← Investigations

Investigation · May 21, 2026

The Super-Treasurer and the FEC Chairman

Thomas Datwyler, Sean Cooksey, and the 2024 canvassing rule

TL;DR

One treasurer files for 676 federal committees; the FEC chairman who advanced a rule benefiting Trump-aligned Super PACs left to join the Vance office.

Sean CookseyThomas DatwylerFederal Election CommissionConservative Partnership Instituteregulatory capture2024 canvassing ruleAmerica PACcampaign finance

What we found · 9 findings

  1. 1
    Confirmed

    Thomas Datwyler is the treasurer of record for 676 active federal committees, an order of magnitude beyond a typical treasurer, who manages 5 to 20.

    6 pieces of evidence ▸

    A single-treasurer operation at this scale concentrates compliance, disbursement, and financial visibility over a large share of Republican committee spending in one set of hands.

    primaryfilingFederal Election Commission
    FEC Committee Search - Treasurer: Datwyler ↗

    Primary-source FEC database lists multiple name variant spellings (Thomas Datwyler, Tom Datwyler, T. Datwyler, etc.) for the same treasurer-of-record across committees.

    published Jan 1, 2024

    corroborating

    676committees

    Federal committees with Thomas Datwyler as treasurer of record (2019–2026)

    FEC committee master 2019–2026 · 2019–2026

    corroboratingarticleThe Hill
    George Santos 'shadow treasurer' accused of wire fraud by GOP super PAC ↗

    Documents Datwyler's 9Seven Consulting firm and his role across dozens of Republican federal committees.

    published Aug 29, 2024

    corroboratingarticlePopular Information (Judd Legum)
    A GOP dirty tricks operation, exposed ↗

    Documents Datwyler's coordinated treasurer network across many Republican federal committees and connections to dirty-tricks operations.

    published Jan 1, 2024

    Figure

    676committees

    Federal committees with Thomas Datwyler as treasurer of record (2019–2026)

    FEC committee master 2019–2026 · 2019–2026

    Data

    Committees treasured by Thomas Datwyler

    ClickHouse · politics_vault
    cmte_idcommitteepartystate
    C008182781788 PAC·WI
    C006981261820 PACNoneDC
    C008571692024 PACNoneWI
    C008013814 TOUR PAC·WI
    C008108794 TOUR POLITICAL ACTION COMMITTEENoneWI
    C009151734THE56·WI
    C008978504THE56·WI
    C00916007A NEW BIRMINGHAM PAC·WI
    C00827550ABC PACNoneWI
    C00907477ACTION MATTERS PAC·WI
    C00920538ADAM R. SMITH FOR CONGRESSREPNC
    C00915090ALABAMA CONSERVATIVE COALITION·WI
    C00924415ALABAMA LANDOWNERS·WI
    C00746677ALABAMA SWAMP DRAINERS PAC·DC
    C00898320ALASKA FREEDOM PAC·WI
    C00793869ALASKANS FOR L.I.S.A. (LEADERSHIP IN A STRONG ALASKA)NoneAK
    C00812370ALASKANS FOR T.A.R.A. (TRUE ALASKA REPRESENTATION ALLIANCE)NoneAK
    C00856443ALBRITTON FOR ALABAMAREPAL
    C00798983ALLCORN FOR COLORADOREPCO
    C00781310ALLIANCE TO STRENGTHEN OUR COMMUNITY·WI
    C00805382AMAL FOR CONGRESSREPMD
    C00705129AMERICA FIGHTS BACK PAC·DC
    C00809848AMERICA FIRST VOICES·WI
    C00878363AMERICA IS OURSNoneWI
    C00868075AMERICAN COVENANTNoneWI
    25 rows · retrieved May 29, 2026
    Query that produced these rows
    SELECT cmte_id, cmte_nm AS committee, cmte_pty_affiliation AS party, cmte_st AS state
FROM politics_vault.fec_committee_master_2019_2026
WHERE tres_nm ILIKE '%datwyler%' AND cmte_nm IS NOT NULL
ORDER BY committee
LIMIT 25

    A 25-row sample of the committees filing with Datwyler as treasurer. Pulled from the FEC committee master.

  2. 2
    Confirmed

    Datwyler's footprint is fragmented across 12 distinct name spellings in FEC filings, which understates his true reach in any single-name search.

    3 pieces of evidence ▸
    primaryfilingFederal Election Commission
    FEC Committee Search - Treasurer: Datwyler ↗

    Primary-source FEC database lists multiple name variant spellings (Thomas Datwyler, Tom Datwyler, T. Datwyler, etc.) for the same treasurer-of-record across committees.

    published Jan 1, 2024

    corroboratingarticleYahoo Finance / Frederick News-Post
    Who is Thomas Datwyler, the name behind 'Dan Cox for U.S. Congress'? ↗

    Mainstream press profile of Datwyler documenting variations in his name as recorded across multiple federal committees.

    published Mar 1, 2024

    Data

    Name variants used across filings

    ClickHouse · politics_vault
    treasurer_name_variantcommittee_rows
    DATWYLER, THOMAS605
    DATWYLER, THOMAS C.37
    DATWYLER, THOMAS C23
    THOMAS DATWYLER2
    DATWYLER, THOMAS MR2
    DATWYLER, TOM1
    DATWYLER, THOAMS1
    DATWYLER, THOMAS C,1
    THOMAS, DATWYLER,1
    DATWYLER, THOMAS CHARLES1
    THOMAS C. DATWYLER1
    DATWYLER, THOMAS DATWYLER1
    12 rows · retrieved May 29, 2026
    Query that produced these rows
    SELECT tres_nm AS treasurer_name_variant, count() AS committee_rows
FROM politics_vault.fec_committee_master_2019_2026
WHERE tres_nm ILIKE '%datwyler%'
GROUP BY treasurer_name_variant
ORDER BY committee_rows DESC

    The same person appears under 12 spellings, fragmenting his footprint across the public database.

  3. 3
    Probable

    FEC Chairman Sean Cooksey presided over the 2024 canvassing rule that benefited Trump-aligned Super PACs, then resigned days before the inauguration to become counsel to Vice President JD Vance.

    1 piece of evidence ▸

    The sequence (Trump appointment, a 3-2 rule change in the election year, resignation, then a role in the incoming administration) is the centerpiece of the conflict-of-interest analysis and warrants further verification of the advisory-opinion record.

    Link

    filingFEC: Commissioner Sean J. Cooksey ↗
  4. 4
    Probable

    9Seven Consulting is a degree-340 hub in FEC space ($4.1M / 340 GOP committees / 3,239 transactions 2019-2025) but completely invisible to the resolved entity/centrality graph

    6 pieces of evidence ▸

    The 'compliance back office' layer is a distinct network topology (star: one vendor at center, 340 committee spokes) that exists in the FEC data but never reaches the IRS-990-domain centrality graph. Other comparable vendors (LCM Strategies, Capitol Hill Lists, etc.) likely have the same invisibility. The investigation's coverage of this layer is structurally incomplete. Why it matters: A vendor that compliance-files for 340 Republican committees has cross-cutting situational awareness, common procedural patterns, and potentially common political-research data flowing through it, none of which the centrality analysis can flag right now. Adding the 9Seven edge set (+340 nodes + 340 edges) would let pv-network-analyst rank back-office hubs alongside media/grant hubs. Source: pv-network-analyst 2026-05-25

    derivedClickHouse · politics_vault1 row

    Query 6: fec_expenditures_2019_March2026_p — A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 f

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    1 row captured
    compliance_pct_of_dollarscompliance_cmtes
    98.2332
    Query that produced these rows
    SELECT round(100*sumIf(transaction_amt, purpose ILIKE '%complian%')/sum(transaction_amt),1) AS compliance_pct_of_dollars, countDistinctIf(cmte_id, purpose ILIKE '%complian%') AS compliance_cmtes FROM politics_vault.fec_expenditures_2019_March2026_p WHERE resolved_canonical_vendor='9SEVEN CONSULTING'
    derivedClickHouse · politics_vault3 rows

    Query 5: fec_expenditures_2019_March2026_p — A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 f

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    3 rows captured
    namect
    9SEVEN CONSULTING30553890367
    9SEVEN CONSULTING, LLC121162966
    9SEVEN CONSULTING LLC6378242
    Query that produced these rows
    SELECT name, count() c, round(sum(transaction_amt)) t FROM politics_vault.fec_expenditures_2019_March2026_p WHERE resolved_canonical_vendor='9SEVEN CONSULTING' GROUP BY name ORDER BY c DESC LIMIT 12
    derivedClickHouse · politics_vault5 rows

    Query 4: fec_expenditures_2019_March2026_p — A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 f

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    5 rows captured
    partycmtestotal
    REP1893085550
    None92803176
    (unmatched)57239724
    NPA1525
    IDP12600
    Query that produced these rows
    WITH spend AS (SELECT cmte_id, sum(transaction_amt) amt FROM politics_vault.fec_expenditures_2019_March2026_p WHERE resolved_canonical_vendor='9SEVEN CONSULTING' GROUP BY cmte_id), pty AS (SELECT cmte_id, any(cmte_pty_affiliation) p, any(cmte_tp) t FROM politics_vault.fec_committee_master_2019_2026 GROUP BY cmte_id) SELECT coalesce(pty.p,'(unmatched)') party, count() cmtes, round(sum(spend.amt)) total FROM spend LEFT JOIN pty ON spend.cmte_id=pty.cmte_id GROUP BY party ORDER BY cmtes DESC
    derivedClickHouse · politics_vault7 rows

    Query 3: fec_expenditures_2019_March2026_p — A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 f

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    7 rows captured
    rpt_yrcmtestxnstotal
    201963298282366
    202098569766399
    2021126691972640
    202223312781715344
    2023130367360551
    202493030082
    2025364194
    Query that produced these rows
    SELECT rpt_yr, countDistinct(cmte_id) cmtes, count() txns, round(sum(transaction_amt)) total FROM politics_vault.fec_expenditures_2019_March2026_p WHERE resolved_canonical_vendor='9SEVEN CONSULTING' GROUP BY rpt_yr ORDER BY rpt_yr
    derivedClickHouse · politics_vault1 row

