunteer-run, significantly
autonomous, formal nonprofit groups (Smith, 2000). These groups have an official membership
of volunteers who perform most, if not all, of the work. Where there are some paid staff
members, the volunteer members regularly provide 50% or more of the activities to meet the
group’s operative goals (Smith, 2000).
Registered party organizations are organized by the legislative district (LD) organization
and are the smallest chartered organizations recognized by the governing state and national party
(Washington State Legislature, 1993/2018). Each LD elects its own officers to fulfill the roles
the organization needs.
Online reporting of campaign activity (ORCA) is the software Washington’s PDC
provides for campaigns to submit their finance reports. This includes monthly reporting as well
as any supplemental reports as required by law. Originally downloaded and installed on a
personal computer, as of April 27, 2021, ORCA is now a web-based product with the same
functionality (PDC, ORCA 2022).
Political action committee (PAC): Under state law, a political committee means any
person (except a candidate or an individual dealing with the candidate’s or individual’s own
funds or property) expecting to receive contributions or make expenditures in support of, or
opposition to, any candidate running for public office, or any ballot proposition (Washington
State Legislature, Definitions, 1977/2020b)
11
The Public Disclosure Commission (PDC) was created by the passage of Initiative 276 in
1972 for the principal purpose of providing the public with accurate information about certain
financial affairs of candidates and elected officials, the financing of election campaigns, the
sponsors of political advertising, and expenditures made while lobbying (Washington State
Legislature, 2018/2020a)
Organization of the Project
This study is organized into five chapters. Chapter One provides the key concepts and
terminology commonly found when discussing the non-compliance of grassroots political
organizations. This includes the local Democratic Party’s mission, goals, and organizational
stakeholders. Chapter One also introduces concepts of Clark and Estes’s (2008) gap analysis and
how the analysis was adapted to the needs of the Democratic Party to overcome their non-
compliance issues. Chapter Two provides a review of the current literature surrounding the scope
of the study.
Topics include issues surrounding non-compliance as well as KMO influences. Chapter
Three details the assumed needs examined in this study and the methodology for choosing the
participants, data collection, and analysis. In Chapter Four, data and results are assessed and
analyzed, while Chapter Five provides solutions based on the data and supporting literature.
Recommendations for closing perceived gaps, implementing, and evaluating any plan for
solution are presented.
12
CHAPTER TWO: REVIEW OF THE LITERATURE
This chapter provides a general overview regarding the background of campaign finance
disclosure laws nationally and at the local level in the state of Washington. The first part of the
chapter gives a brief background of campaign finance laws in the United States. The unexpected
effect of enforcement laws on grassroots politics is being reviewed. Second, the literature
reviews campaign finance laws in the state, the role of elected volunteer officers in compliance,
and the violations that occur in the state. Third, the chapter introduces the framework of Clark
and Estes’s (2008) KMO influences gap analysis. This analysis will encompass the focus of the
research regarding small political organizations’ current performance gaps. Finally, the literature
review concludes with the conceptual framework guiding this study.
Background of American Campaign Disclosure Laws
In the United States, it is public policy that without campaign disclosure laws, the public
would have inaccurate information about the financing of political campaigns, lobbyist
expenditures, or the financial affairs of candidates and public officials (PDC, 2020). Laws
regulating the disclosure of practices and campaign finances rely on the philosophy coined by
Brandeis (1913), where the sunlight (or openness) of publicity is said to be the best disinfectant
as a remedy for social and industrial diseases. The antiseptic qualities of openness in the political
process ensure transparency in public policy and elections (PDC, 2020). Over time, however,
enforcement of campaign disclosure laws has become layered with complex rules and
regulations (Shepherd, 2018).
Origins of Campaign Finance Disclosure in the United States
The first campaign finance disclosure laws in the United States existed as early as the
1890s. These regulations were enacted at the state level and were provisions of “corrupt
13
practice” laws of the time. Those state-level provisions later became part of the Federal Corrupt
Practices Act, enacted in 1910 (Briffault, 2010). The 1970s saw campaign finance change again
at the national level with the creation of the Federal Election Campaign Act (1971/1976). These
changes were intended to involve more people at the grassroots level to participate in the
elections process (Alexander, 1980).
By 1984, every state created its own disclosure requirements for publicly funded
campaigns. These disclosure laws governed candidates running for public office or created
campaign ethics standards (Huckshorn, 1985). By 2000, at least 40 States began to limit
contributions from individuals and organizations (Primo & Milyo, 2003). These organizations
included corporations, unions, and PACs (Primo & Milyo, 2003).
The Role of Grassroots Volunteers
Around the country, volunteers play a role in political organizations because of their
ability to make the needed operational decisions that affect the outcomes their respective
political group desires to achieve. Federal law requires a volunteer group of neighbors or
nonprofit organizations wanting to spend over $1,000 to address political issues or support a
candidate for public office to register as a political action committee (Barr & Klein, 2014).
Political committees are formed with the expectation of receiving contributions or making
expenditures in support, or opposition, to a ballot proposition or candidate (Washington State
Legislature, 1977/2020b). Officers of these committees would be required to assure that
campaign finance activity is made available to the public through compliance authorities
(Gilbert, 2013).
In Washington, authorized political committees must file a statement of organization, and
shall designate and file with the commission the name and address of one legally competent
14
individual, to serve as a treasurer of the political organization. (Washington State Legislature,
1973/2019). Local Democratic Party organizations, which are registered political committees in
Washington, are administered by a corps of volunteer officers. These officers typically receive
no monetary compensation and are held accountable to the members of their local organization.
Unexpected Effect of Enforcement Laws
Many citizens do not fully understand their own state’s campaign finance disclosure laws
(Rizzardi, 2014). It is also common for legislation to be enacted without lawmakers concerned
about its implementation (Gais & Malbin, 1997). Over time, state disclosure laws have been
enacted and evolved without concern for making compliance easier for participants, especially
for ordinary citizens (Milyo, 2007).
Constant Accidental Mistakes and Violations
Participants can violate the campaign finance disclosure law by accident or
misunderstanding (Lochner & Cain, 2000). The state of California, through its Fair Political
Practices Commission (FPPC), came to this conclusion through its efforts at campaign reporting
reform. From 1980 to 1997, the FPPC determined that approximately 46% of campaign
violations in California were due to reporting inconsistencies (FPPC, 2000). Economist Dr.
Jeffery Milyo also demonstrated the complexity and ambiguity of regulations by surveying 255
ordinary citizens from three states who volunteered to complete the required disclosure
paperwork. This experiment was used to gauge their knowledge of disclosure requirements.
Seven percent of respondents were aware of the required forms to file with the government, and
collectively, the 255 respondents completed just 41% of the tasks correctly (Milyo, 2007).
15
Burdensome Regulations
Along with its complexities, compliance with campaign finance laws can be expensive
and impractical (Barr & Klein, 2014). Financial obligations are often too complicated for
average staffers, and the process can constrain small campaigns by diverting resources and
personnel on compliance versus organizing (Alexander, 1980). New candidates, or those new to
politics, must learn the regulations surrounding campaign finance for their jurisdiction
(Shepherd, 2018). These regulations include filling out candidacy forms while understanding the
legal obligations, responsibilities, and reporting requirements of candidacy (Shepherd, 2018).
Depending on the jurisdiction or campaign, the level of detail of reporting requirements
can be more precise to include keeping records of the identities of those donating, detailed
receipt of expenditures (by certain categories), disbursements (also by categories), and available
cash on hand (Barr & Klein, 2014). For example, at the federal level, the preciseness of record-
keeping includes recording the names and addresses of individuals who contribute $10 or more.
Additionally, contributions over $100 require contributors to disclose their occupation and place
of business (Heerwig & Shaw, 2014).
Esoteric and complicated regulations also set a legal trap for unwary citizens where
political opponents can exploit a superior knowledge of disclosure rules to harass opposing
groups (Milyo, 2007). With the emergence of litigation, the consequences for grassroots
organizations and government attempting to enforce campaign finance rules evolved (Rizzardi,
2014). As a result of burdensome laws, volunteers can be discouraged from participating due to
fear of prosecution by authorities for any alleged violation of reporting requirements, even minor
ones (Gagnon & Palda, 2011).
16
Risk of Reputation
Campaigns and candidates confront risks to reputation due to the potential of campaign
finance violations. Such violations increase negative perceptions and attitudes toward a
campaign (Gaskins et al., 2019). Individual candidates or groups that do not obey rules risk
developing negative reputations with the public and the press (Lochner & Cain, 2000). Voters
may hold groups or candidates accountable for the violations, depending on the seriousness of
the violation (Gaskins et al., 2019). Violations could affect the voter’s perception of intelligence,
or competence, when failing to report contributions correctly (Shepherd, 2018) or accepting
excessive contributions above a donor limit (Gaskins et al., 2019).
Some actions would be considered unethical and affect a candidate’s trustworthiness,
regardless of party affiliation (Gaskins et al., 2019). For example, an unethical use of campaign
funds would be to spend resources on personal matters. Personal use of campaign funds can be
regarded as embezzlement or theft (Gaskins et al., 2019). Such actions could cause voters to
assume that all candidates or campaigns are lawbreakers, eroding the social norms that could
otherwise encourage compliance (Gaskins et al., 2019).
Effect on Grassroots Politics
Burdensome laws and confusing reporting requirements threaten participation by
volunteer citizens and grassroots campaigns (Primo, 2011). When volunteers are frustrated with
completing the work to comply with disclosure laws, the difficulties could deter their future
political activity (Carpenter & Milyo, 2012). The U.S. Supreme Court also recognized that
“[Additional] regulations may create a disincentive for such organizations to engage in political
speech” (FEC v. Massachusetts Citizens for Life, 1986). As statutes become harder to
17
comprehend, paid professional experts become more of a de facto requirement of campaigns to
assure organizational compliance with authorities (Shepherd, 2018).
Vexatious Litigation
One of these legal consequences is the fear of vexatious litigation, where a party
advances, or re-advances, a legal claim despite its merits. Litigants can bring multiple actions
against an organization (Manwell, 1966). Compelling a party into action, regardless of the
litigant’s motive, is allowable under the law because the federal government, and certain states,
allow enforcement of campaign finance laws through third parties, which tends to expose more
trivial violations (Lochner & Cain, 2000; Manwell, 1966).
For example, in 2016, according to a PDC spokesperson, 283 citizen action complaints
for campaign finance violations were filed with the PDC. One individual filed 246 of these
complaints (Barnett, 2018). Such practices reinforce the belief that outsider-initiated, third-party
claims may be frivolous attempts at annoying or discrediting political opponents (Lochner &
Cain, 2000). Litigation turned the PDC from a tool of public transparency to one for opposing
political groups (Camden, 2017) and will continue if the incentive and opportunity remain
(Lochner & Cain, 2000).
Vexatious litigation affects government enforcement entities as well, as requests for
public records or filing complaints can be abused, burdening the enforcement system (Rizzardi,
2014). Legal actions can be taken against the government itself for slow or lack of response to
citizens’ requests. Government organizations could continue to expect legal actions for every
error, ultimately being held responsible for attorney’s fees (Rizzardi, 2014).
18
Risk of Overwhelming Fines
Regulatory enforcement for campaign finance violations almost always involves
monetary fines (Lochner & Cain, 2000). For example, in 2018, Google and Facebook were
ordered to pay the state of Washington fines from $217,000 to $238,000 for failing to maintain
legally required information for political advertising (Connelly, 2018). Another example is the
volunteer-run San Juan County Democrats, which was ordered to pay almost $8,000 in fines due
to incorrect reporting errors (Bagby, 2018). Similarly, the volunteers who operated the Spokane
County Democratic Central Committee, along with three of the organization’s officers, were
ordered to pay almost $72,000 in penalties and almost $11,300 in legal fees to the state of
Washington for failure to file required disclosure forms on time (Connelly, 2018). Due to these
fines, grassroots political organizations that are out of compliance could be deterred from
participating in the political process (Primo, 2011) or cease their operations altogether (Barnett,
2018).
Little or No Accountability by Volunteer Officers
State campaign finance laws can be stringent. This ensures confidence in the oversight of
a state’s electoral system (Moynahan, 1976). Regardless of the type of campaign finance
complaint, volunteer organizers or officers make mistakes (Lochner & Cain, 2000). While
following the law in good faith, these volunteers often respond to these complaints (Lochner &
Cain, 2000). Where organizations are liable for their officers’ mistakes (Horwitz & Mead, 2009),
volunteer leaders are rarely evaluated or accountable for their actions. In terms of liability, the
law encourages insurers to cover volunteer groups (Andrews et al., 2018). However, an
organization is still liable for its officers’ mistakes (Horwitz & Mead, 2009).
19
Volunteer political action organizations have several models for legal compliance and
training (Sproul, 1980). Various resources can assist volunteers with compliance (Alexander,
1980). However, these same volunteer organizations lack the technical and legal expertise to
seek assistance or enact compliance practices appropriately (Sproul, 1980). This lack of
knowledge increases the reluctance of volunteers to serve for fear of violating the law
(Alexander, 1980).
Third-Party Enforcement and Its Impact
Violating campaign finance laws can trigger a complaint to authorities. Three distinct
sources can initiate a complaint and lead to an enforcement action: agency-initiated audit or
investigation, self-submission (where violators report themselves for a possible violation), and
third-party or independent reporting (Skahan, 2018). Typically, among the 50 states and the
federal government, complaints against campaign finance violators come from the enforcement
agency or through third-party enforcement (Lochner & Cain, 2000). Consequently, employing
third-party enforcement disproportionately skews toward lower-level infractions. These smaller
infractions tend to be easy to spot by amateurs but missing larger financial schemes that only
experts can uncover (Lochner & Cain, 2000).
From a study of 79 federal complaints in 1991 and 1993, 21% were initiated by the FEC,
and 73% were brought by third-party respondents (Lochner & Cain, 2000). From these
complaints, 60% were charged with serious or substantive violations, including excessive
contributions of over $50,000 or using misinformation to hide corrupt practices with campaign
funds (Lochner & Cain, 2000). The other 40% were charged with trivial or disclosure violations.
As many as 83% of the disclosure violations were a failure to file or failure to file on time.
(Lochner & Cain, 2000). After 1993, the FEC changed its system to streamline the enforcement
20
of late and failure to file violations. This allowed the FEC to focus on more significant cases,
dismissing 11% of their cases from 2001 to 2005 versus 54% from 1995 to 2000 because of the
large caseload (FEC, 2005).
Effects of Campaign Finance Laws in Washington State
Along with federal legislation, some of the earliest campaign disclosure laws, specific to
Washington, can be traced to the City of Seattle requiring financial disclosure in political
campaigns beginning in 1912 (City of Seattle, 2019). By the 1970s, community organizations
sought stronger statewide legislation for disclosing campaign contributions and expenses. In
1972, Washington residents passed statewide ballot Initiative 276 (Washington Coalition for
Open Government, 2019), creating Washington’s PDC (PDC, 2020). The PDC was tasked with
providing the public with accurate information about certain financial affairs of candidates and
elected officials, about the financing of election campaigns and the sponsors of political
advertising, and about expenditures made in the course of lobbying (PDC, 2020). With the
passage of Initiative 276, Washington became one of 16 states to willingly apply civil sanctions
against campaign finance violators (Huckshorn, 1985).
Violations Within Washington State
From 2010 to 2022, the PDC opened 3413 cases covering over 4801 complaints for
violating several parts of the state’s campaign disclosure and election laws. As of 2022, the
largest number of cases, 1425 (or 45.15%), were initiated and closed by the PDC (2022a). The
remaining cases were complaints initiated by third parties. From 2010 to 2022, private
individuals initiated 586 cases (18.57%; PDC, 2022a).
21
As the research revealed, state disclosure laws were especially complex (Huckshorn,
1985). Scholars empirically studying mandatory disclosure at the state level concluded that even
for well-educated citizens, reporting regimes are difficult to complete (Barr & Klein, 2014).
Updates to the Original Washington State Campaign Finance Law
In 2018, the Washington State Legislature updated the state’s original 1972 campaign
finance enforcement and reporting laws in House Bill 2938 (Washington State Legislature,
2018b). The original 1972 law allowed the PDC, the state’s attorney general, and local
prosecutors to pursue enforcement of Washington’s campaign disclosure laws. However, private
citizens could also pursue enforcement after notifying the state’s attorney general or local
prosecutor of an alleged violation (Elections & Information Technology Committee, 2018).
This also meant private citizens could file an enforcement action with the courts even
while the PDC was investigating the issue and seeking a solution. This invited more litigation
and increased the costs for the public in enforcing the law while frustrating the PDC’s work in
providing transparency (Washington State Legislature, 2018b).
2018 Changes to Law
Washington state’s legislature made the following changes affecting the enforcement of
its campaign finance and disclosure laws as of March 2018:
• The PDC’s enforcement procedures were more clearly defined on how complaints are
handled. The PDC may choose to investigate, initiate actions, dismiss or resolve
matters of compliance within its authority (Washington State Legislature, 2018b).
• Citizen action rules changed to where a citizen must now file all complaints with the
PDC. Citizens can no longer bring enforcement actions directly to the courts should
the PDC or the state’s attorney general’s office not immediately respond. This allows
22
the PDC the opportunity to resolve the case first before the PDC refers the case to the
state’s attorney general (Washington State Legislature, 2018b).
• If a citizen’s action commences, the court may require a person that files with the
court to pay the defendant’s costs and attorney’s fees if the court finds the case was
brought without a reasonable cause (Washington State Legislature, 2018b).
Outcomes of the Changes
The change in legislation eliminated the process that undermined PDC efforts to resolve
technical violations and expedite remedies (Washington State Legislature, 2018b). Also, after
reviewing the data from PDC complaints before and after the changes to the law (PDC, 2022a), it
can be concluded that campaign finance and disclosure laws prior to 2018 did invite many
complaints against small organizations. However, after the change, complaints did not stop.
Also, the changes in law exposed the more common types of violations caused by volunteer
organizations, especially those by Democratic Party organizations (PDC, 2022a).
Violations and Common Complaints by Washington Democratic Party Organizations
With respect to changes in the state law, numerous PDC complaints were still filed
against local Democratic Party organizations. From 2010 to 2022, party organizations received
96 violations (Figure 2). Generally, among the 96 violations, 31.25% of violations were due to
failing to report expenditures, reimbursements, and in-kind contributions accurately and
completely. The second largest number of violations came from failure to file timely reports to
the PDC, representing 27 cases, or 28.13%. Finally, the third most common type of violation was
a failure to register as a political organization. This classification represented 14.58% or 11
violations in 10 years (PDC, 2022a).

