April 15, 2019

This MISC-99 statement is issued in conjunction with the 2019 April Quarterly FEC Report filed by Tulsi Now (ID# C00693713), the authorized campaign committee for Democratic presidential candidate Tulsi Gabbard.    The report at issue identifies three transfers that were made during the reporting period between Tulsi Now and Tulsi for Hawai'i (C00497396), which is the authorized campaign committee for Tulsi Gabbard's campaign for U.S. House of Representatives.  The account administrators for the committees made the first transfer from Tulsi for Hawai'i to Tulsi Now prior to making the  relevant notification step according to 11 C.F.R. § 110.3(c)(5)(i).  This occurrence was discovered by committee counsel during a routine compliance check and reported to the Federal Election Commission ("FEC") analyst for Tulsi Now, Ms. Robin Kelly.  The committee was advised to return the transferred funds to Tulsi for Hawai'i prior to the close of the quarter to bring the committee into full compliance with applicable rules and asked to file this MISC-99.  The transfer recommended by Ms. Kelly was completed on March 21, 2019.
Tulsi Gabbard notified the FEC on March 30, 2019 of her intention to move Tulsi for Hawai'I into inactive status.  Tulsi for Hawai'i subsequently made a transfer to Tulsi Now on the same day in accordance with 11 C.F.R. § 110.3(c)(5)(i). 
Should the Commission have any follow-up questions regarding this MISC-99, please do not hesitate to contact the PAC Treasurer.