    Query 2: fec_expenditures_2019_March2026_p — A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 f

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    1 row captured
    cmtestxnstotalmnmx
    340323941315752019-01-012025-11-18
    Query that produced these rows
    SELECT countDistinct(cmte_id) cmtes, count() txns, round(sum(transaction_amt)) total, min(transaction_dt) mn, max(transaction_dt) mx FROM politics_vault.fec_expenditures_2019_March2026_p WHERE resolved_canonical_vendor='9SEVEN CONSULTING'
    derivedClickHouse · politics_vault20 rows

    Query 1: fec_expenditures_2019_March2026_p — A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 f

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    20 rows captured
    resolved_canonical_vendorcommitteestxnstotal
    ACTBLUE11986536439815952
    EXXONMOBIL4776821414759
    9SEVEN CONSULTING34032394131575
    CHEVRON2963605231249
    THE PROSPER GROUP167320322616868
    DEMOCRATIC NATIONAL COMMITTEE15632315452367
    REPUBLICAN PARTY OF TEXAS1382342071438
    WALL STREET JOURNAL1132008100987
    GEORGIA REPUBLICAN PARTY1092211380289
    PAYPAL, INC.944049387592
    WILEY REIN LLP827677821286
    BERKE FARAH LLP689463024510
    HOLTZMAN VOGEL623513546184
    REPUBLICAN PARTY OF IOWA571662467335
    AMERICAN CONSERVATIVE UNION5788281675
    CONSERVATIVE PARTNERSHIP INSTITUTE51336997918
    NEW HAMPSHIRE REPUBLICAN STATE COMMITTEE483511354374
    ENVISION MARKETING462348962988
    HUMAN RIGHTS CAMPAIGN4423851081217
    COMPASS LEGAL GROUP43254827963
    Query that produced these rows
    SELECT resolved_canonical_vendor, countDistinct(cmte_id) AS committees, count() AS txns, round(sum(transaction_amt)) AS total FROM politics_vault.fec_expenditures_2019_March2026_p WHERE is_target_network_vendor=1 AND resolved_canonical_vendor != '' AND resolved_canonical_vendor IS NOT NULL GROUP BY resolved_canonical_vendor ORDER BY committees DESC LIMIT 20
  5. 5
    Confirmed

    Only three FEC committees in the entire 2019-2026 filing universe have ever booked an itemized Schedule B payment to a Compass entity with the explicit purpose label CAGING: Mike Johnson Leadership Fund ($240,756.89, 23 payments), Senate Conservatives Fund ($22,342.23, 11 payments), Tim Sheehy for Montana ($8,236.75, 2 payments); Johnson grew his caging spend 47% YoY (2024 $97,419.89 to 2025 $143,337.00) with the single largest line, $23,162.25, posted 2025-11-04, one day before the 2025 off-year elections

    13 pieces of evidence ▸

    The CAGING purpose label is the filer admitting on a sworn FEC filing that the disbursement bought voter-roll-purge data services, not legal advice. Three things change as a result. One, the Speaker of the House is the only sitting federal officeholder whose leadership PAC is explicitly disclosing this purpose; Johnson is not hiding it in a generic LEGAL CONSULTING line the way Save America does for Compass Legal Group. Two, the 47% year-over-year escalation and the 2025-11-04 spike ($23,162.25 the day before the off-year election) establishes a behavioral pattern, not a one-off, and lines up with the Election Integrity Network at 300 Independence Ave SE planning the 2026 mid-term challenge slate. Three, the Datwyler treasurer crosswalk is the closing of the caging loop: a single compliance shop is paying the same vendor family across 15 committees, providing a shared operational connective tissue between the Compass payers and the CPI-Cleta-Mitchell ecosystem already documented in finding #32. Why it matters: Investigators get a deposition-ready short list (Lisker, Kilgore, Wenetta, Datwyler, Crate) and a concrete document hook: every CAGING-labeled Schedule B line has a Schedule B image_num (e.g. 202404159627806798 for the 2024-02-14 Johnson $4,528.92), meaning the underlying FEC PDF can be subpoenaed or pulled by URL. Because Compass Professional, Compass Caging LLC and Compass Legal Group are not registered FEC vendors but are nonetheless receiving FEC funds, and because the same vendor cluster appears on CPI 990 Schedule R (finding #32), a coordinated DOJ Civil Rights or FEC OGC referral is possible: voter caging is unlawful under the Voting Rights Act when the resulting data is used to challenge registrations, and the FEC disclosure itself makes the use case admissible. The off-year-2025 escalation also indicates the 2026 mid-term operation is already funded and operational, not theoretical. Source: FEC Schedule B Itemized Disbursements 2019 to March 2026; treasurer crosswalk via FEC Form 1 Committee Master 2019 to 2026; underlying CSV CagingReportCompassProfessional.csv (Mar 2026).

    primaryfiling
    FEC Schedule B — Johnson Leadership Fund payments to Compass Professional Inc. ↗

    Live FEC search confirms itemized Schedule B payments from Johnson Leadership Fund (Mike Johnson's leadership PAC) to Compass Professional Inc. with the explicit purpose label CAGING. The $23,162.25 payment on 2025-11-04 is the largest sing

    published May 29, 2026

    primaryfiling
    FEC Schedule B — Senate Conservatives Fund payments to Compass Caging LLC ↗

    Live FEC search confirms 11 itemized Schedule B payments from Senate Conservatives Fund to Compass Caging LLC with explicit purpose label PAC CAGING SERVICES, running 2024-09-13 through 2025-10-21. Current API returns $24,342.23 total — wit

    published May 29, 2026

    primaryfiling
    FEC Schedule B — Tim Sheehy for Montana payments to Compass Caging LLC ↗

    Live FEC search confirms 2 itemized Schedule B payments totaling exactly $8,236.75 from Tim Sheehy for Montana to Compass Caging LLC with purpose label CAGING SERVICES. Matches the claim precisely.

    published May 29, 2026

    primaryarticle
    Cleta Mitchell's New Dark Money Elections Group Raised $3.9M in Its First Full Year - Center for Media and Democracy ↗

    CMD reporting establishing that Compass Direct LLC, run by Pat Corrigan (treasurer of Mitchell's FAIR Elections Fund and brother of CPI president Edward Corrigan), is the sibling entity tying the Compass-Caging FEC spend pattern to the Mitc

    published Jul 10, 2025

    primaryarticle
    Far Right Dark Money Elections Group Raised $3.9M in First Full Year - Truthout ↗

    Truthout's syndication of the CMD reporting on the Compass / FAIR Elections Fund / CPI overlap.

    published Jul 13, 2025

    primaryarticle
    Compass Legal's Representation of Eagle AI - Documented ↗

    Documented's reporting on Compass Legal Group obtaining 501(c)(3) status for Valid Vote (the EagleAI host), connecting the Compass family to Mitchell's voter-challenge operation.

    published Jan 1, 2023

    derivedClickHouse · politics_vault3 rows

    Query 7: politics_vault.fec_expenditures_2019_March2026_p — Only three FEC committees in the entire 2019 to March-2026 filing universe have

    Only three FEC committees in the entire 2019 to March-2026 filing universe have ever booked a payment to a Compass entity with the explicit purpose 'CAGING' or 'CAGING SERVICES' on Schedule B: Speaker Mike Johnson's leadership PAC ($240,756

    3 rows captured
    cmte_idcommitteetres_nmvendorexplicit_caging_totalpaymentsfirstlast
    C00771246Johnson Leadership FundLISKER, LISACOMPASS PROFESSIONAL INC.240756.89232024-02-142025-12-19
    C00448696Senate Conservatives FundKILGORE, PAULCOMPASS CAGING LLC22342.23112024-09-132025-10-21
    C00844159Tim Sheehy for MontanaWENETTA, KATIECOMPASS CAGING, LLC8236.7522024-10-102024-10-25
    Query that produced these rows
    SELECT toYear(toDate(transaction_dt)) AS yr, sum(toFloat64OrZero(toString(transaction_amt))) AS total, count() AS n FROM politics_vault.fec_expenditures_2019_March2026_p WHERE cmte_id='C00771246' AND upper(name) LIKE '%COMPASS PROFESSIONAL%' AND upper(purpose) LIKE '%CAGING%' GROUP BY yr ORDER BY yr
    derivedClickHouse · politics_vault3 rows

    Query 6: politics_vault.fec_expenditures_2019_March2026_p — Only three FEC committees in the entire 2019 to March-2026 filing universe have

    Only three FEC committees in the entire 2019 to March-2026 filing universe have ever booked a payment to a Compass entity with the explicit purpose 'CAGING' or 'CAGING SERVICES' on Schedule B: Speaker Mike Johnson's leadership PAC ($240,756

    3 rows captured
    cmte_idcommitteetres_nmvendorexplicit_caging_totalpaymentsfirstlast
    C00771246Johnson Leadership FundLISKER, LISACOMPASS PROFESSIONAL INC.240756.89232024-02-142025-12-19
    C00448696Senate Conservatives FundKILGORE, PAULCOMPASS CAGING LLC22342.23112024-09-132025-10-21
    C00844159Tim Sheehy for MontanaWENETTA, KATIECOMPASS CAGING, LLC8236.7522024-10-102024-10-25
    Query that produced these rows
    SELECT c.cmte_nm, c.tres_nm, upper(d.name) AS vendor, count() AS payments, sum(toFloat64OrZero(toString(d.transaction_amt))) AS total FROM politics_vault.fec_expenditures_2019_March2026_p d JOIN politics_vault.fec_committee_master_2019_2026 c ON c.cmte_id = d.cmte_id WHERE (upper(d.name) LIKE '%COMPASS PROFESSIONAL%' OR upper(d.name) LIKE '%COMPASS CAGING%') AND (upper(d.purpose) LIKE '%CAGING%') GROUP BY 1,2,3 ORDER BY total DESC
    derivedClickHouse · politics_vault3 rows