23
Figure 2
Common PDC Violations

Note. All violations are from local party organizations only (legislative district and county party
organization). Complaints against the Washington State Democrats are not included. In a 12-year
period, there were 65 complaints with a total of 96 disclosure violations against local Democratic
party organizations. Adapted from Cases by Public Disclosure Commission, 2022a.
(https://www.pdc.wa.gov/rules-enforcement/enforcement/enforcement-cases)

24
Clark and Estes ’s Gap Analytical Framework
Clark and Estes’s (2008) problem-solving process requires understanding a stakeholder’s
goal with respect to the organization’s goal. The problem-solving process examines the
organization and identifies performance gaps and barriers to overcome the gaps. The three causes
of performance gaps relate to individuals’ knowledge and motivation and the organizational
processes affecting them (Clark & Estes, 2008).
These KMO areas are based on general theory, context-specific literature, and an
understanding of the organization. Types of knowledge and skills that can overcome gaps can
fall under four dimensions: factual, conceptual, procedural, and metacognitive (Krathwohl,
2002). Motivational gaps include goal orientation, or why an individual engages in their work
(Yough & Anderman, 2006) and self-efficacy, the belief that if a person can exercise control
over the events that affect their life, they have a stronger incentive to act if they believe that
control is possible and that their actions will be effective (Bandura, 2000). Organizational gaps
include dimensions in organizational culture, the process of work based on values, and
organizational behavior, which investigates the policies or procedures reflecting an
organizational goal (Clark & Estes, 2008).
In the case of the local Democratic Party treasurers, the section will discuss their abilities
to meet their compliance goals and be compliant with the state’s PDC. The study introduces the
assumed KMO influences of the Democratic Party surrounding any organizational or individual
goals to achieve compliance.
Knowledge Influences
For elected volunteer officers of local Democratic Party organizations, knowledge
regarding disclosure compliance affects their operational goal of reaching voters. Achieving any
25
of the organization’s goals requires its stakeholders to address potentially disruptive challenges
in their knowledge gaps (Clark & Estes, 2008). To determine the knowledge and skills of the
stakeholders, Clark and Estes (2008) stated that it is important to understand what stakeholders
need to adapt to changing conditions and what they need to know how to achieve their
performance goals.
Three types of knowledge influencers covered in this study are factual, procedural, and
metacognitive. Factual knowledge affects elements such as terminology, details, and elements of
what must be known (Krathwohl, 2002). Procedural knowledge is knowing the methods of using
skills or techniques to achieve goals (Krathwohl, 2002). Metacognitive knowledge is the
knowledge of oneself as a learner, the aspects of the task at hand, and the control, or planning, of
the strategies one can use to effectively carry out the task (Baker, 2006). Specifically,
metacognitive knowledge is the ability to seek help or know when, where, and how to seek
assistance (Aleven et al., 2003).
Knowing the Fundamental Subject Matter: Factual Knowledge
Volunteers need basic factual knowledge about campaign finance laws and reporting
requirements. Because of the complexity of language in legislation, a candidate, and small
organizations, must learn and understand the regulations to comply (Shepherd, 2018). Numerous
violations of campaign finance law by volunteers occur by accident or a misunderstanding of
basic requirements (Lochner & Cain, 2000). Krathwohl (2002) described factual knowledge as
the basic elements an individual or group must know to be acquainted with a discipline or to
solve problems in it. Additionally, within an organization, individuals should be aware of the
facts or the basic terminology, elements, and contexts to function effectively (Rueda, 2011).
26
Thus, the fundamental nature of factual knowledge, as outlined by Krathwohl (2002), allows the
individual to inject such knowledge into elements required by higher-level processing.
In relation to campaign finance compliance, according to Milyo (2007), treasurers need to
know specific facts regarding legal obligations and specific accounting requirements to navigate
the administrative procedures and forms necessary to comply with disclosure laws. In a study
involving 255 political campaign volunteers, people without special expertise struggled to follow
campaign finance procedures (Milyo, 2007). In the same study, less than 80% of various
compliance tasks were completed.
With the most difficult task, recording anonymous illegal gifts of $1,000, treasurers
succeeded 2% to 8% of the time. These scores demonstrate that a lack of knowledge regarding
campaign finance law terminology generates errors (Milyo, 2007). Disclosure laws provide
details on what needs to be reported, especially regarding contributions and expenditures
(Briffault, 2010). However, knowing the factual elements of terms, limits, and definitions
surrounding campaign finance compliance, treasurers can apply such knowledge to higher-level
process-related functions essential for timely and accurate reporting.
Knowing the Processes for Following Filing Requirements: Procedural Knowledge
Navigating campaign finance laws can be complex (Huckshorn, 1985). However,
treasurers must know the processes for following all campaign finance filing requirements.
Understanding these requirements is defined as learning procedural knowledge. Procedural
knowledge refers to how to do something, including methods of inquiry or learning the criteria
for when to use appropriate procedures, skills, and techniques (Krathwohl, 2002). In American
campaign finance, there is much political learning and adaptation (Sorauf, 1994). Education
regarding regulatory regimes is rapid and intense, and campaigns can find themselves in a new
27
environment with new hazards, limitations, and opportunities. This education also covers
reacting and adapting to new regulatory regimes (Sorauf, 1994).
Literature shows that the organization’s officers, such as the chair or treasurer, should
become familiar with all pertinent laws and filing required disclosures, as rules are complex
(Netterville & Dennis, 1996). In a study of 60 adult participants, experiments demonstrated that
when training is provided, procedural knowledge increases regarding the skilled performance of
tasks, even with limited past experience in a subject (Willingham et al., 1989). Treasurers can be
asked what they believe and the procedures they should learn.
Help-Seeking: Metacognitive Knowledge
Treasurers need to recognize when help-seeking is required and where to seek assistance
with campaign finance filing requirements. Seeking help represents metacognitive knowledge, or
the awareness and knowledge of one’s cognition (Krathwohl, 2002). Specifically, help-seeking is
a process with several steps, including becoming aware of needing help, deciding to seek help,
identifying who can help, and eliciting assistance (Aleven et al., 2003). Like other adult learners,
those seeking help are seeking assistance (LaVallie & Melrose, 2005). It is the intent of help
seekers to increase mastery and competence by obtaining the necessary assistance to accomplish
tasks independently (Lee et al., 2014).
Treasurers seeking help in campaign finance need to have resources available or readily
available online to improve their ability to learn about campaign finance procedures. As a result
of a shift in education, learning is now available with online programs (Wei et al., 2015). In a
study of 102 students, self-efficacy and self-directed learning improved by providing online
academic help-seeking tools that included a blend of live-online learning and on-demand, pre-
recorded videos of relevant content (Chyr et al, 2017).
28
Help-seeking with technology tools has become an important part of contemporary
learning environments (Lee et al., 2014). Officers can be assessed regarding the online assistance
they seek to expand their campaign finance knowledge. In reviewing the assumed knowledge
influencers, Table 1 summarizes and highlights the assumed knowledge influencers.

