Patrick Colbeck

Established Fact As of the compilation of this report, ActBlue has not published an independent third-party audit of its fraud detection performance for the 2020 election cycle, nor has it produced complete responsive records to all congressional inquiries. Citations Letter from Rep. Bryan Steil to ActBlue, Oct. 31, 2023 (on file, House Committee on Administration),

Established Fact Federal law does not require campaigns to itemize contributions below $200 aggregate per donor per cycle. This threshold creates a structural incentive to keep individual fraudulent transactions sub-threshold, rendering them invisible to public FEC disclosure. Citations 11 C.F.R. § 104.3(a)(4)(i) (specifying that authorized committees must report itemized individual contributions in Schedule A, Line

Established Fact ActBlue reported 15.3 million unique donors and over 165 million individual transactions in the 2020 cycle. This volume makes individual-transaction fraud detection and post-hoc audit exceptionally difficult without automated forensic tooling. Citations ActBlue, 2020 Year-End Report (Jan. 2021), https://actblue.com/updates/posts/2020-year-end-report

Established Fact During the 2020 federal election cycle ActBlue processed approximately $3.8 billion in total contributions — more than double its 2018 cycle total — creating an audit environment of exceptional complexity for regulators and recipient committees. Citations ActBlue, 2020 Year-End Report (Jan. 2021), https://actblue.com/updates/posts/2020-year-end-report OpenSecrets.org, ActBlue 2020 Cycle Summary, https://www.opensecrets.org/pacs/lookup2.php?strID=C00401224

Established Fact ActBlue is registered with the FEC as a qualified non-connected committee (C00401224) and operates as a conduit fundraising platform, collecting and transmitting contributions to Democratic candidates while retaining a 3.95% processing fee per transaction. Citations FEC Committee Profile, ActBlue (C00401224), FEC.gov, https://www.fec.gov/data/committee/C00401224/ Presidential Memorandum, Investigation into Unlawful “Straw Donor” and Foreign Contributions in