Ryan Walters has failed to report campaign expenditures in his quarterly finance reports in his bid for State Superintendent, violating state ethics laws and leading to confusion about how much money his campaign actually has on hand.

State campaign finance rules require candidates to disclose all expenditures made by their campaign and to disclose how much money their campaign has on hand at the end of each quarter and just prior to election days. But Walters, who is currently Oklahoma’s Secretary of Education, has not reported any expenditures other than the fundraising fee WinRed charges him.

Walters’ run for the state superintendent has been endorsed by Stitt, who appointed him as Secretary of Education early last year, and he has been a vocal supporter of recent GOP school choice expansion efforts in the state.

According to Walters’ campaign filings with the Oklahoma Ethics Commission, his campaign raised $104,920 between July and September and spent $1,181, all of which was on fees by WinRed, an online Republican fundraising platform. Walters’ October through December campaign finance reports show he raised $43,485 and spent $1,411, again with the entirety of the spent money going toward WinRed fees.

However, records obtained by The Frontier show that Walters’ campaign spent funds last year that were never reported to the Ethics Commission, and that he has hired several people to work on his campaign, though no payments to those individuals have been reported by his campaign.

Walters, who did not respond to numerous phone messages from The Frontier seeking more information about his campaign expenditures, is listed as the treasurer of his campaign committee meaning it is up to him to file, sign and keep track of all expenses.

Oklahoma campaign rules require a candidate committee to report expenditures and provide information about those expenditures that are $200 or greater, as well as any reimbursements to the candidate. Candidates also must state what the expense was for and to whom it was paid. The rules also require expenditures made by political consultants and other third parties on behalf of the committee be reported as if the expenditures were made by the committee.

Ashley Kemp, executive director of the Oklahoma Ethics Commission, which oversees state campaign reporting rules and regulations, said she could not comment on specific cases, but in general, candidate committees are required to report any expenditures made during the period it was made.

“Voters need that information on how funds are being raised, from who funds are being raised and how those funds are being spent,” Kemp said. “They need to be made aware of those before they go to the ballot box and make their decisions on who they want to vote for. And how those funds are raised and spent oftentimes impacts a voter’s decision on what candidates they may want to support.”

Walters held a press conference at the Oklahoma History Center in Oklahoma City on July 12 to announce his candidacy for State Superintendent. Event booking records from the Oklahoma Historical Society, which operates the History Center, show that Matt Langston, a consultant with the national Republican consulting firm Big Dog Strategies, had booked the event and paid a $450 deposit and $450 rental fee to the Oklahoma Historical Society. Langston told The Frontier in a phone conversation that he is “running Ryan Walters’ stuff.”

The documents show the expense was to be billed to Walters’ campaign, and an Oklahoma City restaurant was hired to cater the event, though the record does not state how much was paid for catering.

Big Dog Strategies is a New York-based firm started by former New York Republican Congressman Chris Collins’ chief of staff Christopher Grant. In 2019, Collins resigned from Congress and pleaded guilty to federal charges of insider trading and lying to the FBI. Grant was also involved in the allegations of insider trading, according to the FBI, but was not charged.

Walters’ campaign filings do not show any payments to Langston, Big Dog Strategies, or any other campaign staff for work on his campaign, some of whom have been working on the campaign since July 2021.

In addition to hiring Big Dog Strategies and the Historical Society receipts, Walters developed a campaign website and personally paid for Ethics Commission filing fees, none of which has been publicly reported by Walters’ campaign, according to documents and interviews.

Domain registration data shows Walters’ campaign website was registered on July 8, 2021, though his campaign did not report spending money to create or register a website.

Though Walters’ campaign was established with the Oklahoma Ethics Commission on July 9, the following day Walters formed a separate limited liability company through the Oklahoma Secretary of State’s office, Walters for State Superintendent 2022 LLC, records show.

Read now: Ryan Walters 2022 Secretary of State filing

Kemp said she was unaware of any candidate forming a candidate committee with the Ethics Commission and a related corporation through the Secretary of State’s Office, and in such a situation, the two entities would be considered separate groups.

“The (candidate) committee itself is a legal entity. So it doesn’t mean you have to register as a corporation in order to be recognized as a candidate committee, or as some kind of legal entity. It is in and of itself, a recognized type of entity,” Kemp said. “Those two statuses are inconsistent. You can’t be a political committee, and a corporation. For tax purposes, there may be reasons to incorporate that as far as the actual structure of the entity itself. You can be a corporation, you can be an LLC, you can be a political committee, but you can’t necessarily be all three types of structures.”

Read now: Contract between Walters campaign and Oklahoma Historical Society

Read now: Walters Candidate Committee Contributions and Expenditures Report 7/1-9/31

Read now: Walters Candidate Committee Contributions and Expenditures Report 10/1-12/31

In a statement, Langston told The Frontier the campaign has taken “meticulous efforts” to comply with all Oklahoma Ethics requirements and blamed their Republican primary opponent April Grace for “trying to create a false narrative based on manufactured and fictitious issues” despite them not reporting expenditures.

When later asked how much he was charging Walters or if he was being paid, Langston, who is from Texas, said he didn’t know how that was “relevant to any of the major issues facing the state.”

In February, Grace, one of Walters’ Republican opponents, questioned Walters’ campaign’s lack of documented expenses saying no one can run a statewide campaign “for free.”

Grace, who as of Dec. 31, 2021, leads in fundraising, has reported a total of $187,440 raised and $35,739 spent, while Republican John Cox, who records show also gave his campaign a $30,000 loan, raised $21,545 and spent $31,756. Walters’ campaign shows that he raised a total of $148,405 but spent only $2,592, all of which was on WinRed fees. The sole Democrat to enter the race, Jena Nelson, registered her candidate committee on March 17, and has yet to file a contribution and expenditure report.

The primary election is scheduled for June 28, with a runoff election date of Aug. 23, if necessary. The general election is scheduled for Nov. 8.

The next campaign filing period, which would cover donations and expenditures made between Jan. 1 and March 31 this year, ends on April 30.

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