Table 1
Knowledge Influencers
Knowledge influence Knowledge type Knowledge influence assessment
Treasurers need training in
the fundamental subject
matter of campaign finance
laws and reporting
requirements.
Factual
Data collection via interview.

Treasurers need to know the
processes for following all
campaign finance filing
requirements.
Procedural
Data collection via interview.

Treasurers need to recognize
when help-seeking is
required and where to seek
assistance with campaign
finance filing requirements.
Metacognitive
Data collection via interview.

Motivation Influences
The decision for someone to volunteer is about motivation (Connors, 2011).
Volunteers are seeking compelling reasons to become involved with a nonprofit organization,
whether it is giving time, effort, money, and the ease of access to become involved (Connors,
2011). Lack of motivation will diminish the direction, persistence, and energy to accomplish an
organization’s goal (Clark & Estes, 2008). Motivation requires making an active choice,
29
persistence to pursue an activity over time, and the effort to work smarter and develop novel
solutions (Clark & Estes, 2008).
Volunteers are a sustaining element to the organization and the political activities they
participate in (Alexander, 1980). This is especially true as political money is scarce and where
resources are not readily available for paid professionals to maintain compliance (Alexander,
1980). Motivational variables that this study will cover are self-efficacy and goal orientation.
Self-efficacy is concerned with a person’s belief in their ability to influence events that
affect their lives (Bandura, 2010). Goal orientation is the pattern of beliefs that represent the
different ways of approaching, engaging in, and responding to achievement situations (Ames,
1992; Rueda, 2011). More specific to treasurers will be the emphasis on performance goal
orientation (Ames, 1992). Performance goal orientation focuses on demonstrating ability in front
of others for the purpose of recognition, reward, or avoiding negative judgments on low ability
(Rueda, 2011).
Believing in Own Skills: Self-Efficacy
Treasurers must possess confidence in their own skills and abilities to be in compliance
with campaign finance rules. In other words, treasurers require self-efficacy regarding their
abilities to be more effective. Self-efficacy is where people create an action, through beliefs in
their capabilities, to produce the desired effect by their actions (Bandura, 2000). In other words,
it is the feeling of exerting influence and control to realize the desired future and forestall
undesired outcomes (Bandura, 2000).
The literature suggests that organizations feel discouraged about participating in the
political process because of the responsibility of accurately and timely reporting to public
disclosure authorities (Gagnon & Palda, 2011). Unless stakeholders believe their actions can
30
produce the outcomes they desire, they will have little incentive to act or persevere in the face of
difficulties (Pajares, 2006). Self-efficacy is critical, as individuals, who are confident in their
capabilities to perform productively as a team, are likely to enjoy their jobs and feel committed
to their organization (Borgogni et al., 2011).
In a study of 1,149 middle-level managers, self-efficacy was both directly and indirectly
related to the collective efficacy of the team, which related to an individual’s job satisfaction and
commitment to the organization and its goals (Borgogni et al., 2011). When performing as a
team, stakeholders must develop a strong commitment to a common approach to how they will
work together to accomplish their purpose (Fisher & Cole, 1993). Treasurers also feel personally
empowered if they can articulate their own vision of their role in the organization to accomplish
their tasks (Connors, 2011).
Stakeholders were interviewed if they felt empowered about their roles in the
organization. Additionally, treasurers evaluated their own level of confidence regarding their
ability to fulfill their responsibilities (Connors, 2011). Treasurers were interviewed to ask how
they felt about their own skills and confidence to carry out their responsibilities to the
organization.
Develop Performance Goals: Goal Orientation
Treasurers must develop performance goals to demonstrate their accuracy, timeliness,
and knowledge regarding campaign finance compliance to have fewer compliance violations.
Developing performance goals are an example of goal orientation. Goal orientation is orienting
actions in the achievement of a task (Kaplan & Maehr, 2007) or performance standards to be
attained (VandeWalle, D., 2003). Goal orientation recognizes two methodologies for completing
31
a task, a mastery goal and a performance goal (Yough & Anderman, 2006). Some people may
display either one of the two methodologies or both.
A mastery goal refers to an individual’s purpose of developing competence, which refers
to a student focusing on learning, understanding, developing skills, and mastering information
(Ames, 1992). This leads to a purpose of personal development and growth guiding
achievement-related behavior (Kaplan & Maehr, 2007). Performance goals refer to the
demonstration of competence, focusing on managing the impression that others have of their
ability (Ames, 1992).
Performance goals also include creating an impression of high ability to avoid creating an
impression of low ability (Dweck, 1986). Additionally, in a study of 150 students, who set both
high-mastery and high-performance goals, participants showed that there were no ill effects
when adopting a mindset of achieving both mastery and performance goals at the same time
(Pintrich, 2000). Students who set high goals were concerned about their performance, wanted to
do better in their assignments, and were more motivated to learn and understand the materials
(Pintrich, 2000).
Without clear goals and feedback, the individual’s goals that are not in alignment with
the group, will have a detrimental effect on the group’s performance (Locke & Latham, 2002).
Setting goals allows treasurers to adjust their performance to match what their goal requires
(Locke & Latham, 2012). Treasurers were interviewed to ask what goals would be effective to
set to achieve better compliance. For performance goal-setting purposes, stakeholders will be
interviewed to ask how they feel about establishing performance goals for compliance (Locke &
Latham, 2012). Table 2 shows the motivational goals and includes assumed motivational
32
influences and assessments regarding how to benchmark each motivational assessment (See
Table 2).

Table 2
Motivational Influencers
Motivation influence Motivation type Motivation influence assessment
Stakeholders must possess
confidence in their own
skills and abilities to be in
compliance.
Self-efficacy
Data collection via interview.

Treasurers must develop
performance goals to
demonstrate their accuracy,
timeliness, and knowledge
regarding campaign
finance compliance to have
fewer compliance
violations.
Goal orientation
Data collection via interview.

Organizational Influences
Organizational performance gaps in an organization are caused by a lack of efficient and
effective organizational work processes and material resources (Clark & Estes, 2008).
Regardless of how highly motivated and knowledgeable staff may be, inadequate or ineffective
organizational processes can hamper or prevent the achievement of performance goals. This
achievement is tied to the organization’s culture or work process (Clark & Estes, 2008).
Changing culture affects the process of an organization and the impact of stakeholders
reaching their performance goals (Clark & Estes, 2008). To improve effectiveness, local
Democratic Party organizations must include new best accounting practices, review monetary
costs of compliance, and incorporate professional compliance expertise (Barr & Klein, 2014).
33
Campaign Finance Training: Cultural Change Processes
Training programs must be part of the organization’s cultural process or practice (Rueda,
2011). The need for a stable organization is to ensure that the organization's culture and work
process are compatible and that the work processes can accommodate rapid shifts in challenges
to the organization (Clark & Estes, 2008). Changing the organization’s cultural process requires
training in teamwork and process analysis (Clark & Estes, 2008).
Carpenter and Dunn (2018) reviewed political simulations presented to college students
about campaign finance laws. From 2008 to 2018, students developed a deeper and more
concrete understanding of campaign finance laws through the simulations. They also learned that
modern campaign finance laws are complex (Carpenter & Dunn, 2018). Another study, a review
of 165 published training and development literature from 1960 to 2000, measured the
effectiveness of different training programs (Arthur et al., 2003). The study concluded that
effective training depends on the training method used, the skill (or task) to be trained on, and
the choice of the training evaluation criteria. In terms of assisting treasurers, formal training
enhances skills, productivity, and knowledge for the organization’s staff. Stakeholders will be
asked what courses, specific tasks, and evaluation criteria can be used to assure the effectiveness
of training can create effective outcomes.
Providing Customer Service or Helpdesks: Cultural Model
Treasurers need a place to find answers to questions regarding compliance. Effective
organizational change requires constant communicating with those involved with the
organization’s change, planning, and progress (Clark & Estes, 2008). Information and corrective
feedback can help people adjust to the new knowledge and skills they use to help stakeholders
accomplish their goals (Clark & Estes, 2008).
34
Providing customer service can provide services at the point of need while having a
single place of service to effectively use resources to create an active learning environment
(Venner & Keshmiripour, 2016). In a study of 80 undergraduate students seeking help, 59%
sought out peers, and 47% found assistance with writing centers or instructors (Beisler &
Medaille, 2016). Findings in the same study suggest assistance can expand to encourage more
support and encourage students to seek more assistance whenever possible (Beisler & Medaille,
2016).
Treasurers were interviewed to discover where they sought assistance and asked how
they would be encouraged to seek assistance when needed. Table 3 shows the organizational
goals and includes assumed organizational influences and assessments regarding how to
benchmark each motivational assessment.

Table 3
Organizational Influences
Organizational influences Organization type
Organization influence
assessment
Treasurers needed to include
training programs as part of
the organization’s cultural
process, or practice
Cultural change
processes
Data collection via interview.

Treasurer stakeholders need a
place to find assistance to
answer questions regarding
compliance
Cultural models
Data collection via interview.

35
Conceptual Framework
The conceptual framework is a model explaining the focus of a study (Maxwell, 2013).
Conceptualizing the theoretical framework of the work acts as a guide, or blueprint, that defines
the philosophical, analytical, and methodological approaches to the study (Grant & Osanloo,
2014). A concept map visually describes the phenomenon that is being studied. The diagram
includes how specific KMO gaps are identified and how each gap interacts with each other
(Merriam & Tisdell, 2015). Figure 3 illustrates the overall goal of the organization, which is
compliance with campaign finance disclosure laws.

36
Figure 3
Conceptual Framework

37
All three KMO influencers are depicted inside the circle as core components needed for
the organization to achieve its objective of compliance. Knowledge influences require basic
knowledge for treasurers and improving the means of assistance to treasurers who are working to
assure the organization’s compliance. Motivation influences focus on the emphasis on
compliance skills and creating performance goals for treasurers. Organizational influences
describe overcoming gaps by improving treasurer training and developing internal resources for
those seeking help.
Summary
This chapter sought to present the professional literature regarding campaign finance
disclosure laws and their effect on small political organizations. The literature described the
unexpected effects of campaign finance disclosure laws on the national level and their impact on
local organizations, specifically those in Washington. The literature review also included a
description of the gap analysis framework by Clark and Estes (2008), including KMO influences.
The chapter identified KMO influences and provided insights surrounding the ability of small
political organizations to maintain compliance with public disclosure authorities.

38
CHAPTER THREE: METHODOLOGY
Clark and Estes’s (2008) framework d helps to clarify an organization’s goals and
identify the performance gaps within the individual and organization. As stated in Chapter One,
the purpose of this study was to uncover the KMO factors required for treasurers to improve
compliance measures with campaign disclosure authorities and reduce infractions and complaints
at the federal and state levels. Data on this analysis was acquired by identifying the KMO gaps of
stakeholders by using interviews and analysis of the interview content.
The research questions that framed this study are as follows:
1. What stakeholder knowledge and motivation are required for local Democratic Party
organizations to reduce or eliminate public disclosure violations?
2. What are the organizational factors required to reduce campaign finance violations?
Interview Sampling and Recruitment
For the interviews, selecting a convenience sample was appropriate as the participants are
from a pool of Democratic Party organizations. Participants also had their contact information
available to the general public. Participants were selected from the state’s Democratic Party
organizations, which are regulated by Washington’s PDC. This is a pool of 88 organizations
where 34 Democratic Party organizations (approximately 38.63%) experienced violations or
violations with the PDC in a period from 2010 to 2022 (PDC, 2022a).
Participating Stakeholders
The stakeholders for this study were the treasurers among the local Democratic Party
organizations in the state of Washington. These individuals were those with responsibilities
compelling them to perform any relative compliance or disclosure duties (Gilbert, 2013).