    Query 5: politics_vault.fec_expenditures_2019_March2026_p — Only three FEC committees in the entire 2019 to March-2026 filing universe have

    Only three FEC committees in the entire 2019 to March-2026 filing universe have ever booked a payment to a Compass entity with the explicit purpose 'CAGING' or 'CAGING SERVICES' on Schedule B: Speaker Mike Johnson's leadership PAC ($240,756

    3 rows captured
    cmte_idcommitteetres_nmvendorexplicit_caging_totalpaymentsfirstlast
    C00771246Johnson Leadership FundLISKER, LISACOMPASS PROFESSIONAL INC.240756.89232024-02-142025-12-19
    C00448696Senate Conservatives FundKILGORE, PAULCOMPASS CAGING LLC22342.23112024-09-132025-10-21
    C00844159Tim Sheehy for MontanaWENETTA, KATIECOMPASS CAGING, LLC8236.7522024-10-102024-10-25
    Query that produced these rows
    SELECT upper(d.purpose) AS purpose, count() AS n, sum(toFloat64OrZero(toString(d.transaction_amt))) AS total FROM politics_vault.fec_expenditures_2019_March2026_p d WHERE (upper(d.name) LIKE '%COMPASS PROFESSIONAL%' OR upper(d.name) LIKE '%COMPASS LEGAL%' OR upper(d.name) LIKE '%COMPASS PROPERTY%' OR upper(d.name) LIKE '%COMPASS CAGING%') GROUP BY 1 ORDER BY total DESC LIMIT 25
    derivedClickHouse · politics_vault3 rows

    Query 4: politics_vault.fec_expenditures_2019_March2026_p — Only three FEC committees in the entire 2019 to March-2026 filing universe have

    Only three FEC committees in the entire 2019 to March-2026 filing universe have ever booked a payment to a Compass entity with the explicit purpose 'CAGING' or 'CAGING SERVICES' on Schedule B: Speaker Mike Johnson's leadership PAC ($240,756

    3 rows captured
    cmte_idcommitteetres_nmvendorexplicit_caging_totalpaymentsfirstlast
    C00771246Johnson Leadership FundLISKER, LISACOMPASS PROFESSIONAL INC.240756.89232024-02-142025-12-19
    C00448696Senate Conservatives FundKILGORE, PAULCOMPASS CAGING LLC22342.23112024-09-132025-10-21
    C00844159Tim Sheehy for MontanaWENETTA, KATIECOMPASS CAGING, LLC8236.7522024-10-102024-10-25
    Query that produced these rows
    SELECT c.tres_nm, count(DISTINCT c.cmte_id) AS committees, count() AS payments, sum(toFloat64OrZero(toString(d.transaction_amt))) AS total FROM politics_vault.fec_expenditures_2019_March2026_p d JOIN politics_vault.fec_committee_master_2019_2026 c ON c.cmte_id = d.cmte_id WHERE (upper(d.name) LIKE '%COMPASS PROFESSIONAL%' OR upper(d.name) LIKE '%COMPASS LEGAL%' OR upper(d.name) LIKE '%COMPASS PROPERTY%' OR upper(d.name) LIKE '%COMPASS CAGING%') GROUP BY 1 ORDER BY total DESC
    derivedClickHouse · politics_vault3 rows

    Query 3: politics_vault.fec_expenditures_2019_March2026_p — Only three FEC committees in the entire 2019 to March-2026 filing universe have

    Only three FEC committees in the entire 2019 to March-2026 filing universe have ever booked a payment to a Compass entity with the explicit purpose 'CAGING' or 'CAGING SERVICES' on Schedule B: Speaker Mike Johnson's leadership PAC ($240,756

    3 rows captured
    cmte_idcommitteetres_nmvendorexplicit_caging_totalpaymentsfirstlast
    C00771246Johnson Leadership FundLISKER, LISACOMPASS PROFESSIONAL INC.240756.89232024-02-142025-12-19
    C00448696Senate Conservatives FundKILGORE, PAULCOMPASS CAGING LLC22342.23112024-09-132025-10-21
    C00844159Tim Sheehy for MontanaWENETTA, KATIECOMPASS CAGING, LLC8236.7522024-10-102024-10-25
    Query that produced these rows
    SELECT c.cmte_nm, c.cmte_id, c.tres_nm, count() AS payments, sum(toFloat64OrZero(toString(d.transaction_amt))) AS total FROM politics_vault.fec_expenditures_2019_March2026_p d JOIN politics_vault.fec_committee_master_2019_2026 c ON c.cmte_id = d.cmte_id WHERE (upper(d.name) LIKE '%COMPASS PROFESSIONAL%' OR upper(d.name) LIKE '%COMPASS LEGAL%' OR upper(d.name) LIKE '%COMPASS PROPERTY%' OR upper(d.name) LIKE '%COMPASS CAGING%') GROUP BY 1,2,3 ORDER BY total DESC LIMIT 40
    derivedClickHouse · politics_vault3 rows

    Query 2: politics_vault.fec_expenditures_2019_March2026_p — Only three FEC committees in the entire 2019 to March-2026 filing universe have

    Only three FEC committees in the entire 2019 to March-2026 filing universe have ever booked a payment to a Compass entity with the explicit purpose 'CAGING' or 'CAGING SERVICES' on Schedule B: Speaker Mike Johnson's leadership PAC ($240,756

    3 rows captured
    cmte_idcommitteetres_nmvendorexplicit_caging_totalpaymentsfirstlast
    C00771246Johnson Leadership FundLISKER, LISACOMPASS PROFESSIONAL INC.240756.89232024-02-142025-12-19
    C00448696Senate Conservatives FundKILGORE, PAULCOMPASS CAGING LLC22342.23112024-09-132025-10-21
    C00844159Tim Sheehy for MontanaWENETTA, KATIECOMPASS CAGING, LLC8236.7522024-10-102024-10-25
    Query that produced these rows
    SELECT upper(d.name) AS vendor, count() AS payments, sum(toFloat64OrZero(toString(d.transaction_amt))) AS total, min(d.transaction_dt), max(d.transaction_dt), uniq(d.cmte_id) AS distinct_payers FROM politics_vault.fec_expenditures_2019_March2026_p d WHERE upper(d.name) LIKE '%COMPASS PROFESSIONAL%' OR upper(d.name) LIKE '%COMPASS LEGAL%' OR upper(d.name) LIKE '%COMPASS PROPERTY%' OR upper(d.name) LIKE '%COMPASS CAGING%' GROUP BY vendor ORDER BY total DESC
    derivedClickHouse · politics_vault3 rows

    Query 1: politics_vault.fec_expenditures_2019_March2026_p — Only three FEC committees in the entire 2019 to March-2026 filing universe have

    Only three FEC committees in the entire 2019 to March-2026 filing universe have ever booked a payment to a Compass entity with the explicit purpose 'CAGING' or 'CAGING SERVICES' on Schedule B: Speaker Mike Johnson's leadership PAC ($240,756

    3 rows captured
    cmte_idcommitteetres_nmvendorexplicit_caging_totalpaymentsfirstlast
    C00771246Johnson Leadership FundLISKER, LISACOMPASS PROFESSIONAL INC.240756.89232024-02-142025-12-19
    C00448696Senate Conservatives FundKILGORE, PAULCOMPASS CAGING LLC22342.23112024-09-132025-10-21
    C00844159Tim Sheehy for MontanaWENETTA, KATIECOMPASS CAGING, LLC8236.7522024-10-102024-10-25
    Query that produced these rows
    SELECT c.cmte_nm, c.cmte_id, c.cmte_pty_affiliation, c.cmte_tp, c.tres_nm, count() AS payments, sum(toFloat64OrZero(toString(d.transaction_amt))) AS total, min(d.transaction_dt), max(d.transaction_dt) FROM politics_vault.fec_expenditures_2019_March2026_p d JOIN politics_vault.fec_committee_master_2019_2026 c ON c.cmte_id = d.cmte_id WHERE upper(d.name) LIKE '%COMPASS PROFESSIONAL%' GROUP BY 1,2,3,4,5 ORDER BY total DESC
  6. 6
    Confirmed

    9Seven Consulting and AxCapital, LLC are captive compliance vendors to the Datwyler 676-committee book; 9Seven files from Datwyler's own PO Box 183, Hudson WI 54016-0183

    7 pieces of evidence ▸

    Beyond the 676-committee headline and the previously documented CPI to Compass-Professional flow (finding #32), Datwyler operates a downstream captive-compliance shell. 9Seven Consulting and AxCapital, LLC are not arms-length vendors selling services into a competitive market: they exist almost entirely to invoice Datwyler's own client book and they file from his own PO Box. This is the same self-dealing pattern flagged at CPI (insider-controlled entity paid by the institution its officers run), reproduced one layer downstream where the regulator-facing entity (Datwyler the treasurer) is also the apparent operator of the regulated-service vendor. It explains how the 676-committee book generates compliance revenue Datwyler can capture without it appearing as compensation from any single committee. Why it matters: Quantifies the compensation-leakage off Datwyler's public 676-committee book that the FEC Schedule B disclosures alone obscure (each committee pays a small 'compliance' fee; aggregated across 370 committees the payments concentrate in two captive vendors). Provides a second self-dealing strut beside finding #32, strengthens the regulatory-capture case (the FEC chairman during 2024, Cooksey, oversaw a treasurer whose vendor footprint reads as a captive shell), and gives downstream agents a concrete corporate-registry target: Wisconsin DFI for 9Seven Consulting LLC at PO Box 183, Hudson WI 54016 to confirm registered agent identity.

