A federal political action committee was one of the largest donors to state Sen. Aaron Rouse’s campaign for lieutenant governor. Where that money came from won’t be known until months after the primary election.
A difference in reporting requirements between the Federal Election Commission and the State Board of Elections has created a loophole that allows for federal PACs to temporarily shield the source of their money, even as they contribute to state candidates in Virginia’s off-year elections.
The PAC, called Our States Matter, contributed tens of thousands of dollars to Rouse for Virginia, the senator’s campaign for lieutenant governor. Those contributions include $15,000 on December 31, 2024, and $60,000 on March 31. The PAC also contributed tens of thousands of dollars to Rouse for Senate, the senator’s General Assembly campaign. Those contributions include $60,000 on March 31, 2025, and $60,000 on April 3, 2025, according to data reported to the State Board of Elections.
All together, Rouse’s campaigns received $195,000 from Our States Matter within a roughly four-month period. Rouse, a Democrat from Virginia Beach, lost his bid to be the party’s nominee for lieutenant governor. He is up for reelection in the state Senate in 2027, along with the rest of the chamber.
At the end of December, Our States Matter PAC reported a cash on hand balance of $16,769.11. Where the PAC got the tens of thousands of dollars to contribute to Rouse’s campaigns won’t be known until after July 31 — the FEC’s midyear reporting deadline for the 2025 “off-year.”
A discrepancy between deadlines
The FEC required federal PACs to file financial reports on a quarterly or monthly basis during the 2024 election year. During the 2025 “off-year,” or a year when a federal election is not normally held, the reporting schedule changed to twice a year — with deadlines on July 31 and Dec. 31 — well after Virginia’s primary and general elections.
The commonwealth’s campaign finance reporting schedule is much more frequent, but federal PACs exist outside of the State Board’s jurisdiction.
Virginia’s financial reporting guidelines changed after a bill was passed in 2023 that added reporting requirements for campaign contributions and expenditures over $1,000 close to the primary and general elections
Sen. David Suetterlein, R-Roanoke County, patroned the 2023 bill after it was discovered that Dominion Energy gave money to a group that funded attack ads against then-Republican candidate for Governor Glenn Youngkin in 2021.
“Dominion Energy’s use of a shadow PAC to attack Glenn Youngkin on gun rights — which was an issue they did not actually care about — exposed a gap in Virginia’s state PAC reporting that could be especially exploited close to a primary or general election,” Suetterlein said in a phone interview, when asked why he patroned the bill. The bill, he said, was an effort to provide greater transparency in campaign funding for state PACs.
“This bill does increase the number of schedule reporting times and amounts to the extent that there’s disclosure and that’s public information, then people can make their own decisions whether too much money is going toward particular candidates or for particular purposes,” said Karen Hult, professor of political science at Virginia Tech.
The bill, however, does nothing to address spending by federal PACs. That is because the General Assembly can only regulate state entities, Suetterlein said.
As state-level organizations, Rouse’s campaigns were required to file more frequent reports with the Virginia Board of Elections. His campaigns disclosed the money contributed to them by Our States Matter, as required by state statute. But where the federal PAC received that money will not be discoverable through the FEC database until after the July 31 federal off-year reporting deadline.
A PAC with a Rhode Island address contributing to Virginia elections
Our States Matter PAC lists a Rhode Island address on its FEC statement of organization, but it was originally formed as Virginia Matters PAC, said Allison Murray, the custodian of records for the PAC. Murray is a partner at CFO Compliance, a Rhode Island-based organization.
She noted that the PAC is registered with the Virginia Department of Elections in compliance with Virginia law and provided that documentation to Cardinal News. Andrea Gaines, spokesperson for the Virginia Department of Elections, confirmed that the PAC is registered with the Department of Elections, but because it is a federal PAC, it is not required to file campaign finance reports with the state.
Our States Matter has contributed more than $400,000 to more than two dozen Virginia candidates since 2019, Murray said. The PAC has a Rhode Island address because that is where its custodian of records is based.
Murray said that the PAC’s report with the FEC, disclosing donors and expenditures for the 2025 “off-year,” will be filed and publicly available by July 31, when asked where the money that the PAC contributed to Rouse’s campaigns came from.
Could lawmakers fix Virginia’s ‘swiss cheese’ campaign finance system?
Virginia is one of the least restrictive states in terms of campaign finance reporting and contribution expenditure limits, and the state does not subject federal PACs to its campaign finance laws.
“Our campaign finance regulatory system is swiss cheese,” said John Martin, research assistant professor of law at the University of Virginia.
“Federal PACs become an attractive option for those looking to avoid Virginia’s disclosure requirements and attempt to influence Virginian elections without detection. This is a problem because Virginia voters end up not fully knowing who is actually influencing our state and local politics,” he said.
Martin noted that the General Assembly could close the loophole by amending the definition of “political action committee” under state statute to not exempt federal PACs.
“Other states subject federal PACs to state-level campaign finance laws. There is no reason why Virginia could not do so,” he added, and named California when asked which states subject federal PACs to state-level laws.
Whether the General Assembly will pass such legislation remains to be seen. Six out of ten pieces of legislation regarding campaign finance failed during the 2025 General Assembly session. None of the ten pieces of legislation appeared to attempt to address campaign contributions from federal PACs.
“Rather clearly, many people evidently are worried about the potential for money to distort decision making and representative government. Somewhat less clear are workable (and feasible) responses and legislative will and public support for adopting them,” Hult said.
Rouse’s office did not respond to a request for comment.