39
Sampling Criteria
To be selected as part of the sample, officers who execute the daily ministerial financial
and compliance functions for their respective organizations. Other officers were substituted if an
organization did not have a treasurer or assistant treasurer to fill the role. This role was filled by
the chair of the local Democratic Party organization.
Recruitment
Treasurers were recruited by contacting the local party organization or by direct contact
via email. The information used to recruit participants was publicly available via the internet and
found on local party organization websites. A combination of email and phone calls was utilized
to conduct outreach to individual officers. An invitation to participate in an interview was sent
via email to prospective participants if an email was available. A total of 14 individuals were
interviewed. 13 were elected treasurers. One individual was a chair of a local organization.
Data Collection
The sources of data were interviews (Creswell & Creswell, 2018). A qualitative study
looks at how one circumstance can cause a phenomenon and what the process is that connects
the two or more phenomena together (Maxwell, 2013). This method was chosen because
qualitative research assumes there is no single, observable reality. Rather, there can be multiple
realities or interpretations of a single event (Merriam & Tisdell, 2016). Because of the unique
perspectives that individuals from different organizations have regarding public disclosure
compliance, it will be necessary to observe and interpret the individual experiences of each
participant in the study.

40
Instrumentation
Interview questions asked participants about their knowledge pertaining to the need for
training on campaign finance laws and reporting requirements, a volunteer’s need to know the
process for following all campaign finance requirements and recognizing when help-seeking is
required by treasurers. This includes where to seek assistance with campaign finance filing
requirements. Motivation interview questions were asked to address if the stakeholder (i.e., a
treasurer) has confidence in their own ability to be in compliance. Other motivation-related
interview questions focused on if treasurers developed performance goals to demonstrate their
accuracy, timeliness and knowledge regarding campaign finance compliance. Finally, to address
organizational influences, stakeholders were asked if training programs were part of the
organization’s cultural process and if stakeholders needed to find a place to find assistance for
compliance questions (See Appendix A).
Interview Procedures
Interviews included open-ended questions with some follow-up to clarify the
respondents’ answers. There were 18 open-ended questions. Open-ended questions allowed
individuals the opportunity to provide a unique response and to qualify their response where
needed. All questions align with the assumed KMO influences affecting local party
organizations.
During the interview, follow-up questions were asked, where needed, to clarify or better
define the respondents’ responses. Data collection occurred in a 2-month time frame. All but one
interview was conducted via Zoom teleconferencing. Due to technical difficulties with Zoom, a
phone interview was conducted. All interviews lasted approximately 1 hour. I recorded notes and
41
also recorded Zoom interviews. Zoom interviews were transcribed via Otter.ai to accurately
portray the respondents’ answers.
Data Analysis
As soon as all notes were entered into EXCEL, I conducted a coding of the responses.
Coding is the process of notating bits of data that are potentially relevant to answering the
research questions (Merriam & Tisdell, 2016). Using the EXCEL spreadsheet, I compared all
interview responses to spot similar responses, direct quotes, keywords, or experiences among the
respondents that related to the research questions. This comparison was conducted by using
separated subject tabs, color coding of responses, and extended notation to identify specific
phenomena within the interviews. Once coding was completed, the next step was to initiate axial
coding. Axial coding is the grouping of codes to interpret the meaning of the data (Merriam &
Tisdell, 2016).
From the initial coding of the responses, I discovered similar patterns and themes began
to emerge among the answers of the participants. Patterns from the original research questions
were reorganized and color-coded, and additional comments were added in Excel to correspond
to the KMO influences in the performance gap analysis. The patterns eventually became
exhaustive, where all possible and relevant data were collected (Merriam & Tisdell, 2016). I also
determined that saturation of the data was achieved, where no new insights could be gathered
into the phenomenon being studied (Merriam & Tisdell, 2016).
Ethics
During this study, ethical responsibilities were observed with respect to human subject
research. This study followed the ethical research standards outlined by the institutional review
board of the University of Southern California. During this study, participants were invited to
42
participate and informed about the purpose of the inquiry. Participation was voluntary, and
participants were informed that they could withdraw from the study at any time. All data from
individual responses were confidential. No data that could identify a respondent, including email
addresses, names, and respondents’ organization, were shared with anyone or provided in reports
and in the interview.
I did have a relationship with some stakeholders from the local Democratic Party
organizations. My relationship included being a current member and past officer of a local
organization. I served in different leadership roles, including chair, vice-chair and treasurer. As a
former leader, I would most likely be viewed as a peer and not in a subordinate role. My former
positions may have provided more credibility to the research and allowed faster response than if
I were not part of the organization.

43
CHAPTER FOUR: FINDINGS
The purpose of this study was to identify KMO gaps hindering compliance with public
disclosure authorities by 50% or greater. This study utilized a modified gap analysis framework
following a qualitative design. This chapter outlines the following elements of the study:
participating stakeholders, recent changes in state law study, results, and findings. The research
questions that framed this study are as follows:
1. What stakeholder knowledge and motivation are required for local Democratic Party
organizations to reduce or eliminate public disclosure violations?
2. What are the organizational factors required to reduce campaign finance violations?
This chapter provides the findings related to Research Questions 1 and 2.
Participating Stakeholders
As stated previously, the stakeholders selected for this study were the officers among the
local Democratic Party organizations in the state. The officers selected for the study are those
responsible for compliance or disclosure duties (Gilbert, 2013). Interviews were conducted with
officers serving in the capacity of treasurer or chair from 14 of the 88 local Democratic Party
organizations.
Profile of the Participants
Fourteen local Democratic Party organizations represented 10 LDs and four countywide
organizations. Of the 14 people interviewed, one was the chair of the organization who
supervised a paid vendor to do the daily ministerial functions of the treasurer.
One interviewee was the elected treasurer in two different organizations. Party experience
ranged from one year to 22 years regarding possible knowledge of organizational operations and
44
familiarity with the PDC. Participant names are replaced with a number to protect the
confidentiality of the participant (See Table 4).

Table 4
Participating Stakeholders
Participant Party
experience
Organizational type Role in the party
1 5 years Legislative district Treasurer
2 11 years Legislative district Chair, uses paid vendor for
treasury work
3 10 years County Treasurer
4 1 year County Treasurer
5 3 years Legislative district Treasurer
6 4 years Legislative district, county Treasurer, two organizations
7 2 years Legislative district Treasurer
8 6 years County Treasurer
9 3 years Legislative district Treasurer
10 22 years Legislative district Treasurer
11 2 years Legislative district Treasurer
12 4 years Legislative district Treasurer
13 1 year Legislative district Treasurer
14 Under 1 year Legislative district Treasurer

This section reveals the result of interviews conducted with treasurers of the Democratic
Party. The questions address the KMO influences in Chapter Three and correspond to the gaps
identified in the conceptual framework. The results from the interviews are organized to answer
the study’s three research questions. Interview results also reveal the KMO gaps with
Democratic Party stakeholders and their abilities, or inabilities, to comply with public disclosure
authorities.
45
Research Question 1
The first research question pertained to knowledge and motivation: What stakeholder
knowledge and motivation are required for local Democratic Party organizations to reduce or
eliminate public disclosure violations?
Knowledge Findings
This section reviews the required factual, procedural, and metacognitive knowledge gaps
for organizations to overcome. The responses are illustrated in Table 5. These gaps were
identified from the questions presented to the stakeholders. Questions were also aligned to
answer the specific factual, procedural, and metacognitive perspectives from the conceptual
framework.

Table 5
Knowledge Findings
Knowledge
influence
Knowledge
type
Gap confirmed
Treasurers need
knowledge in
the
fundamental
subject matter
of campaign
finance laws
and reporting
requirements
Factual Gap confirmed: yes.

Inconsistent transitioning
6 of 14 participants stated that the past treasurer helped
them transition into their new role.

Inconsistent learning or training for the new treasurer
6 of 14 treasurers indicated having formal training, either
tutelage or from the PDC directly. Eight of 14 were self-
taught.

Inconsistent knowledge and usage of resource materials
All 14 treasurers use PDC materials. However, 8 of 14 use
various reference materials from the PDC website. 4 of
14 treasurers use the official PDC Manual as their
primary reference.
46
Factual Knowledge Gaps
To determine knowledge gaps in factual knowledge, treasurers were asked three
questions to assess their factual knowledge about campaign finance laws and filing (Table 5).
For all knowledge types, the data from the interviews confirm that gaps in factual knowledge do
exist. Specific gaps include inconsistent transitioning, inconsistent training, and multiple sources
of learning materials. Information on campaign finance came from the PDC. Most efforts are
self-study or on-demand questions with the PDC.
Inconsistent Transitioning for New Treasurers When interviewed, six of the 14
participants stated that the past treasurer helped them transition into their role. A transition is a
meeting between a newly elected treasurer meeting with the outgoing one to discuss the state of
the organization’s operations and status compliance with current disclosure laws. The transition
education can include regulations and best practices. This could also include transferring
knowledge of the organization’s finances and sharing best practices that can benefit the
organization in maintaining its compliance practices. Some encounters are brief but informative.
When describing their experience, Participant 4 explained, “I spent a day with the former
treasurer going through her explaining what her processes were and how she kept records and
files. We [probably spent] 4 or 5 hours.”
Other treasurers described their transition in terms of the past treasurer covered topics
that were well organized and expansive. Participant 1 stated,
[I] worked with the outgoing treasurer. And he supplied me with all his paperwork and
documentation. He had a nice, organized binder. I sat with him at his house. And he
showed me the PDC process. So that was just kind of a tutorial with him at his house, and
then I took over.
47
Participant 1 mentioned that the transition also took approximately 3 hours. Participant 12
described a similar experience that included the past treasurer offering more support. Participant
12 said,
I was fortunate that I was able to get [a] one-on-one with the previous treasurer. [I] had
his number, [and] I would call him frequently in the beginning to ask him [questions].
[He] gave me a whole lot [of] resources. [The initial] time when we actually met in
person, [probably] a couple hours, maybe a little more.
Where there were instances of lengthy, organized, and detailed transitions, seven treasurers had
an opposite experience. In describing their own transition, Participant 8 stated,
[I was] handed a banker’s box full of records and told in such a sketchy outline of what
the job was that I had no idea what the hell I had. This [was] by the seat of my pants at
the start, and I quickly learned that you get on the phone with the PDC and get the
information you need. [They’ve] been very helpful.
Participant 2 had an experience where there was no transition. Participant 2 stated,
The [elected treasurer was] a very old school accounting-like person who [understands]
the concepts but [doesn’t] have any experience in using any [PDC] tools. So, I [found]
myself very involved in the treasury role … making sure that our reports are pulled and
all that kind of good stuff.
As the interview data suggests, treasurers that had the opportunity to transition with their
predecessors had a positive experience being in the role. Those who did not have a transition
period did express challenges in the beginning of their service as treasurers but did not express
too much difficulty during the rest of their tenure because of the lack of transition time.
However, four participants did encounter deficiencies where past treasurer was unable to
48
adequately transfer information their successor would deem useful to perform their duties.
Where past treasurers may have had some general knowledge to pass along, it is clear there was
inconsistency in the time spent during a transition and on what important knowledge could be
transferred.
Inconsistent Learning or Training for the New Treasurer When asked about their
training, six treasurers indicated some form of formal training. Formal training would be defined
as tutelage from a person, such as the former treasurer, giving personal guidance or instruction
regarding basic factual information needed regarding the PDC. This experience can be several
hours to several days. Training could also be augmented with PDC materials and PDC training to
give a broader context of factual knowledge needed for a treasurer to do their work. The six
treasurers who received formal training are also the same treasurers who also received formal
transitioning from the past treasurer. However, two of these six also augmented their training
with resources from the PDC. This was the experience of Participant 4. Along with a transition
from the past treasurer, additional PDC training was taken. “I signed up for [three] different
classes they had, and each one of those was either an hour or 2 hours. And I watched [webinars]
when they were made available.” Participant 7 explained their experience in the following way,
It was self-study. I was pretty much on my own. I think I had one lesson with [the Past
Treasurer] in her home, and [did my] first filing, and pretty much then she was gone. [It]
was so overwhelming at first, and I did try to watch some of the videos online that the
PDC has, but most of my training came from having a mistake. Emailing [the PDC],
having them work with me on it, and [resolving] it.
Eight of 14 treasurers, who did not receive formal training did self-study. Self-taught is
defined as no specific plan of engagement with the PDC to obtain compliance knowledge. There
49
was no specific period of tutelage from peers or past treasurers to aid in learning compliance
requirements. Also, participants would access educational materials regarding compliance
regulations on their own, utilizing learning material from the PDC. Any materials from the PDC
were augmented with assistance from PDC Staff regarding specific compliance questions and not
considered formal training.
When commenting on their self-study experience, Participant 2 said, “Oh my gosh, I wish
[I had formal training]. My experience was next to nothing. I was thrown a website URL and
told to get education on PDC law.” Participant 3 described their own self-study experience as the
following, “I did not have formal training. I did not attend any classes, either online or in person.
I did read extensively on the PDC website, all the different regulations and reporting
requirements.” In the most extreme case, where there was no training at all.
Observation results were that all 14 treasurers did not encounter any particular issue in
doing their duties, whether they were formally trained or did self-study. However, 11 treasurers
did mention that formal training would have been more advantageous in doing their duties.
Treasurers who received training did encounter inconsistency in the number of hours spent on
training, the materials used, or subjects to learn. Those doing self-study did mention specific
topics that should be learned, such as knowledge of the PDC reporting software (e.g., ORCA),
PDC deadlines, and regulations on collecting funds from large events. It was observed that the
ones providing the training needed to identify topics that new treasurers should learn about
typical scenarios they would encounter.
Inconsistent Usage and Knowledge of Resource Materials There is a gap due to the
inconsistent use of different source materials treasurers use to gain their factual knowledge.
Treasurers use different materials to assist in their learning or as a source reference to overcome
50
a lack of knowledge in a compliance topic. It should be noted that all 14 participants utilized
materials from the PDC.
Treasurers will also directly reference the Revised Code of Washington or the
Washington Administrative Code (WAC) for legal guidance. Seven treasurers use various, non-
specific reference materials from the PDC website. Four treasurers use a manual from the PDC
called the political committee instructions (PDC, 2022c). When explaining the use of this PDC
manual, Participant 10 said,
When I started [as a treasurer], I would just use the [PDC] manual all the time if it was
anything other than basic recording. And I also look at the RCWs because sometimes
there’s actually laws on the books that pertain to things going on. And because I’m a
paralegal, I know how to do legal research. And so, I often search [for an] issue from a
legal standpoint.
Participant 12 explained their own experience in using PDC learning materials with the internet:
“They have some tutorials. I couldn’t find those in the beginning. But now, since the pandemic,
you can find everything. [The PDC has] got [their training sessions] recorded. I can find them
from the PDC website.”
Some participants did not know about the PDC manual for Political Committee
Instructions, such as Participant 4, who said,
[I used] the PDC website for referral and then also emails. I would write [the PDC] when
I had questions ... they were very responsive to get back to me and help me with whatever
I wasn’t understanding so that I did understand. I didn’t even realize there was an entire
manual. I wish I knew, because then I probably would have printed it out and had it on
my desk.
51
Participant 3 also describes encountering alternative non-PDC-based resource materials in
unexpected places researching a compliance topic. Participant 3 said,
There were resources other than the PDC. When I looked up the state laws, they would
lead to various resources and so on. I would print out and maintain printed versions of
what was found online. And it wasn’t necessarily just the PDC [reference materials].
As interviews have described, the resources needed to comply with reporting regulations
come from the PDC or from state law. Each treasurer was introduced to PDC resources
differently. Also, treasurers do not know of all materials or how to take advantage of the
information from its contents. Where the needs of each treasurer may differ in accessing the
information, no uniform method was mentioned that introduced the resources to the treasurers.
Treasurers should be introduced and more deliberately referred to the PDC website for guidance
or to contact the PDC for assistance.
Procedural Knowledge Gap: Inconsistent Experiences of Compliance Learning Procedures
To determine knowledge gaps in procedural knowledge, interviewees were asked
questions to determine their level of procedural knowledge about campaign finance laws and
filing. Procedural knowledge is learning how to do something (Krathwohl, 2002). In the
research, participants were asked how they learned about filing procedures with the PDC. The
following were the gaps discovered in their procedural knowledge (See Table 6).