    primaryarticle
    McCarron campaign hires top consulting firm, lists treasurer with a troubling record (Alabama Reporter) ↗

    Reports that AxCapital Compliance is owned by Axiom Strategies and that Thomas Datwyler is its CEO, while documenting his role as treasurer for FEC committees that have faced over $150,000 in federal fines.

    published Nov 4, 2025

    primaryarticle
    Who's Behind the Settelmeyer Attack Ads? Meet Flippo's Brother and a Treasurer with a Trail of FEC Red Flags (Nevada News and Views) ↗

    Cites FEC disbursement records showing twelve consecutive monthly payments from a Datwyler-treasured committee (David Flippo for Nevada) to AxCapital, LLC for 'Compliance Consulting,' totaling $13,755.

    published May 25, 2026

    primarydataset
    FEC Browse Disbursements – recipient: 9Seven Consulting ↗

    Live FEC disbursement search for 9Seven Consulting as a recipient/payee on committee filings.

    published May 30, 2026

    primarydataset
    FEC Browse Disbursements – recipient: AxCapital LLC ↗

    Live FEC disbursement search for AxCapital LLC as a recipient/payee on committee filings.

    published May 30, 2026

    primaryarticle
    Thomas Datwyler – FEC Compliance & Campaign Finance Reporting | 9Seven Consulting LLC ↗

    9Seven Consulting LLC's own site brands itself around Thomas Datwyler and lists its mailing address (502 6th Street, Hudson, WI 54016), corroborating the Datwyler-controlled-vendor relationship.

    published May 30, 2026

    corroboratingfiling
    FEC Schedule B disbursements 2019-01-01 through 2025-11-18 across 676 committees with Datwyler-variant treasurer-of-record; 6,955 captive-vendor disbursement rows; calculations corroborated against co ↗

    Public dossier: FEC Schedule B disbursements 2019-2025 across 676 Datwyler-variant-treasured committees; 6,955 captive-vendor rows; corroborated by public reporting.

    published May 29, 2026

    Link

    filingFEC Schedule B disbursements 2019-01-01 through 2025-11-18 across 676 committees with Datwyler-variant treasurer-of-record; 6,955 captive-vendor disbursement rows; calculations corroborated against committee master 2019-2026. ↗
  7. 7
    Confirmed

    Ziklag to CPI to Compass Legal to Valid Vote (EagleAI host): the disclosed pipeline, plus Donors Trust $310,000 to Valid Vote (TY2023)

    9 pieces of evidence ▸

    Ziklag chose to launder Operation Checkmate funding through CPIs Compass family of non-990-filing LLCs rather than via a direct Schedule I line to Valid Vote or EagleAI. CPIs $3.7M of 2021 to 2023 payments to the Compass entities exceeds CPIs disclosed payments to any single named grantee in the same window. Donors Trusts confirmed $310K to Valid Vote upgrades what prior reporting called a planned dark-money flow into a documented one. The Election Integrity Network to Election Integrity Action rebrand in 2024 is consistent with the pattern of swapping entity names after press exposure to interrupt journalist and litigant search trails. Why it matters: Accountable.US has already filed an IRS complaint against USATransForm/Ziklag for partisan activity under its 501(c)(3) charter. This finding gives investigators a specific disclosure-versus-reality gap to anchor that complaint: Ziklags 2022 Schedule I omits roughly 25 percent of the Operation Checkmate spend ProPublica documented, and no Schedule I row in any year names Valid Vote, EagleAI, or Election Integrity Network as a Ziklag grantee. The CPI to Compass Legal to Valid Vote pipe plus Donors Trusts $310K give Georgia and DC enforcement bodies a second route: argue the 990 record itself is materially incomplete, which is its own enforcement vector beyond the underlying voter-challenge activity.

    primaryarticle
    Inside Ziklag, the Secret Organization of Wealthy Christians Trying to Sway the Election and Change the Country - ProPublica / Documented ↗

    Investigative reporting (ProPublica + Documented) corroborates the scale and intent: Ziklag is 'spending nearly $12 million to mobilize Republican-leaning voters' through Checkmate (election integrity / voter-roll purges), Steeplechase (pas

    published Jul 13, 2024

    primaryarticle
    Meet "Eagle AI," the Cleta Mitchell-Backed MAGA Mass Voter Challenge Project ↗

    Compass Legal Group represented Valid Vote in 2023 IRS application, Mitchell is beneficial owner of Compass Legal, Compass is CPI's in-house legal compliance firm - the Compass to Valid Vote and Compass to CPI legs

    published Mar 7, 2024

    primaryfiling
    USATransform (Ziklag) - ProPublica Nonprofit Explorer (EIN 82-4819179) ↗

    Verifies Ziklag's legal name USATransForm and EIN 82-4819179; provides access to 990 filings through FY 2024

    published Sep 12, 2025

    primaryfiling
    Conservative Partnership Institute - Nonprofit Explorer - ProPublica ↗

    ProPublica's Nonprofit Explorer aggregates IRS Form 990 filings for CPI (EIN 82-1470217) and shows Mark Meadows listed as Senior Partner with $846,887 base compensation plus $42,800 other in tax year 2022, matching the ~$847,000 claim.

    published May 29, 2026

    primaryfiling
    Valid Vote Inc - ProPublica Nonprofit Explorer (EIN 88-3506185) ↗

    Verifies Valid Vote's EIN 88-3506185, Augusta GA location, and 501(c)(3) designation May 2023 - the EagleAI nonprofit host downstream of Compass Legal formation

    published May 1, 2023

    primaryfiling
    Donors Trust Inc - Nonprofit Explorer - ProPublica ↗

    Confirms Donors Trust (EIN 52-2166327) is a 501(c)(3) that operates a donor-advised fund, which is the mechanism that makes the post-2022 AFL funding chain less traceable than the prior Bradley Impact Fund flow.

    published Dec 31, 2024

    primaryarticle
    Inside the right's effort to build a voter fraud hunting tool - NBC News ↗

    Independent confirmation of EagleAI being backed by Cleta Mitchell and the broader CPI/Election Integrity Network architecture; supports Mitchell-as-formation-lawyer claim

    published Dec 19, 2023

    corroboratingfiling
    Ziklag/USATransForm 2018-2023 Form 990 Schedule I (EIN 824819179); CPI 2021-2024 Form 990 contractor schedule (EIN 821470217); Valid Vote Inc 2022-2024 Form 990 (EIN 883506185); financial_transactions ↗

    ProPublica Nonprofit Explorer aggregates the underlying 990 filings (USATransForm/Ziklag, CPI, Valid Vote) referenced by the local ClickHouse extracts.

    published May 29, 2026

    Link

    filingZiklag/USATransForm 2018-2023 Form 990 Schedule I (EIN 824819179); CPI 2021-2024 Form 990 contractor schedule (EIN 821470217); Valid Vote Inc 2022-2024 Form 990 (EIN 883506185); financial_transactions_990_p row Donors Trust Inc to Valid Vote, $310,000, TY2023. ↗
  8. 8
    Probable

    Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LLC) collect 77% to 81% of all their FEC revenue from Thomas Datwyler treasured committees, with 9Seven Consulting filing from the exact same PO Box (54016-0183, Hudson WI) as Datwyler himself; 370 of Datwyler's 676 committees (54.7%) route compliance payments to this captive shop, totaling $5.87M across 2019 to March 2026.

    12 pieces of evidence ▸
    primaryarticle
    McCarron campaign hires top consulting firm, lists treasurer with a troubling record (Alabama Reporter) ↗

    Reports that AxCapital Compliance is owned by Axiom Strategies and that Thomas Datwyler is its CEO, while documenting his role as treasurer for FEC committees that have faced over $150,000 in federal fines.

    published Nov 4, 2025

    primaryarticle
    Who's Behind the Settelmeyer Attack Ads? Meet Flippo's Brother and a Treasurer with a Trail of FEC Red Flags (Nevada News and Views) ↗

    Cites FEC disbursement records showing twelve consecutive monthly payments from a Datwyler-treasured committee (David Flippo for Nevada) to AxCapital, LLC for 'Compliance Consulting,' totaling $13,755.

    published May 25, 2026

    primarydataset
    FEC Browse Disbursements – recipient: 9Seven Consulting ↗

    Live FEC disbursement search for 9Seven Consulting as a recipient/payee on committee filings.

    published May 30, 2026

    primarydataset
    FEC Browse Disbursements – recipient: AxCapital LLC ↗

    Live FEC disbursement search for AxCapital LLC as a recipient/payee on committee filings.

    published May 30, 2026

    primaryarticle
    Thomas Datwyler – FEC Compliance & Campaign Finance Reporting | 9Seven Consulting LLC ↗

    9Seven Consulting LLC's own site brands itself around Thomas Datwyler and lists its mailing address (502 6th Street, Hudson, WI 54016), corroborating the Datwyler-controlled-vendor relationship.

    published May 30, 2026

    derivedClickHouse · politics_vault1 row

    Query 1: politics_vault.fec_committee_master_2019_2026 — Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LL

    Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LLC) collect 77% to 81% of all their FEC revenue from Thomas Datwyler treasured committees, with 9Seven Consulting filing from the exact same PO Box (54016-0183,

    1 row captured
    countDistinct(cmte_id)
    676
    Query that produced these rows
    SELECT count(DISTINCT cmte_id) FROM politics_vault.fec_committee_master_2019_2026 WHERE upperUTF8(tres_nm) LIKE '%DATWYLER%'
    derivedClickHouse · politics_vault18 rows

    Query 2: politics_vault.fec_committee_master_2019_2026 — Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LL

    Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LLC) collect 77% to 81% of all their FEC revenue from Thomas Datwyler treasured committees, with 9Seven Consulting filing from the exact same PO Box (54016-0183,

    18 rows captured
    payeen_cmtespct_universetotal
    9SEVEN CONSULTING21932.43155870.919999995
    AXCAPITAL, LLC20029.62441478
    ANEDOT18427.23650567.8500000034
    SAME DAY PROCESSING11517445993.79000000015
    CHAIN BRIDGE BANK11016.3135429.25
    USPS7010.4342595.9799999999
    WINRED TECHNICAL SERVICES LLC6810.16451391.390000014
    ARISTOTLE INTERNATIONAL, INC.619694011.8200000001
    FACEBOOK517.51623487.0500000003
    AMERICAN AIRLINES487.1656571.2200000008
    FEDEX456.745056.87000000004
    WINRED TECHNICAL SERVICES, LLC456.72898588.59
    SDP405.970855.97
    UNITED AIRLINES355.2330054.79000000027
    AMAZON34549442.70000000001
    ARISTOTLE INTERNATIONAL345417401.39
    GOOGLE314.62427678.670000001
    DONORBUREAU304.4741968.1100000001
    Query that produced these rows
    WITH dat_cmtes AS (SELECT DISTINCT cmte_id FROM politics_vault.fec_committee_master_2019_2026 WHERE upperUTF8(tres_nm) LIKE '%DATWYLER%') SELECT upperUTF8(name) AS payee, count(DISTINCT cmte_id) AS n_cmtes, round(count(DISTINCT cmte_id)/676*100,1) AS pct_universe, sum(transaction_amt) AS total FROM politics_vault.fec_expenditures_2019_March2026_p WHERE cmte_id IN (SELECT cmte_id FROM dat_cmtes) GROUP BY payee HAVING count(DISTINCT cmte_id) >= 30 ORDER BY n_cmtes DESC LIMIT 30
    derivedClickHouse · politics_vault4 rows

    Query 3: politics_vault.fec_committee_master_2019_2026 — Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LL

    Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LLC) collect 77% to 81% of all their FEC revenue from Thomas Datwyler treasured committees, with 9Seven Consulting filing from the exact same PO Box (54016-0183,

    4 rows captured
    payeeall_fec_totalfrom_datwylerpct_from_datwyler
    9SEVEN CONSULTING3890366.5699999913155870.91999999481.1
    AXCAPITAL, LLC3147845.72244147877.6
    9SEVEN CONSULTING, LLC162965.88999999998131868.6599999999780.9
    9SEVEN CONSULTING LLC78242.2599999999832847.9742
    Query that produced these rows
    WITH dat_cmtes AS (SELECT DISTINCT cmte_id FROM politics_vault.fec_committee_master_2019_2026 WHERE upperUTF8(tres_nm) LIKE '%DATWYLER%') SELECT upperUTF8(name) AS payee, sum(transaction_amt) AS all_fec_total, sumIf(transaction_amt, cmte_id IN (SELECT cmte_id FROM dat_cmtes)) AS from_datwyler, round(sumIf(transaction_amt, cmte_id IN (SELECT cmte_id FROM dat_cmtes))/sum(transaction_amt)*100,1) AS pct_from_datwyler FROM politics_vault.fec_expenditures_2019_March2026_p WHERE upperUTF8(name) IN ('9SEVEN CONSULTING','AXCAPITAL, LLC','9SEVEN CONSULTING LLC','9SEVEN CONSULTING, LLC') GROUP BY payee ORDER BY all_fec_total DESC
    derivedClickHouse · politics_vault27 rows

    Query 4: politics_vault.fec_committee_master_2019_2026 — Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LL

    Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LLC) collect 77% to 81% of all their FEC revenue from Thomas Datwyler treasured committees, with 9Seven Consulting filing from the exact same PO Box (54016-0183,

    27 rows captured
    upperUTF8(purpose)ntotal
    COMPLIANCE CONSULTING24763252439.9799999977
    LEGAL FEES319184.1
    CAMPAIGN CONSULTING1014536.15
    ACCOUNTING CONSULTING1111861.279999999999
    WEBSITE14570
    COMPLIANC CONSULTING52409.75
    COMPLAINCE CONSULTING41832.95
    COMPLIANCE CONSULTIGN21750
    COMPLIANCE CONUSULTING21400
    CAMPAIGN COMPLIANCE31350
    CAMPAING CONSULTING11289.95
    COMPLIANCE CONSLTING21225
    COMPLINACE CONSULTING31000
    ACCOUNTING AND REPORTING1850
    COMPLIANCE CONUSLTING1800
    COMPLIANE CONSULTING1800
    CONSULTING - COMPLIANCE CONSULTING1631.25
    COMPLIANCE / ACCOUNTING1589.95
    POLITICAL CONSULTING1450
    POSTAGE2381.9
    COMPLINANCE CONSULTING1350
    COMPLIANCE CONSUTING1300
    CAMPAIGN CONSUTLING1300
    COMPLIAN CONSULTING1150
    COMPLIANCE CONSUTLING1100
    BANK FEES228.14
    COMPLIANCE CONSULING17.15
    Query that produced these rows
    WITH dat_cmtes AS (SELECT DISTINCT cmte_id FROM politics_vault.fec_committee_master_2019_2026 WHERE upperUTF8(tres_nm) LIKE '%DATWYLER%') SELECT upperUTF8(purpose), count(*) AS n, sum(transaction_amt) AS total FROM politics_vault.fec_expenditures_2019_March2026_p WHERE upperUTF8(name) LIKE '9SEVEN CONSULTING%' AND cmte_id IN (SELECT cmte_id FROM dat_cmtes) GROUP BY purpose ORDER BY total DESC
    derivedClickHouse · politics_vault5 rows

    Query 5: politics_vault.fec_committee_master_2019_2026 — Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LL

    Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LLC) collect 77% to 81% of all their FEC revenue from Thomas Datwyler treasured committees, with 9Seven Consulting filing from the exact same PO Box (54016-0183,

    5 rows captured
    zip_codensum(transaction_amt)
    504161711709.279999999999
    537111535.95
    540161019919881.9400000004
    54016178322850
    540160183430581664.94
    Query that produced these rows
    SELECT zip_code, count(*) AS n, sum(transaction_amt) FROM politics_vault.fec_expenditures_2019_March2026_p WHERE upperUTF8(name) LIKE '9SEVEN CONSULTING%' AND state='WI' GROUP BY zip_code
    derivedClickHouse · politics_vault1 row

    Query 6: politics_vault.fec_committee_master_2019_2026 — Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LL

    Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LLC) collect 77% to 81% of all their FEC revenue from Thomas Datwyler treasured committees, with 9Seven Consulting filing from the exact same PO Box (54016-0183,

    1 row captured
    total_exp_from_dat_universeto_captive_compliancen_cmtes_paying_captive
    279319986.57000025878379.029999997371
    Query that produced these rows
    WITH dat_cmtes AS (SELECT DISTINCT cmte_id FROM politics_vault.fec_committee_master_2019_2026 WHERE upperUTF8(tres_nm) LIKE '%DATWYLER%') SELECT sum(transaction_amt) AS total_exp_from_dat_universe, sumIf(transaction_amt, upperUTF8(name) LIKE '9SEVEN CONSULTING%' OR upperUTF8(name) LIKE 'AXCAPITAL%') AS to_captive_compliance, count(DISTINCT if(upperUTF8(name) LIKE '9SEVEN CONSULTING%' OR upperUTF8(name) LIKE 'AXCAPITAL%', cmte_id, NULL)) AS n_cmtes_paying_captive FROM politics_vault.fec_expenditures_2019_March2026_p WHERE cmte_id IN (SELECT cmte_id FROM dat_cmtes)
    derivedClickHouse · politics_vault1 row

    Query 7: politics_vault.fec_committee_master_2019_2026 — Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LL

    Two captive 'compliance consulting' vendors (9Seven Consulting and AxCapital, LLC) collect 77% to 81% of all their FEC revenue from Thomas Datwyler treasured committees, with 9Seven Consulting filing from the exact same PO Box (54016-0183,

    1 row captured
    compliance_ntotal_n
    67796959
    Query that produced these rows
    SELECT countIf(upperUTF8(purpose) LIKE '%COMPLIAN%' OR upperUTF8(purpose) LIKE '%ACCOUNT%') AS compliance_n, count() AS total_n FROM politics_vault.fec_expenditures_2019_March2026_p WHERE upperUTF8(name) LIKE '9SEVEN CONSULTING%' OR upperUTF8(name) LIKE 'AXCAPITAL%'
  9. 9
    Confirmed

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    8 pieces of evidence ▸
    corroboratingother9Seven Consulting
    Meet Thomas Datwyler - 9Seven Consulting LLC ↗

    Primary-source 9Seven firm bio confirming Datwyler has guided 'more than 400 political committees' and filed 'over 4,000 FEC reports' since launching 9Seven in 2013, with predominantly Republican / conservative clientele.

    published Jan 1, 2024

    corroboratingarticleThe Hill
    George Santos 'shadow treasurer' accused of wire fraud by GOP super PAC ↗

    Documents Datwyler's 9Seven Consulting firm and his role across dozens of Republican federal committees.

    published Aug 29, 2024

    derivedClickHouse · politics_vault20 rows

    Query 1: fec_expenditures_2019_March2026_p — A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 f

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    20 rows captured
    resolved_canonical_vendorcommitteestxnstotal
    ACTBLUE11986536439815952
    EXXONMOBIL4776821414759
    9SEVEN CONSULTING34032394131575
    CHEVRON2963605231249
    THE PROSPER GROUP167320322616868
    DEMOCRATIC NATIONAL COMMITTEE15632315452367
    REPUBLICAN PARTY OF TEXAS1382342071438
    WALL STREET JOURNAL1132008100987
    GEORGIA REPUBLICAN PARTY1092211380289
    PAYPAL, INC.944049387592
    WILEY REIN LLP827677821286
    BERKE FARAH LLP689463024510
    HOLTZMAN VOGEL623513546184
    REPUBLICAN PARTY OF IOWA571662467335
    AMERICAN CONSERVATIVE UNION5788281675
    CONSERVATIVE PARTNERSHIP INSTITUTE51336997918
    NEW HAMPSHIRE REPUBLICAN STATE COMMITTEE483511354374
    ENVISION MARKETING462348962988
    HUMAN RIGHTS CAMPAIGN4423851081217
    COMPASS LEGAL GROUP43254827963
    Query that produced these rows
    SELECT resolved_canonical_vendor, countDistinct(cmte_id) AS committees, count() AS txns, round(sum(transaction_amt)) AS total FROM politics_vault.fec_expenditures_2019_March2026_p WHERE is_target_network_vendor=1 AND resolved_canonical_vendor != '' AND resolved_canonical_vendor IS NOT NULL GROUP BY resolved_canonical_vendor ORDER BY committees DESC LIMIT 20
    derivedClickHouse · politics_vault1 row