52
Table 6
Procedural Knowledge Gaps
Knowledge influence Knowledge type Gap confirmed
Treasurers need to
know the processes
for following all
campaign finance
filing requirements
Procedural Gap confirmed: yes.
Inconsistent training experiences in learning
compliance procedures.
Five of 14 participants learned from past
treasurers. 8 of 14 relied on self-study.

Like factual knowledge, treasurers have gaps in their procedural knowledge when
learning the activities required for PDC compliance. When participants were asked about their
training in compliance procedures, it was clear that a training and transition program to transfer
procedural knowledge was not uniformly applied and was inconsistent among all organizations,
if applied at all. When participants were asked how they learned about the PDC filing process,
five participants said they relied mostly on their transition with the previous treasurer for
procedural knowledge. Participant 4 portrayed their experiences as follows,
[The] prior treasurer showed me ORCA on her computer and then had saved all her
material and information, and then we transferred it over to my computer and then started
a new campaign for [the following year] for me. All that data is in there, and so when I
type in a thing, it recognizes everybody, and we just continue, so she did that with me,
and that’s it. [The past treasurer] was pivotal in the transition. I couldn’t have done it if
she hadn’t been willing to tutor me in it.
Participant 12 portrayed a similar experience regarding tutelage from a previous treasurer,
[The past treasurer] went there at the time of the month when he had to do a filing. And
so, he basically [was] with me there. And I took as many notes as I could. He also gave
53
me a pretty detailed handout with screenshots and all kinds of stuff. We used a different
software program instead of the free ORCA program [the PDC provides] because it’s so
much better. But there was a bit of a learning curve.
For the remaining nine participants, these participants relied mostly on self-study and PDC
assistance for their procedural knowledge. Participant 7 had an initial lesson with her past
treasurer but learned most of their procedural knowledge from the PDC. Participant 7 described
their experience as follows,
I didn’t understand, you know, like, the whole make the deposit thing. [It] was too much.
It was too much all at once. And it was shown to me just once. There’s steps involved
and [it’s] very confusing. If I was able to shadow, watch the process, see it more than
once, have somebody watching me do it more than once, instead of pretty much cold
turkey, I think it would have been a lot easier.
Participant 2 described their self-study, along with PDC assistance, as the following:
I mean, I hate to say, I literally relied only on just some light reading of the PDC
webpage to learn. If I remember correctly, I don’t even know that I finished it because it
was extremely dry and boring. It’s not very consumable. [You] can’t just throw up
information and expect people to just devour it. You have to serve it up in a way that is
consumable. And it will stick. And that was definitely not how that [PDC] information is.
As observed in the interviews, each participant was trained following their own
individual plan or with a limited orientation by the previous treasurer. Five of the participants did
express initial difficulty in their role due to their limited or non-existent training in procedural
knowledge. Where assistance from the PDC was available, all participants did not express
further difficulty as they continued their duties. However, a performance gap was observed
54
because of the different ways of how procedural knowledge was transferred to the new
treasurers.
Metacognitive Knowledge Gaps
Two questions were asked to determine knowledge gaps in metacognitive knowledge. As
stated before, metacognitive knowledge is help-seeking ability, or knowing when, where, and
how to seek assistance (Aleven et al., 2003). All 14 participants responded that they would ask
the PDC for assistance. There is no gap in this circumstance, as all participants demonstrated
abilities to seek assistance from the PDC and recognize the agency as the primary authority for
information. However, when asked how to recognize when help was needed and to explain
where and how they would seek assistance on their compliance topic, there were varying
answers (See Table 7).

Table 7
Metacognitive Knowledge Gaps
Knowledge influence Knowledge type Gap confirmed
Treasurers need to
recognize when
help-seeking is
required and where
to seek assistance
with campaign
finance filing
requirements
Metacognitive Gap verified: yes.
Recognizing scenarios when help is needed.
Treasurers identified scenarios to ask for help. But
do not recognize all the circumstances that asking
for assistance may be required.
When a unique situation occurs
(Six of 14 participants)
When the treasurer is unsure of the answer
(Six of 14 participants)
When there is a technical issue
(One of 14 participants)
When accounting balances and errors are difficult to
resolve.
(Two of 14 participants)
Asking for help from multiple secondary sources
55
Knowledge influence Knowledge type Gap confirmed
A gap exists when reaching out to sources of
assistance outside of the PDC.
Seven treasurers prefer to speak with other treasurers
for aide.
Five would contact the county or state party
treasurer for assistance.
Two treasurers would not ask for assistance at all
from other treasurers and only asked the PDC.

Metacognitive Knowledge: Recognizing Scenarios When Help Is Needed From the
interviews, in general terms, all treasurers do ask for help from the PDC. However, not all
treasurers recognized the circumstances that could be encountered where asking for assistance
would be required. Treasurers revealed four scenarios where they requested assistance.
The first scenario is when a new situation arises for the treasurer. Approximately 6 of 14
participants mentioned would ask for assistance in new situations. As Participant 1 stated, “If it’s
a unique situation that I haven’t encountered before, I would ask.” Participant 3 stated facing
new scenarios as follows:
It just popped up from time to time. This is beyond my knowledge base. I’ve got to ask a
question or two. So, I just went in and looked to the PDC website. If you don’t think it
through, you’ll get in trouble. You have to have an inquiring mind and know where to get
a ruling on that particular situation.
The second scenario would be if the treasurer was unsure or did not know the answer to their
problem. This is also representative of six participants. Participant 2 described the experience as
follows, “I mean, I tend to doubt my interpretations from the get-go because I’m just scared that
56
I’m wrong. When it comes to stuff like this. So, it is much more likely that I would reach out
immediately [to the PDC].”
A third scenario is where there is a technical issue. Participant 10 described a technical
issue as the following:
[It] usually has to do with some glitch in the system or the [ORCA reporting] software
more than a question about how I file something. So, I have to go to the PDC. Because
[they have] IT people that are going to figure it out.
A final instance when a treasurer would ask for help when accounting balances and errors
are difficult to resolve. Two treasurers described this encounter. This is not a PDC request for
assistance but a request for assistance from other parts of the organization.
Participant 14 described their experience as follows:
Before I can come fulfill all the compliance requirements to the PDC, I must find the
right information to put into the right report. Then, I can meet the compliance
requirements of PDC. So, the challenges come from [where] I do not have a full
description [of the item to be recorded into the compliance report]. [Tell] me [where] the
money [comes] from, then I have to make sure I have information on the source. I have to
have the original source it came from.
As uncovered by the interviews, all participants understand that there could be different
circumstances where calling for help would be needed. However, not all treasurers are aware of
when to call for help when they encounter these scenarios. This gap shows the importance of
engaging with others to seek help and when help should be sought.
Metacognitive Knowledge: Asking for Help From Multiple Secondary Sources
Treasurers disclosed instances where they contacted alternative sources for assistance. Instead of
57
the PDC, seven treasurers preferred to speak with past treasurers or other officers with treasury
experience. Participant 3 expressed asking for help from other treasurers as follows, “Sometimes
I would call the treasurer of [the county party] being [right] next door to us. There were
occasions where I call and ask either the chair or the treasurer a question or two. Particularly
something new.”
Another 5 of 14 treasurers preferred to ask those from their local county party or the state
Democratic Party directly due to the perception of superior or advanced expertise. Participant 1
described whom they would go to if the PDC were not involved: “[If] it’s a unique situation that
I haven’t encountered before, I would ask [for help]. So, we have some more qualified financial
people [at] the county [party] organization [I can call for help].” Despite the assistance of other
treasurers, two participants chose not to engage with other treasurers. When describing their
reason for why there would be no assistance from other treasurers, Participant 9 stated, “[There
are] no other peers. [I] might be a snob, but they are not [a licensed CPA] like me.’ When asked
the same question about contacting an alternative person for assistance, Participant 10 responded,
Not really? I mean, there’s people I can ask, but I feel like why not just go to the source?
It’s not that often that I do [ask for help], and it usually has to do with some glitch in the
system or the software more than a question about how I file something.
All treasurers can agree to contact the PDC directly for almost any issue. However, some gaps
may exist with treasurers going to multiple individuals with perceived superior knowledge. The
gap could extend to another extreme where treasurers choose not to reach out while waiting for
assistance from the PDC.
58
Overcoming Knowledge Gap Suggestions from Treasurers
Treasurers described several suggestions that could be used to overcome their knowledge
gaps to overcome compliance issues.
Treasurers Should Know Deadlines As stated previously, factual knowledge affects
elements such as terminology, details, and elements of what must be known (Krathwohl, 2002).
When training treasurers with new factual knowledge, nine participants recommended that
treasurers know PDC deadlines. A comment from Participant 3 characterized this
recommendation for most of the group, “That was the most important thing. [The] PDC did have
calendars [that] they provided [at the] beginning of the year and also on their website [and] on
ORCA.”
Participant 12 also contributes a recommendation stating, “[I] make sure [I have] all the
filing dates, and then so I have all of those I keep a calendar posted. And I highlight all the dates
so that I know to make sure that I [email] the group before [the] filing deadline to make sure that
any expenses or in-kind donations are in so I can import them on time.
Increased Accuracy There were overlapping responses to factual knowledge
recommendations with treasurers regarding procedural knowledge. As mentioned, procedural
knowledge is knowing the methods of using skills or techniques to achieve their goals
(Krathwohl, 2002). Seven of 14 recommended treasurers focus on the accuracy of reporting. As
represented by Participant 7 when describing the importance of accuracy in compliance:
[The PDC] basically said, “No,” you got to find that error. So, the lesson I learned to take
away from all that [was] I will never let a month go by; I will never let a [submitted
form] go by that has an error or mistake because it’s incredibly difficult to go back more
than a month and try to figure out what went wrong and try to fix it after the fact. So right
59
now, and every single time I have to the [account balanced] penny [with] our bank
account each time, which I take a lot of pride in.
Call the PDC First. As part of having metacognitive knowledge of oneself to effectively
carry out a task, nine treasurers recommended contacting the PDC first for assistance. Typical of
most answers in regard to contacting the PDC for compliance issues, Participant 4 stated,
“Again, the PDC website. [You] can ask [for] any number of things [about compliance issues] in
Washington state. But it probably [will] just point [you] right back to the PDC.”

Motivation Findings
To determine gaps in motivation, questions were asked regarding self-efficacy and goal
orientation (See Table 8). Self-efficacy is where individuals can feel empowered and can
articulate their vision of their role in the organization to accomplish their tasks (Connors, 2011)
as well as create an action, through beliefs in their capabilities, to produce a desired effect
(Bandura, 2002). Goal orientation is orienting actions in the achievement of a task (Kaplan &
Maehr, 2007) or performance standards to be attained (VandeWalle, 2003).

Table 8
Motivational Self-Efficacy Gaps
Motivation
influence
Motivation
type
Motivational
confidence results
Gap confirmed
Stakeholders must
possess
confidence in
their own skills
and abilities to
be in
compliance.
Self-
efficacy
Responses
1: 100% Confident
3: Confident/very
confident
4: Eight of 10/80%
2: Pretty good/pretty
confident
Gap confirmed: Yes.
Varying degrees of self-efficacy
for treasurer skills.
Where some treasurers are highly
confident in their abilities, not
all are confident in their abilities
60
Motivation
influence
Motivation
type
Motivational
confidence results
Gap confirmed
1: Relatively
confident
1: Fairly confident
1: Halfway or
moderately
confident
regarding their skills and
knowledge.
This demonstrates treasurers do
not feel they have influence to
control their desired outcomes
of their work.

Self-Efficacy Gaps
Varying Degrees of Self-Efficacy for Treasurer Skills. To have them self-assess their
skill, all treasurers were asked one question to gauge their confidence regarding campaign
finance laws and ability to file. Three felt very confident in their abilities, two felt “pretty
confident,” one felt “relatively confident,” one was “fairly confident,” and one was “halfway
confident.” One was fully confident, and one was neutral in the assessment of their abilities.
When elaborating on their self-assessment, Participant 5 said,
I would say eight out of 10, maybe eight and a half. I have a good general working
knowledge of it. [There’s] times I just feel like I understand that piece. I know there’s
something we’re required to do. I’m not sure what it is. But I have a good solid
understanding, but not perfect.
Participant 11, who had 80% confidence in their knowledge, attributed their skills to the size of
the organization:
I think there’s probably a lot of other people that are filing with the PDC that have a lot
more activity than we do. And I’m doing a lot of other things, and we’re kind of just a
little quiet group.
61
On the other extreme, Participant 5 described their full confidence in their abilities and described
the personal commitment needed to maintain their organization’s compliance:
I still have a fear. I know I just said 100% [confident]. It’s because [I] don’t want to have
any surprises, and I never want to go back to a period of uncertainty with this. So, I am
hypervigilant. I’m not going to relax about this. I’m going to get this done as soon as
possible. And I’m going to triple check. I probably am excessive, but I feel it’s the best
way to protect this job and make sure I’m doing it right.
The participants generally feel they do not have enough personal control in the
compliance process due to their knowledge of laws and procedures to effect the desired outcome.
However, all participants do have enough confidence to complete their duties. Organizations
should support treasurers in boosting their confidence in their abilities by assisting them in
constantly improving their compliance skills.
Motivational Goal Orientation Gaps
Goal orientation is creating a mastery, or a process, of performance-oriented actions to
achieve the impression of high ability and competence (Kaplan & Maehr, 2007), such as having
performance standards to attain the goal (VandeWalle, 2003). I asked two questions of
participants to determine gaps in making performance goals. The first question inquired about
personal performance goals of treasurers. The second question inquired about goals for the
organization and what would make the organization effective (See Table 9).

62
Table 9
Motivational Influences and Goal Orientation Gaps
Motivation influence Motivation type Gap confirmed
Treasurers must
develop performance
goals to demonstrate
their accuracy,
timeliness, and
knowledge regarding
campaign finance
compliance, to have
fewer compliance
violations.
Goal orientation Gap confirmed: yes.
Inconsistency in having personal performance
goals
Nine participants do not have a specific personal
goal, beyond basic compliance requirements, to
improve or master their compliance abilities.
Five participants described a process to achieve
higher levels of mastery of their compliance
abilities.
Non-existent Organizational goals
One treasurer mentioned having activities or
actively developing activities to improve their
organization’s compliance practices as a whole
goals.

Inconsistency in Having Personal Performance Goals to Master Compliance
Abilities. All participants described their commitment to the basic compliance obligations,
including timely reporting, maintaining records, accurate reports, and balanced books. However,
eight participants do not have specific personal performance goals, beyond basic compliance
requirements, to improve or master their compliance abilities. Five participants described a
process to achieve higher levels of mastery of their compliance abilities.
Participant 1 gave a typical response of those organizations, stating, “Submitting the
reports on time and [having] the information up-to-date accounting-ready for each executive
board meeting and the general meeting typically is motivation for me to make sure I’m up to
date.” Participant 2 also characterized why there is no specific personal performance goal,
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It’s just an expectation; it’s not a goal. It’s “we will be on time,” and “we will be
compliant.” We’re not currently trying to get better. Because we’re compliant. We follow
reporting on time, we record all our expenses, and we do everything we need to do. I am
not aware of anything that we need to do better. [We] don’t really have any goals.”
As responses show, more than half of interviewees do not have specific individual goals
to improve their compliance performance. In these cases, the term “goals” was used
interchangeably and equated to performance expectations or required compliance actions, which
are not performance goals. Participants should develop individual performance goals to improve
or master their performance.
Non-existent Organizational Goals When treasurers were asked about their
organizational goals to improve compliance, one treasurer of 14 mentioned having activities or
actively developing activities to improve their organization’s compliance practices. Where all 14
participants did have ideas or suggestions to improve compliance practices, no specific program
was planned to be executed.
In the case of Participant 10, and the only organization with a performance goal,
Participant 10 explained their organization’s goal as follows:
I do take a very active role as the treasurer. We write the budget at the beginning of the
year, we do a projected budget, and I’m always reminding people that, if we’re going to
spend something, I’m kind of [monitoring] the budget. But my goal is [to] have all the
membership understand what it means to be complying. What are the rules we have to
abide by, and [how to] abide by them.
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As discovered in the interviews, organizations and treasurers work together regarding
compliance for the organization. However, organizations, along with the treasurers, should work
to form goals to improve the organization’s ability to be in compliance with the PDC.
Summary of Research Question 1:Knowledge and Motivation Gap Findings
Research Question 1 asked, “What stakeholder knowledge and motivation are required
for local Democratic Party organizations to reduce or eliminate public disclosure violations.”
Findings begin with analyzing knowledge gaps. The findings suggested that treasurers had
inconsistent transitioning, training, and knowledge about, or usage of, PDC resource materials to
guide them. From a procedural knowledge perspective, the experience of learning compliance
practices and procedures was inconsistent among treasurers and local party organizations. When
needing assistance, treasurers did not often recognize when asking for help was required. And,
when help was sought, treasurers utilized multiple secondary resources if PDC assistance was
not available.
Motivational gaps in compliance performance were analyzed next. Findings on
motivational gaps revealed varying degrees of self-efficacy (or self-confidence) regarding
individual skills as a treasurer. This demonstrates that many treasurers do not feel they have
influence on the desired outcome of their work. Findings revealed that treasurers have few, if
any, personal goals the prefer to achieve when remaining in compliance with the PDC. Also,
most do not have a larger organizational goal to develop or improve compliance practices.
Treasurers have suggestions regarding improving these knowledge and motivation gaps,
including knowing PDC deadlines, increasing reporting accuracy, and calling the PDC first for
assistance. Treasurers also suggested focusing on the timeliness and accuracy of their reporting.
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Research Question 2
The second research question concerned organizational aspects: What are the
organizational factors required to reduce campaign finance violations?
Organizational Influences Gaps
In answering Research Question 2 regarding making a cultural change, there must be an
understanding of the organization’s current culture. The culture of an organization can be
described as the group’s internal workings or personality (Sims, 2000). Looking into the
processes of the Democratic party would determine what cultural changes need to be made to
improve compliance (See Table 10).
Table 10
Organizational Influence Gaps
Organizational
influences
Organization type Gap confirmed
Treasurers needed to
include training
programs as part of
the organization’s
cultural process, or
practice
Cultural change
processes
Gap confirmed: yes.
No cultural or cultural model for the formal
training process is in place for the treasurer.
All 14 treasurers mentioned that no training
programs were available.
Different ways to find assistance.
Twelve participants preferred to contact the PDC
for assistance and questions on compliance
procedures. One preferred using a singular
manual for reference. One treasurer preferred
to contact a third-party vendor first before
contacting other entities or the PDC.

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Organizational Change Process: No Formal Training Program for Treasurers
From the interviews of treasurers, there was no cultural or cultural model by the party
organization to provide any initial formal training or continuing education for treasurers. When
treasurers were asked about training programs from the organization, all 14 treasurers mentioned
that there were no programs from the organization regarding treasurers.
Many responses to this question were as short as the word “no,” as characterized by
Participants 2, 4, 6, and 11. Participant 3 shared similar sentiments and stated, “I have not taken
part in anything recently, and I have not heard from the state democrats about any training
program. So, no.” Other treasurers, such as Participant 1, also mentioned their experiences as
being self-instruction: “We have no formal training programs and that [I] was only trained sort of
casually [and] trained the one time.”
Where there is no formal training program, all participants obtained the information they
needed from the PDC or other sources to fulfill their duties. A theme in the interviews was that
formal training could have been an advantage at the beginning of their tenure as treasurers;
however, it was not a requirement or a major factor in their success. However, 11 of 14
treasurers still recommended that more formal training would be a good idea.
Cultural Change Models Gaps: Differing Ways of Finding Assistance
Ideally, a single place of service could effectively expand a learning environment for
those needing training (Venner & Keshmiripour, 2016). Treasurers were asked what their ideal
way was to find assistance regarding campaign finance disclosure or procedures to maintain
compliance with the PDC. Treasurers, for the most part, gave similar answers.
Twelve participants preferred to contact the PDC for assistance and questions on
compliance procedures. One treasurer preferred using a singular manual for reference. Another
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treasurer preferred to contact a third-party vendor first before contacting other entities or the
PDC. Describing their preference using a third-party vendor, Participant 2 said,
I think it all comes down to interaction and human interaction with this kind of stuff.
Because again, reading pages and pages of a website is not the greatest way to get
information. It’s not interactive. If we had a point person that we could communicate
with I think that would be great, you know. Having someone that is an expert that can
help. Having a person to talk to is, I think, a huge deal.
As Locke and Latham (2002) stated, without clear goals and feedback, individuals are not so
committed to their assigned work and are not inclined to meet goals with their best efforts.
Interviews indicated that where all treasures have good ideas for organizational improvement,
there seems to be no plan or goals to initiate any suggestions to improve compliance measures
for their organizations.
Suggestions From the Interviewees
With 14 treasurers and their different experiences, each was asked to identify key
takeaways that they found important in keeping organizations in compliance. Where there are
more personalized individual suggestions, the following are the most repeated themes from
treasurers as recommendations for overcoming the KMO gaps to achieve the organizational goal
of increased compliance with public disclosure authorities.
Overcoming Organizational Gap Suggestions
Upon the cultural changing of the organization to make local Democratic Party
organizations more efficient and effective in their work process and material resources,
treasurers suggested the following recommendations.
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Formal Training. Overwhelmingly, 11 of 14 treasurers suggested a more formal training
process for new treasurers. Participant 14 encapsulated the position of the majority of those
interviewed by saying, “It will be nice to have a proper training to standardize the reporting. So,
a treasurer could be trained [with the] same process and standardize the responsibility,
standardize the knowledge, and standardize the process. So, the same treasurer can serve from
one district to another district. Or [be] able to have a treasurer [available] for [a] different district
when they have a vacancy open to fill the position.
Summary of Research Question 2: Organizational Gap Findings
Research Question 2 asked, “What are the organizational factors required to reduce
campaign finance violations?” Analyzing the organizational performance gaps from interviews
revealed that there was no cultural or cultural model for a formal training process to train new
treasurers. Interviews of all 14 treasurers mentioned that no training programs were available
from their local organization. There were also no plans to provide training. All 14 treasurers did
not indicate that the organization would change and provide treasurer training.
Finally, treasurers mentioned different ways to find assistance. There was no singular
source of information to which treasurers could turn. The PDC may be a well-known source, but
it is not necessarily a preferred or primary source of assistance. To overcome these
organizational gaps, the interviewees suggested a formal training program for new treasurers.
Comparisons and Successes
Some practices were observed during the study that could be used as model practices by
treasurers. Treasurers could enact some or all of these practices to prevent performance gaps.
These practices include one-on-one time with their predecessors, calling the PDC for assistance,
modeling a self-study process, and keeping timely reporting by keeping a calendar.
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One-on-One Time With Their Predecessor
Some model practices included new treasurers spending time with their predecessors.
Participant 12 mentioned the least amount of time of 2 hours. Participant 1 described 3 hours.
The most typical amount of time described by Treasurers 4, 11 and 13 was approximately 4 to 6
hours of transition time.
During this transition, the past treasurers described subjects such as relevant
administrative and treasury functions for LD, and budget reporting. This was followed by
presenting resources to their succeeding treasurer, such as PDC contacts, accessing accounts at
the local bank, or PDC filing processes that were unique to the LD due to the amount of activity
the LD encounters. Participants 1 and 4 also described continuously working with the previous
treasurer when assistance was needed after their initial training.
Calling the PDC for Assistance
As for model behavior, all 14 treasurers agreed they would contact the PDC for
assistance. Treasurers would still contact other sources, such as a paid third-party vendor
(Participant 2) or treasurers in other party organizations (Participants 1, 3, and 5). However, all
would seek assistance from the PDC as their primary source. Participant 10 has an established
relationship with the PDC. “I use [PDC] help [when things] come along. [In the] 40-plus years
I’ve been doing it, there’s things that come up that you just never encountered before. So, it’s a
learning experience, always.”
Model Self-Study
An example of self-study came from Participant 10. Participant 10 used the PDC manual,
conducted research, and voluntarily took PDC courses, in combination with direction from the
PDC, to answer questions. As Participant 10 stated,
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I have this big manual, and I read every word of that manual and how you report. I’m
[also] the sort of person that researches everything anyway. And, I have to give praise to
[the people at PDC] because if I have a question, [they respond].
As Participant 10 stated, “The worst mistake you can make as treasurer is to assume you know
how to do something without double checking,”
Keeping Timely Reporting by Keeping a Calendar
Nine participants stated that timely filing is key for treasurers to comply with the PDC.
Treasurers like Participant 8 describe their model behavior as using simple tools to ensure timely
compliance. “[It’s] very basic stuff. [I] just keep marking out my calendar, filing dates and
[making] sure checking donations and getting them in within the proper filing times. So, [I] keep
just keep [dates] all scheduled on a simple calendar that’s always in view, on my desk. So, I
don’t miss any filing dates. That’s probably the key thing for the treasurer.”
Participant 12 also keeps a calendar:
I keep a calendar posted, and I highlight all the dates so that I know to make sure that I
got email or group before filing deadline to make sure that any expenses or in-kind
donations are in so I can import them on time.