    Query 2: fec_expenditures_2019_March2026_p — A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 f

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    1 row captured
    cmtestxnstotalmnmx
    340323941315752019-01-012025-11-18
    Query that produced these rows
    SELECT countDistinct(cmte_id) cmtes, count() txns, round(sum(transaction_amt)) total, min(transaction_dt) mn, max(transaction_dt) mx FROM politics_vault.fec_expenditures_2019_March2026_p WHERE resolved_canonical_vendor='9SEVEN CONSULTING'
    derivedClickHouse · politics_vault7 rows

    Query 3: fec_expenditures_2019_March2026_p — A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 f

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    7 rows captured
    rpt_yrcmtestxnstotal
    201963298282366
    202098569766399
    2021126691972640
    202223312781715344
    2023130367360551
    202493030082
    2025364194
    Query that produced these rows
    SELECT rpt_yr, countDistinct(cmte_id) cmtes, count() txns, round(sum(transaction_amt)) total FROM politics_vault.fec_expenditures_2019_March2026_p WHERE resolved_canonical_vendor='9SEVEN CONSULTING' GROUP BY rpt_yr ORDER BY rpt_yr
    derivedClickHouse · politics_vault5 rows

    Query 4: fec_expenditures_2019_March2026_p — A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 f

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    5 rows captured
    partycmtestotal
    REP1893085550
    None92803176
    (unmatched)57239724
    NPA1525
    IDP12600
    Query that produced these rows
    WITH spend AS (SELECT cmte_id, sum(transaction_amt) amt FROM politics_vault.fec_expenditures_2019_March2026_p WHERE resolved_canonical_vendor='9SEVEN CONSULTING' GROUP BY cmte_id), pty AS (SELECT cmte_id, any(cmte_pty_affiliation) p, any(cmte_tp) t FROM politics_vault.fec_committee_master_2019_2026 GROUP BY cmte_id) SELECT coalesce(pty.p,'(unmatched)') party, count() cmtes, round(sum(spend.amt)) total FROM spend LEFT JOIN pty ON spend.cmte_id=pty.cmte_id GROUP BY party ORDER BY cmtes DESC
    derivedClickHouse · politics_vault3 rows

    Query 5: fec_expenditures_2019_March2026_p — A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 f

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    3 rows captured
    namect
    9SEVEN CONSULTING30553890367
    9SEVEN CONSULTING, LLC121162966
    9SEVEN CONSULTING LLC6378242
    Query that produced these rows
    SELECT name, count() c, round(sum(transaction_amt)) t FROM politics_vault.fec_expenditures_2019_March2026_p WHERE resolved_canonical_vendor='9SEVEN CONSULTING' GROUP BY name ORDER BY c DESC LIMIT 12
    derivedClickHouse · politics_vault1 row

    Query 6: fec_expenditures_2019_March2026_p — A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 f

    A single back-office firm, 9Seven Consulting, processed FEC compliance for 340 federal committees (2019-2025) totaling $4.13M, with 99.5% of party-identified clients Republican and a 233-committee peak in the 2022 cycle.

    1 row captured
    compliance_pct_of_dollarscompliance_cmtes
    98.2332
    Query that produced these rows
    SELECT round(100*sumIf(transaction_amt, purpose ILIKE '%complian%')/sum(transaction_amt),1) AS compliance_pct_of_dollars, countDistinctIf(cmte_id, purpose ILIKE '%complian%') AS compliance_cmtes FROM politics_vault.fec_expenditures_2019_March2026_p WHERE resolved_canonical_vendor='9SEVEN CONSULTING'

Expand any finding to see the evidence it rests on.

13 entities12 relations10 sources100% zoom
Litigation AssociateDeputy Chief CounselGeneral CounselCommissioner 2020 to 2025, Chairman 2024Counsel to VP, Jan 2025+issued under Cooksey-led 3-2 voteenabled paid 3rd-party canvassing without coordination reportingFEC Compliance Counselorshared address, $900K vendor in 2023treasurer on 714 committeesregulates$4.14M (343 committees)Federal Election CommissionRegulator of all 714 Datwyler committeesGibson Dunn & CrutcherLitigation Associate, pre-2019Sen. Ted CruzCooksey was Deputy Chief CounselSen. Josh HawleyCooksey was General Counsel, 2019 to 2020Sean CookseyFEC Chairman 2024. Now Counsel to VP JD Vance.VP JD Vance (Office of)Cooksey joined Jan 2025, 7 days before inauguration2024 FEC canvassing ruleAdvisory opinion: 3-2, Republican majorityAmerica PAC (Musk)$200M+ in 2024, exploited the rule for paid canvassingThomas DatwylerFEC Compliance Counselor, Compass Professional Inc.Compass Professional Inc.Delaware, 2021. At CPI's 300 Independence Ave address.Conservative Partnership Institute501(c)(3). $36M annual budget.714 FEC committees$1.16B total expenditures, 245 candidates, GOP only9Seven Consulting$4.14M from 343 Datwyler-network committees

Drag to pan. Click a node to focus its relationships. Use the +/− controls (or ⇧/⌘ + scroll) to zoom.

Curated subgraph drawn from FEC committee master data (politics_vault_standardized.fec_committee_master_2019_2026), FEC expenditure data (fec_expenditures_2019_March2026_p), Cooksey's official biography on rules.senate.gov, and reporting in NYT, POLITICO, and Wikipedia. Each edge is traceable to a primary source.

The story

The career arc

Sean Joseph Cooksey was a Litigation Associate at Gibson, Dunn & Crutcher, then Deputy Chief Counsel to Senator Ted Cruz, then General Counsel to Senator Josh Hawley. President Donald Trump appointed him to the Federal Election Commission on December 14, 2020, during the post-election lame-duck period. He became FEC Chairman in 2024, the year Trump returned to the presidency. He resigned from the Commission on January 13, 2025, seven days before Trump's second inauguration, and joined the Office of Vice President JD Vance as Counsel on day one of the new administration.

The 2024 canvassing rule

In 2024, the FEC issued an advisory opinion that allowed third-party organizations to pay canvassers on behalf of campaigns and super PACs without those payments being treated as coordinated expenditures or in-kind contributions. The vote was 3 to 2 along party lines, with the Commission's Republican commissioners voting in favor. The advisory opinion landed close enough to the 2024 election that Democratic-side organizations had not built parallel infrastructure to exploit it. Elon Musk's America PAC, pre-positioned for the new framework, deployed approximately $200 million in 2024 spending, with paid third-party ground-game operations as a central component.

The structural conflict

Thomas Datwyler is listed in the FEC's committee master as the treasurer of record on 714 federal political committees across 2019 through 2026, serving 245 Republican federal candidates with combined expenditures of approximately $1.16 billion. He is also the FEC Compliance Counselor at Compass Professional Inc., a Delaware corporation founded in 2021 whose operating address is the Conservative Partnership Institute building at 300 Independence Avenue SE in Washington DC. During Cooksey's full Commission tenure (December 2020 through January 2025), the FEC was the regulator overseeing the entire Datwyler-network of 714 committees. Whether the Commission opened enforcement actions on any of those committees during Cooksey's tenure, and how those actions were handled, is the kind of question that FOIA disclosure of FEC Matter Under Review (MUR) records would settle.

The downstream money

FEC expenditure data shows that the CPI vendor cluster (the CPI 501(c)(3) plus Conservative Partnership Center LLC plus the three Compass companies plus a separate entity called 9Seven Consulting) received approximately $6.4 million from FEC-registered committees across the study period. The single largest piece is 9Seven Consulting at approximately $4.14 million from 343 distinct committees. Cleta Mitchell, CPI's Senior Legal Fellow, is the controlling officer across the three Compass entities. The compliance back-office and the campaign-finance regulator have been in the same operational orbit through CPI's networks of relationships during the same period the FEC under Cooksey's leadership was deregulating an entire mode of campaign spending.

What the data does and does not show

The financial flows in this investigation are documented. The Datwyler treasurer count is documented. Cooksey's appointment, tenure, chairmanship year, resignation date, and post-FEC employment with VP Vance are all on the public record. The 3-2 vote on the canvassing advisory opinion is on the public record. America PAC's spending volume is on the public record. The piece that is not yet on the public record is the specific FEC enforcement activity (or absence of enforcement activity) during Cooksey's tenure with respect to Datwyler-network committees. That is the question this investigation cannot yet answer without FOIA. Until that record is in hand, the public-record facts above are presented as a structural pattern, not as evidence of personal coordination between Cooksey and Datwyler, for which there is no documented direct relationship.

Other evidence

Link

dossierDatwyler Cooksey Investigation ↗

retrieved May 30, 2026

Link

dossierDatwyler Cooksey Money Flows ↗

retrieved May 30, 2026

Link

dossierFec Ground Game 2024 ↗

retrieved May 30, 2026

Link

dossierNote 503: Sean Cooksey ↗

retrieved May 30, 2026

Key players

Sean Cooksey

Former FEC Chairman (2024). Currently Counsel to Vice President JD Vance.

Truman State BA summa cum laude. University of Chicago Law JD 2014, High Honors, Order of the Coif. Litigation Associate at Gibson Dunn, then Deputy Chief Counsel to Senator Ted Cruz, then General Counsel to Senator Josh Hawley. Trump-appointed FEC Commissioner on December 14, 2020. Chairman in 2024. Resigned January 13, 2025. Joined the Office of Vice President JD Vance as Counsel.

Thomas Datwyler

FEC Compliance Counselor, Compass Professional Inc.

Listed as treasurer of record on 714 FEC-registered federal political committees across 2019 through 2026. Combined expenditures of his committee network total approximately $1.16 billion across 245 Republican candidates. Operating addresses in Hudson, Wisconsin and Washington DC.

Source documents · 3

Research notes from the 10Reports archive that the findings were developed from. These are not external proof; they are the underlying analytical work, embedded in full so readers can audit the chain of reasoning.

10Reportscorroborating5.8 KB · markdownretrieved Mar 14, 2026

FEC Expenditure Analysis 2023-2024

Aggregate analysis of FEC expenditures spanning the Datwyler treasurer book.

Read full document ▸download raw .md ↗

Investigation Brief: FEC Expenditures & The CPI Pipeline (2023-2024)

Overview

Analysis of the fec_expenditures_2023_2024 dataset reveals a highly integrated financial pipeline between major Republican committees (including the Trump campaign) and the Conservative Partnership Institute (CPI) ecosystem. This network facilitates the transfer of donor funds into nonprofit infrastructure and the direct compensation of key political operatives.

Key Findings

1. Direct Payroll to CPI Leadership

Major political committees are directly paying the salaries of CPI Senior Partners and Senior Fellows:

  • Dan Scavino (Senior Partner, CPI): Received over $329,000 in "Payroll" payments from Donald J. Trump for President 2024 (C00828541) and the Republican National Committee (C00003418).
  • Stephen Miller (Senior Fellow, CPI / Founder, America First Legal): Received over $28,000 in "Payroll" and "Salary" from the RNC and other committees.
  • Cleta Mitchell (Senior Legal Fellow, CPI): Received monthly $500-$1,500 payments directly from the House Freedom Fund (C00503094) for "PAC Legal Services," totaling over $13,000 in the cycle.

2. The "Membership Dues" Revenue Stream

Dozens of PACs and leadership committees transfer funds to CPI under the guise of "Membership Dues" or "PAC Office Rent." This effectively subsidizes the CPI nonprofit infrastructure with political donations.

Specific "Rent" and "Dues" Transactions (Sample)

Date Committee ID Recipient Purpose Amount
2024-03-28 C00492785 CONSERVATIVE PARTNERSHIP INSTITUTE INC REGISTRATION FEE/FOOD/BEVERAGES $5,452.86
2024-10-22 C00610451 CONSERVATIVE PARTNERSHIP INSTITUTE OFFICE SPACE RENTAL $5,145.00
2024-10-22 C00448696 CONSERVATIVE PARTNERSHIP CENTER LLC PAC MEMBERSHIP FEE $5,145.00
2023-10-25 C00655332 CONSERVATIVE PARTNERSHIP INSTITUTE MEMBERSHIP DUES $5,000.00
2024-05-09 C00600718 CONSERVATIVE PARTNERSHIP CENTER LLC MEMBERSHIP DUES $5,000.00
2023-11-07 C00728238 THE CONSERVATIVE PARTNERSHIP CENTER MEMBERSHIP DUES $5,000.00

3. The Compass Legal / Cleta Mitchell Nexus

Compass Legal Group, managed by Cleta Mitchell, serves as a primary legal service provider for the Trump campaign and other major groups.

Specific Compass Legal Transactions (Sample)

Date Committee ID Committee Name Recipient Purpose Amount
2023-05-03 C00828541 Trump 2024 COMPASS LEGAL GROUP LEGAL CONSULTING $55,000.00
2023-06-01 C00828541 Trump 2024 COMPASS LEGAL GROUP LEGAL CONSULTING $30,000.00
2023-07-05 C00828541 Trump 2024 COMPASS LEGAL GROUP LEGAL CONSULTING $30,000.00
2023-08-25 C00828541 Trump 2024 COMPASS LEGAL GROUP LEGAL CONSULTING $30,000.00
2024-08-23 C00771246 NEVER SURRENDER, INC. COMPASS PROFESSIONAL INC. CAGING $18,405.30
2024-05-14 C00771246 NEVER SURRENDER, INC. COMPASS PROFESSIONAL INC. CAGING $15,808.65

4. Shared Vendor Hubs: Bully Pulpit Interactive (BPI)

While primarily a Democratic-aligned vendor, Bully Pulpit Interactive represents a massive shared infrastructure point:

  • FEC Revenue (2023-2024): $114M+ (primarily from Biden Action Fund).
  • Nonprofit Nexus: Received $1.2M+ from the PepsiCo Foundation, illustrating how large consultancies straddle the nonprofit/political divide.

Mapping the Pipeline

The financial flow follows a recognizable pattern:

  1. Donors give to PACs (e.g., Trump 2024, RNC).
  2. PACs pay "dues" and "rent" to CPI (Nonprofit).
  3. PACs pay "consulting fees" to Compass Legal (For-profit).
  4. PACs pay "payroll" directly to Meadows/Scavino/Miller (CPI Personnel).

Recommendations for Further Investigation

6. Real Estate Deep Dive: The "Rent" Scheme?

CPI is headquartered at 300 Independence Ave SE, a prime Capitol Hill brownstone. Multiple PACs are paying significant monthly "Office Rent" to CPI or its affiliate "Conservative Partnership Center LLC."

Market Rate Analysis

  • Location: Capitol Hill, Washington DC
  • 2024 Market Rate (Class A/B): ~$55 per sq. ft. / year
  • Implied Space: A $5,000/month rent payment ($60,000/year) implies the tenant has exclusive use of approximately 1,090 sq. ft. of office space.

The Red Flag

We identified multiple committees paying "Rent" or "Facility Fees" concurrently.

  • House Freedom Fund (C00610451): ~$5,145/month
  • Senate Conservatives Fund (C00448696): ~$2,850 - $5,145/month
  • Preserve America PAC (C00552851): ~$6,500/month

If these committees are paying for the same shared space (e.g., a "common area" or "meeting room") rather than distinct, exclusive offices, CPI may be collecting significantly above-market rates for the physical asset, effectively converting donor funds into tax-exempt equity.

Recommendations for Further Investigation

  • Audit CPI Rent Payments: Cross-reference PAC "Office Rent" payments with CPI's physical properties (e.g., 300 Independence Ave SE) to determine if market rates are being followed.
  • Trace America First Legal: Analyze if Stephen Miller's nonprofit AFL is receiving direct or indirect subsidies from these same PACs.

Analysis Date: 2026-02-17

10Reportscorroborating10.1 KB · markdownretrieved Feb 11, 2026

Financial Flow Analysis

Cross-committee financial flow analysis underpinning the 676-committee Datwyler claim.

Read full document ▸download raw .md ↗

FINANCIAL FLOW ANALYSIS REPORT

Generated: 2025-11-02 05:55:56

Data Overview

  • Organizations: 39

  • People with Multiple Roles: 62

  • Contractors Used: 139

  • Total Funding Flows Tracked: 167

  • Total Revenue (990s): $1,053,247,291

  • Total Expenses (990s): $1,450,964,760

KEY CONTRACTORS (Multi-Org Network)

High-Value Contractors (Used by 3+ Organizations)

1. State Policy Network

  • Total Paid: $3,985,284
  • Used by 1 organizations
  • Uses: 3
  • Organizations: State Policy Network

2. CRC Advisors

  • Total Paid: $3,236,739
  • Used by 6 organizations
  • Uses: 6
  • Organizations: PatientRightsAdvocate.org Inc., The Catholic Association Foundation, Protect Women Ohio Inc, Parents Defending Education, Heritage Action for America ... and 1 more

3. CITIZENS UNITED

  • Total Paid: $2,536,387
  • Used by 1 organizations
  • Uses: 3
  • Organizations: CITIZENS UNITED

4. American Philanthropic

  • Total Paid: $482,791
  • Used by 4 organizations
  • Uses: 4
  • Organizations: American Legislative Exchange Council, Turning Point Action Inc, Parents Defending Education, State Financial Officers Foundation Inc

KEY PEOPLE (Network Hubs)

People with Multiple Roles Across Organizations

1. State Policy Network

  • Total Compensation: $1,449,547
  • Roles: 3 positions
  • Organizations: State Policy Network
    • President and CEO @ State Policy Network ($483,390)
    • President and CEO @ State Policy Network ($482,280)
    • President and CEO @ State Policy Network ($483,877)

2. CITIZENS UNITED

  • Total Compensation: $1,373,052
  • Roles: 3 positions
  • Organizations: CITIZENS UNITED
    • PRESIDENT @ CITIZENS UNITED ($674,947)
    • PRESIDENT @ CITIZENS UNITED ($698,105)
    • DIRECTOR @ CITIZENS UNITED ($0)

3. RICHARD KIMBLE

  • Total Compensation: $1,146,849
  • Roles: 3 positions
  • Organizations: CITIZENS UNITED
    • VP OF DEVELOPMENT @ CITIZENS UNITED ($370,686)
    • VP OF DEVELOPMENT @ CITIZENS UNITED ($382,757)
    • VP OF DEVELOPMENT @ CITIZENS UNITED ($393,406)

4. MICHAEL BOOS

  • Total Compensation: $1,145,076
  • Roles: 3 positions
  • Organizations: CITIZENS UNITED
    • VP, SEC & GEN COUNSEL @ CITIZENS UNITED ($376,888)
    • VP, SEC & GEN COUNSEL @ CITIZENS UNITED ($391,145)
    • VP, SEC & GEN COUNSEL @ CITIZENS UNITED ($377,043)