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CHAPTER FIVE: RECOMMENDATIONS
This chapter discusses how local party organizations can transform their compliance
abilities. Drawing on this study’s findings, there are 14 recommendations for closing the KMO
gaps related to compliance.
Factual Knowledge Recommendations
Part of factual knowledge is the basic elements with which students must be acquainted
in a discipline and in resolving issues. This knowledge can include terminology or unique details
(Krathwohl, 2002), such as state law. Clark and Estes (2008) stated that all training courses,
lessons, and discussions must begin with a clear and concrete description of what will be learned
and what to do with the knowledge when the training is completed. In the context of campaign
finance compliance, training and the transfer of factual knowledge can have a considerable
impact on the results (Clark & Estes, 2008)
Recommendation 1: Utilize Uniform Learning Materials When Training New Treasurers
The party organization should utilize a uniform set of learning materials when training its
new treasurers. All treasurers rely on materials directly from the PDC or state law to guide them
in their duties. However, it is not known if all treasurers are drawing from the same sources of
learning materials to ensure the consistency of information among the different local party
organizations throughout the state. Also, it is not known when treasurers acquired their original
training.
Since laws are subject to change annually, it would be important to know if all treasurers
are drawing from the same set of materials to prevent errors or to fill in gaps of basic factual
knowledge for treasurers. Unknown or unforeseen consequences can occur when inadequate or
wrong information is presented during instruction resulting in those being trained with incorrect
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knowledge (Clark & Estes, 2008). Treasurers and party organizations throughout the state can
implement this recommendation through coordinated efforts to identify and adopt standard
materials for all treasurers.
An ideal example would be from Participant 10. Participant 10 used specific PDC
materials to learn, such as the PDC Manual. Participants also contacted or made use of PDC
resources during their initial learning. This information was useful when Participant 10 also
worked in training other treasurers.
Recommendation 2: Identify and Teach Uniformed Key Learning Topics
When new treasurers are being trained, local party organizations should identify and
teach key learning topics that are uniform throughout all party organizations. From a cognitive
learning perspective, identifying topics or parts of topics can focus the learner on meeting
training objectives (Mayer, 2011). This will also allow the student to pay attention to the relevant
information offered in a lesson. Also, in terms of coherence, students would learn better when
extraneous materials are excluded (Mayer, 2011). In the case of party treasurers, it is
recommended that local party organizations identify and teach specific, relevant subjects. This
action could ensure compliance by focusing on topics that need greater attention while
reinforcing existing knowledge.
To execute this recommendation, party organizations should ask current or past treasurers
what key facts were needed on the job, what key facts should be shared with new treasurers, and
if there were specific topics treasurers wished to learn. With this information, party organizations
can work with the PDC, experienced treasurers, or subject matter experts to develop a curriculum
built around the requested topics. Party organizations should share knowledge on top compliance
issues periodically. This could be quarterly or monthly, depending on the ability of treasurers
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statewide to organize such a mechanism for sharing information. This effort could be
coordinated by either the state or county party organizations. Party organizations can also work
with the PDC to identify the most common violations during particular periods.
A model example of this recommendation would be from Participant 12’s LD. The
outgoing treasurer was also a paid vendor who did treasury work professionally. This enabled
Participant 12, the incoming treasurer, to learn key topics and up-to-date information on best
compliance practices with the PDC.
Metacognitive Knowledge Recommendation: Develop Resources for All Treasurers Who
Need Assistance
Metacognitive knowledge involves knowledge about cognition as well as awareness of
and knowledge about one’s cognition (Krathwohl, 2002). This perspective is important when
individuals are determining when help is needed. Individuals must become aware of the need for
help, decide to seek help, identify a potential helper, use strategies to elicit help and evaluate the
help given (Aleven et al., 2003). All treasurers discussed circumstances when they would need
assistance with a compliance topic. However, there was inconsistency among all treasurers
regarding whom to contact and why.
Party resources should be developed for treasurers who need additional assistance
regarding compliance questions. The reason for this recommendation is that treasurers contacted
four types of sources for help when they needed assistance. The first preference was for other
treasurers, then the state or county Democratic Party. The third place is to directly contact the
PDC. A final source is a paid vendor, should an organization choose to employ one. Where the
PDC is not immediately available, the other three options are readily convenient to access.
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Those who solicited help were usually looking for comfort, reassurance, and advice, and
they initially turned to family or friends before turning to professional advice (Gourash, 1978).
To accomplish this, party organizations could cultivate sources for assistance, such as a pool of
past treasurers with a high degree of PDC of knowledge and expertise. Other trusted individuals
can include comparable experts with PDC experience outside the party, such as a pool of paid
vendors to ensure a more satisfying outcome for the problem (Gourash, 1978).
Party resources that could be developed include a reference guide of phone numbers or
emails of specific departments at the PDC that can assist in a particular treasurer’s question.
Another reference guide that could be created is a list of veteran party treasurers specifically
trained or chosen to answer complex PDC questions if the PDC cannot be conveniently
contacted. These resources should also be updated frequently to ensure that experts are available
or if there are changes in contact information.
An example would be from Participant 2’s legislative district. In this organization,
resources were developed to ensure compliance. These included using a paid vendor to provide
treasury services, contacts with the county party, and communication with the PDC for resources
if there were compliance issues.
Self-Efficacy Recommendation: Develop Continuing Education Opportunities for Existing
Treasurers
Treasurers were asked about their confidence regarding their knowledge, skills and
abilities when keeping their organization compliant. One had full confidence. Treasurers and
their respective organizations should continuously improve their identification, mitigation, and
elimination of motivation gaps.
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Treasurers must feel empowered to articulate their own vision of their roles to better
accomplish their tasks (Connors, 2011) and believe in their abilities to produce the intended
outcome (Bandura, 2000). Specifically, there should be performance standards, continuing
training opportunities, and accountability within the organization.
Organizations should support their treasurers by improving or expanding their continuing
education opportunities for campaign finance compliance. This idea is recommended because,
during the study, party treasurers identified advanced topics where their knowledge was
deficient. Some topics that treasurers mentioned were accounting for donations after fundraisers,
exempt versus non-exempt accounts, and documenting in-kind donations. With changing state
laws and constant technological upgrades by the PDC, continuing education is an important tool
for organizations to succeed (Laal et al., 2014).
To implement this recommendation, continuing education could encompass taking a paid
course that issues a diploma or certificate. The party could also offer its own courses suited to
meeting the state party’s objectives. These courses should provide training that enhances specific
skills and knowledge (Laal et al., 2014). These skills could include basic bookkeeping techniques
or newly updated laws.
Offering regular continuing education would enrich the skills of treasurers or officers
who are responsible for the financial fitness of their local party organization. Another option is
for the party organizations to pay expenses for a treasurer to attend a PDC-based training if their
personal finances present a barrier to their attendance.
The best example of this behavior comes from Participant 12. Participant 12 takes PDC
online training sessions and voluntarily receives email updates from the PDC regarding different
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PDC topics and events. Participant 12 also takes steps to take other training by the PDC when
available.
Goal Orientation Recommendation: Treasurers Should Create Individual Compliance
Goals
Goals are commonly defined in terms of the performance standards to be attained
(VandeWalle, 2003). All interviewees have a general goal or desire to comply with the PDC.
However, they do not follow a specific plan to achieve this goal. Treasurers and their party
organizations should create goals tailored to meet their specific desired outcomes.
It is recommended that treasurers work to create individual compliance goals to ensure
compliance for their organization. The reason for this recommendation is that all interviewees
had a general objective of compliance with the PDC. However, two treasurers reported having
specific metrics in their daily activities to ensure their personal goals of maintaining compliance
for their organization.
To accomplish this recommendation, an individual treasurer would develop goals to
demonstrate and validate the adequacy of one’s competence or ability. This evolution of goals
happens over time and can be difficult to develop (VandeWalle, 2003). Feedback regarding the
treasurer’s ability to meet their goal would be in the form of an evaluation by the organization of
the treasurer’s judgment and competence in meeting their compliance goals (VandeWalle, 2003).
It must be noted that meeting the goal should not focus strictly on performance but on whether
new skills have been learned and transferred (VandeWalle, 2003).
The motivation for this goal is the development of specific or difficult goals to lead to
higher performance (Locke & Latham, 2012). To ensure this activity occurs, a county
organization could cooperate with LDs and hold them accountable for meeting compliance goals.
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To specifically implement this recommendation, a committee from the county
organization could meet with the officers of their local party organization and state the specific
goals that a treasurer wants to accomplish, such as timely reporting or accurate reporting of
expenditures. By working in unity, the county organization could uncover any personal
assistance a treasurer needs. This work also ensures that the individual compliance goals align
with organizational compliance goals.
The organizations exhibiting this model behavior are those of Participants 6, 7, and 10.
All three treasurers have working goals of full compliance. These include knowledge of all
deadlines, ensuring the accuracy of bank statements with PDC records, and the accuracy of
reports filed with the PDC. All three also ensure timely filings and take affirmative steps to avoid
submitting errors. These affirmative steps include double-checking work before submission,
enacting a daily reporting routine, and working with fellow officers to ensure they, too, follow
PDC rules.
Organizational Recommendations
As Clark and Estes mentioned (2008), even with motivated individuals, missing or
inadequate processes and materials can prevent the achievement of organizational performance
goals. Organizational culture inevitably filters and affects all attempts to improve performance,
and any change will depend on taking the specific organizational culture into account (Clark &
Estes, 2008). The following recommendations pertain to change in the party organizations’
cultural process and cultural model to improve public disclosure compliance. The
recommendation includes implementing a coordinated training program, an evaluation method
for the training program, compliance training for all officers, and creating a process to ask for
help.
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Implement a Formal Training Program for New Treasurers and Officers
It is recommended that party organizations implement a formal training program for new
treasurers and officers, especially those with campaign finance duties. This recommendation is
important to enact because all study participants described separate and unique experiences when
learning about compliance regulations, PDC filing procedures, or daily duties as treasurers. This
variability extended to the degrees of additional hours spent on self-study when transitioning into
their duties.
All treasurers interviewed confirmed that there are no training programs to enhance skills
and knowledge for those new to the treasury role. When treasurers were asked for additional
recommendations about training programs, six recommended that training include all of the
organization’s officers, even those with no treasury or compliance responsibilities.
Enhancing knowledge is required when people do not know how to accomplish their
goals and when it can be anticipated that future challenges will require novel problem solving
(Clark & Estes, 2008). Enacting a coordinated training program could ensure all individuals
receive the same training in similar scenarios in various circumstances. Implementing a formal
training program can first be accomplished with party leaders approving these in their local
organizations. These programs can set a new tone in the organization that places greater
importance on training (Towler, 2014).
Training programs can incorporate specific topics such as basic bookkeeping, training on
ORCA, an overview of state compliance laws, and party resources of where to turn for assistance
if needed. The trainers for these courses do not need to be the direct predecessor of the current
treasurer but could be another experienced treasurer with expertise in compliance regulations.
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Also, local party organizations would coordinate their efforts to ensure that every treasurer in
their county organization performs the same job the same way.
The model example for a training program would be similar to the experiences of
Participant 12. As mentioned in Recommendation 2, where there should be uniformed key
learning topics, Participant 12’s experience is an example of how a new treasurer went through a
learning process with their predecessor. The process included spending at least 2 hours of
orientation regarding the treasurer’s duties, the organization’s financial records, resources
available to the treasurer, how to file with the PDC, and the opportunity for follow-up.
Adopt an Evaluation Method for Any Treasurer Training Programs
When training programs are enacted, it is recommended that there be an evaluation of the
effectiveness of the training program. The reason for this recommendation is that there is
currently no method of evaluating treasurer training methods. This lack can be attributed to the
also lacking training for these officers.
To accomplish this recommendation and ensure the effectiveness of any goals or
outcomes, Democratic Party organizations should start by evaluating the organization’s current
compliance goals’ suggested metric of growth and to see changes in performance. Metrics could
include tracking the accuracy of account balances or improving timely reporting with the PDC.
Currently, no LD has a model of performance for an evaluation method for training programs
since no local party organization has an organized training program.
With no active training evaluation program, party organizations should adopt a model for
evaluating new training programs. It is recommended that local party organizations use the new
world Kirkpatrick model (Kirkpatrick & Kirkpatrick, 2016) to evaluate their training regimes for
treasurers or other personnel responsible for their organization’s compliance.
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The Kirkpatrick Model
The Kirkpatrick model focuses on three reasons to evaluate a training program. The first
reason is to ensure training programs are developed and delivered to maximize learning. The
second reason is to help increase the amount of on-the-job learning. The third reason is to
determine the contribution of key success factors (Kirkpatrick & Kirkpatrick, 2016).
The Kirkpatrick model focuses on four levels: reaction, learning, behavior, and results.
Reaction is Level 1, which focuses on whether participants find the training favorable, engaging,
and relevant to their duties (Kirkpatrick & Kirkpatrick, 2016). The study’s results show there
needed to be a cultural change by recommending formal training for new treasurers. Level 1 is
where treasurers can be engaged to create a learning environment that is more desirable,
applicable, and relevant for additional compliance training. This environment can be created
when treasurers sit down with either county organization to provide resources, such as regular
meeting space, gather experts to teach specific compliance topics, and identify an instructor to
coordinate efforts and ensure the training is executed.
Level 2 is learning, where trainees acquire the intended knowledge, skills, attitude,
confidence, and commitment based on their participation in the training (Kirkpatrick &
Kirkpatrick, 2016). During the study, every interviewee made recommendations for topics for
treasurers and other officers. All relevant factual and procedural compliance topics would be
incorporated to create a Level 2 experience. Under Kirkpatrick, trained treasurers would be
evaluated to see if there was a complete transfer of factual and procedural knowledge of
fundamental compliance knowledge. To accomplish this, a county party organization would
survey the treasurers to identify specific topics that should be covered in training and identify
best practices to overcome performance gaps.
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The third level is behavior, in which participants apply what they learned during training
when returning to their duties (Kirkpatrick & Kirkpatrick, 2016). On a metacognitive level,
participants’ behaviors would be evaluated, and treasurers would be asked how much of their
training was useful, helpful, or relevant. Also, evaluating behavior creates and opportunity to
monitor, reinforce, encourage, and reward preferred practices for treasurers who try to improve.
The final level is results. These are the degree to which targeted outcomes occur because
of the training. The results are achieved by looking at leading indicators and seeing if the desired
outcome was reached (Kirkpatrick & Kirkpatrick, 2016). This outcome could take the form of
treasurers in LDs self-reporting their findings to the county organization.
Limitations and Delimitations
Certain limitations and delimitations apply to the study. According to Theofanidis and
Fountouki (2019), limitations are weaknesses usually out of the researcher’s control.
Delimitations are limitations the authors consciously set.
Limitations included the 2020 COVID-19 pandemic, which delayed response times.
Another limitation was that the research was conducted after the 2021 campaign cycle, when
local party organizations had completed their participation in local municipal elections from
January 2021 to November 2021. Party treasurers were engaged in the annual reporting of their
organization’s activities to the PDC.
The 2021 holiday season was another limitation, as many interviewees were not available
due to family or personal obligations for Thanksgiving, Christmas, or New Year’s observations.
A large limitation was that some party officers felt they required permission from a higher
authority, such as the WSD or their local organization.
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For delimitations, I limited interviewees to the local Democratic Party, where the PDC
had direct enforcement authority. This delimitation was needed as some Democratic Party
organizations chose to operate in a manner to avoid PDC oversight.
Future Research
Given the study’s limitations, future research should encompass more treasurers to hear
more opinions about current party compliance operations. There was a saturation of information
gained from the treasurers’ responses. However, a qualitative study on the treasurers’ opinions
and how to improve compliance would be useful. Such a study could validate broader opinions
about how treasurers can improve compliance practices. Additionally, if the recommendations
from this study are enacted, another study to determine the efficacy of these changes would also
be in order. One goal of a future study could measure if the changes reduced or eliminated
compliance violations.
Conclusion
The purpose of the study was to determine the performance gaps of small political
organizations that have difficulty following public disclosure regulations. Using Clark and
Estes’s (2008) gap analysis framework, the KMO influences were studied. Peer-reviewed
literature and interviews with party treasurers helped to shape the findings regarding the gaps and
recommendations to improve compliance practices.

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APPENDIX: DEMOCRATIC PARTY TREASURER STUDY INTERVIEW QUESTIONS
Thank you for agreeing to participate in this study.
I appreciate the time, and this could take about an hour, depending on our discussion.
Introduction Statement to the Subject
The purpose is to research practices from officers, specifically treasurers, regarding your
personal experience with campaign finance and campaign disclosure procedures with the PDC.
Your responses will be aggregated with the responses of other interviewees to form the results of
the study.
Do you have any questions before we begin? Can I start the recording for the interview?
Basic Information Question
1. Share your background with the Democratic Party.
Main Interview Questions
2. Describe the initial training you experienced in learning the basic facts about public
disclosure, campaign finance laws? For example, could you please describe how long
it took, the type of training (lecture, formal classes, self-study, etc.)?
3. Describe what kinds of material (i.e., books, pamphlets, manuals, computer files), if
any, you used to learn about campaign finance rules and reporting requirements.
4. Explain some key facts (or takeaways) that you found important to know from your
training that were helpful in keeping your organization in compliance with campaign
finance and campaign disclosure authorities.
5. Describe the sources of reference materials you currently draw from to make sure you
are following compliance reporting requirements. For example, is there a manual,
guide, or resource you refer to when you have a question?
94
6. What are some key facts you learned on the job that became useful in keeping your
organization in compliance?
7. If you were a new treasurer, or training a new treasurer, what are some other key facts
you think a new treasurer should know?
8. Is there anything that you wish you were trained on that you did not receive training
on?
9. How did you come to learn about the filing processes and tools to keep your
organization in compliance? What challenges did you face?
10. How would you recognize when you need to seek help with a compliance topic?
11. Explain where and how you would seek assistance regarding disclosure laws or help
in filing reports.
12. Describe how confident you are in your knowledge, skills and abilities when keeping
your organization in compliance.
13. What performance goals, if any, do you have regarding campaign finance
compliance?
Probing Question 1: Does this include any means to track any reduction of errors,
violations, or complaints?
Probing Question 2: Does this include any standards re: timeliness?
14. What goals do you think will be effective for your organization to set to achieve
better compliance performance?
15. What training programs are currently in place for you? How often are you using
them?
95
16. What recommendations would you make for a training program for your
organization?
17. What would be the ideal way to find assistance or answer your questions regarding
campaign finance, disclosure, or filing?
18. Is there anything else that you would like to share about your experiences?
Closing Comments
Thank you so much for taking part in my study! Your insights will be invaluable to the
results.

Abstract (if available)

Abstract The purpose of this study was to uncover the knowledge, motivation, and organizational factors required for treasurers in Washington state to improve compliance measures with campaign disclosure authorities and reduce infractions and complaints at the federal and state levels. Numerous studies revealed that campaign finance regulations are complex, confusing, and burdensome. Specifically, amateur or grassroots organizations were negatively affected by the large learning curve in conforming to all reporting procedures and laws.

Following Clark and Estes’s method of organizational analysis, party treasurers were selected to uncover knowledge, motivation, and organizational performance gaps from local Democratic Party organizations. Treasurers were chosen because of their unique role in the daily administration and maintaining the financial compliance for the organization. The study applied qualitative research methodology by collecting data from interviews of active treasurers who were recruited from local Washington State Democratic Party organizations. The analysis of the interviews revealed several inconsistencies in training, help-seeking, confidence, setting performance goals, and organizational behavior. Knowledge, motivation, and organizational recommendations were offered based on findings to reduce campaign disclosure violations.

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Asset Metadata

Creator Rosete, Marvin Allen (author)

Core Title Small political groups' compliance with public disclosure authorities: a gap analysis

School Rossier School of Education

Degree Doctor of Education

Degree Program Organizational Change and Leadership (On Line)

Degree Conferral Date 2023-08

Publication Date 07/31/2023

Defense Date 01/20/2023

Publisher University of Southern California. Libraries (digital)

Tag campaign finance,campaign finance complaints,campaign finance disclosure,campaign finance laws,campaign finance violations,campaign violations,campaigns,Compliance,democratic party,Democrats,disclosure,election complaints,Election law,election law violations,election laws,election violations,financial disclosure,grassroots,grassroots organization,grassroots political organization,grassroots politics,grassroots volunteer,grassroots volunteers,help seeking,OAI-PMH Harvest,party treasurers,political campaign,political campaign violations,political complaints,Politics,Public Disclosure Commission,setting performance goals,training,training political volunteers,training volunteers,treasurers,Volunteers

Language English

Contributor Electronically uploaded by the author (provenance)

Advisor Malloy, Courtney (committee chair), Roberts, Chris (committee member), Stowe, Kathy (committee member)

Creator Email marvin.rosete@gmail.com,mrosete@usc.edu

Permanent Link (DOI) https://doi.org/10.25549/usctheses-oUC113291697

Unique identifier UC113291697

Identifier etd-RoseteMarv-12166.pdf (filename)

Legacy Identifier etd-RoseteMarv-12166

Document Type Dissertation

Rights Rosete, Marvin Allen

Internet Media Type application/pdf

Type texts

Source 20230731-usctheses-batch-1076 (batch), University of Southern California (contributing entity), University of Southern California Dissertations and Theses (collection)

Access Conditions The author retains rights to his/her dissertation, thesis or other graduate work according to U.S. copyright law. Electronic access is being provided by the USC Libraries in agreement with the author, as the original true and official version of the work, but does not grant the reader permission to use the work if the desired use is covered by copyright. It is the author, as rights holder, who must provide use permission if such use is covered by copyright.

Repository Name University of Southern California Digital Library

Repository Location USC Digital Library, University of Southern California, University Park Campus, Los Angeles, California 90089, USA

Repository Email cisadmin@lib.usc.edu