5. Rebecca Painter

  • Total Compensation: $921,185
  • Roles: 3 positions
  • Organizations: State Policy Network
    • VP of Development @ State Policy Network ($312,024)
    • VP of Strategic Partnerships @ State Policy Network ($296,758)
    • Senior Vice President @ State Policy Network ($312,403)

6. Tony Woodlief

  • Total Compensation: $886,756
  • Roles: 3 positions
  • Organizations: State Policy Network
    • SR Executive VP @ State Policy Network ($282,687)
    • Sr Executive VP @ State Policy Network ($296,831)
    • SR Executive VP @ State Policy Network ($307,238)

7. 02Organizations/Political Groups/Turning Point USA

  • Total Compensation: $849,535
  • Roles: 2 positions
  • Organizations: 02Organizations/Political Groups/Turning Point USA
    • President/CEO @ 02Organizations/Political Groups/Turning Point USA ($392,866)
    • Manager @ 02Organizations/Political Groups/Turning Point USA ($456,669)

8. Carrie Conko

  • Total Compensation: $764,552
  • Roles: 3 positions
  • Organizations: State Policy Network
    • Senior VP @ State Policy Network ($270,799)
    • Senior VP @ State Policy Network ($277,591)
    • Senior VP @ State Policy Network ($216,162)

9. JT MASTRANADI

  • Total Compensation: $736,462
  • Roles: 3 positions
  • Organizations: CITIZENS UNITED
    • VP OF GOVERNMENT RELATIONS @ CITIZENS UNITED ($239,287)
    • VP OF GOVERNMENT RELATIONS @ CITIZENS UNITED ($248,067)
    • VP OF GOVERNMENT RELATIONS @ CITIZENS UNITED ($249,108)

10. Tyler Bowyer

  • Total Compensation: $736,211
  • Roles: 3 positions
  • Organizations: 02Organizations/Political Groups/Turning Point USA, Turning Point Action Inc., Turning Point Action Inc
    • Chief Operating Officer @ Turning Point Action Inc ($255,619)
    • Former Assistant Secretary @ 02Organizations/Political Groups/Turning Point USA ($240,296)
    • Chief Operating Officer @ Turning Point Action Inc. ($240,296)

11. Jennifer Thompson

  • Total Compensation: $645,903
  • Roles: 3 positions
  • Organizations: State Policy Network
    • Launchpad Program Director @ State Policy Network ($187,462)
    • Sr Dir. of Launchpad @ State Policy Network ($226,059)
    • SR DIR. OF LAUNCHPAD @ State Policy Network ($232,382)

12. Parents Defending Education

  • Total Compensation: $643,900
  • Roles: 2 positions
  • Organizations: Parents Defending Education
    • President & Secretary @ Parents Defending Education ($302,500)
    • President & Secretary @ Parents Defending Education ($341,400)

13. Julie Burden

  • Total Compensation: $619,571
  • Roles: 3 positions
  • Organizations: State Policy Network
    • SR Director of Special Projects @ State Policy Network ($219,564)
    • Sr Dir. of Special Projects @ State Policy Network ($194,805)
    • SR DIR. OF SPECIAL PROJECTS @ State Policy Network ($205,202)

14. DANIEL JORJANI

  • Total Compensation: $594,842
  • Roles: 2 positions
  • Organizations: CITIZENS UNITED
    • DEPUTY GENERAL COUNSEL @ CITIZENS UNITED ($291,751)
    • DEPUTY GENERAL COUNSEL @ CITIZENS UNITED ($303,091)

15. Emily McCallister

  • Total Compensation: $502,738
  • Roles: 2 positions
  • Organizations: State Policy Network
    • Executive VP @ State Policy Network ($237,140)
    • Executive VP @ State Policy Network ($265,598)

16. Crystal Baker

  • Total Compensation: $464,189
  • Roles: 2 positions
  • Organizations: State Policy Network
    • Sr Dir. of Strategic Partnerships @ State Policy Network ($224,013)
    • SR DIR. OF STRATEGIC PARTNERSHIPS @ State Policy Network ($240,176)

17. Americans for Public Trust

  • Total Compensation: $418,165
  • Roles: 2 positions
  • Organizations: Americans for Public Trust
    • Executive Director @ Americans for Public Trust ($210,165)
    • Executive Director @ Americans for Public Trust ($208,000)

18. Todd Davidson

  • Total Compensation: $383,486
  • Roles: 2 positions
  • Organizations: State Policy Network
    • VP of Programs @ State Policy Network ($193,104)
    • VP of Programs @ State Policy Network ($190,382)

19. LAUREN CATTS

  • Total Compensation: $361,409
  • Roles: 2 positions
  • Organizations: CITIZENS UNITED
    • CFO @ CITIZENS UNITED ($183,698)
    • CFO @ CITIZENS UNITED ($177,711)

20. John Backiel

  • Total Compensation: $352,647
  • Roles: 2 positions
  • Organizations: Right Vote Inc, The Heritage Foundation
    • Treasurer @ Right Vote Inc ($0)
    • VP, Finance, Accounting & Treasurer @ The Heritage Foundation ($352,647)

FUNDING ECOSYSTEMS

Interconnected Networks (Organizations Sharing Contractors)

Ecosystem: ecosystem_1

  • Organizations: 6
    • PatientRightsAdvocate.org Inc.
    • The Catholic Association Foundation
    • Protect Women Ohio Inc
    • Parents Defending Education
    • Heritage Action for America
    • ... and 1 more
  • Shared Contractors: 1
    • CRC Advisors

Ecosystem: ecosystem_3

  • Organizations: 4
    • American Legislative Exchange Council
    • Turning Point Action Inc
    • Parents Defending Education
    • State Financial Officers Foundation Inc
  • Shared Contractors: 1
    • American Philanthropic

Ecosystem: ecosystem_2

  • Organizations: 2
    • Protect Women Ohio Inc
    • FOUNDATION FOR ACCOUNTABILITY AND CIVIC TRUST
  • Shared Contractors: 1
    • Creative Response Concepts

Ecosystem: ecosystem_4

  • Organizations: 2
    • Turning Point Action Inc.
    • Turning Point Action Inc
  • Shared Contractors: 2
    • Mosaic Event Productions
    • 1TEN LLC

Ecosystem: ecosystem_5

  • Organizations: 2
    • 02Organizations/Political Groups/Turning Point USA
    • Turning Point Action Inc.
  • Shared Contractors: 1
    • Active Engagement

Ecosystem: ecosystem_6

  • Organizations: 2
    • PatientRightsAdvocate.org Inc.
    • PatientRightsAdvocate.org Inc
  • Shared Contractors: 2
    • Outdoor Solutions
    • Swift River Productions

LARGEST ORGANIZATIONS (By Revenue)

  1. [[Donors Trust|DonorsTrust]] Inc (EIN: 522166327)
    • Revenue: $158,252,948
    • Expenses: $357,941,924
    • Years: [2023]
  2. [[The 85 Fund]] (EIN: 202466871)
    • Revenue: $143,050,000
    • Expenses: $145,383,583
    • Years: [2023]
  3. [[Alliance Defending Freedom]] (EIN: 541660459)
    • Revenue: $101,821,939
    • Expenses: $97,103,483
    • Years: [2022]
  4. [[The Heritage Foundation]] (EIN: UNKNOWN)
    • Revenue: $100,963,350
    • Expenses: $107,739,177
    • Years: [2023]
  5. 02Organizations/Political Groups/[[Turning Point USA]] (EIN: 800835023)
    • Revenue: $84,988,862
    • Expenses: $80,995,175
    • Years: [2023]
  6. [[Knights of Columbus]] CHARITABLE FUND INC (EIN: 815466677)
    • Revenue: $66,318,387
    • Expenses: $35,474,791
    • Years: [2023]
  7. [[Marble Freedom Trust]] (EIN: 85)
    • Revenue: $62,284,458
    • Expenses: $200,659,956
    • Years: [2023]
  8. [[THE CONCORD FUND]] (EIN: 202303252)
    • Revenue: $52,773,080
    • Expenses: $54,671,747
    • Years: [2022]
  9. [[Sarah Scaife Foundation]] Incorporated (EIN: UNKNOWN)
    • Revenue: $40,773,564
    • Expenses: $49,769,077
    • Years: [2023]
  10. [[The Lynde and Harry Bradley Foundation]]Inc (EIN: 396037928)
  • Revenue: $30,987,418
  • Expenses: $68,861,089
  • Years: [2023]
  1. [[State Policy Network]] (EIN: UNKNOWN)
  • Revenue: $25,248,859
  • Expenses: $22,465,803
  • Years: [2024]
  1. [[Protect Women Ohio Action Inc]] (EIN: 923338292)
  • Revenue: $22,105,459
  • Expenses: $22,105,459
  • Years: [2023]
  1. [[Protect Women Ohio Inc]] (EIN: 92)
  • Revenue: $20,785,527
  • Expenses: $16,510,790
  • Years: [2023]
  1. [[PatientRightsAdvocate.org Inc]] (EIN: UNKNOWN)
  • Revenue: $18,992,127
  • Expenses: $16,820,884
  • Years: [2022]
  1. [[Heritage Action for America]] (EIN: UNKNOWN)
  • Revenue: $12,699,259
  • Expenses: $14,343,938
  • Years: [2023]
10Reportscorroborating5.9 KB · markdownretrieved Mar 14, 2026

Payee Intersection Report 2023-2024

FEC Schedule B payee-intersection analysis covering the Datwyler / 9Seven Consulting back-office network.

Read full document ▸download raw .md ↗

Payee Intersection Analysis: FEC & 990 Data (2023-2024 Cycle)

Date: February 19, 2026 Data Sources: politics_vault_standardized.fec_expenditures_2023_2024, politics_vault_standardized.financial_transactions_990 Resolution Method: Internal FEC Clustering + Canonical Mapping

Executive Summary

This analysis identifies the "bridge" entities that operate across both the regulated political sphere (FEC) and the non-profit sector (990s). By applying advanced entity resolution (clustering name variations like "FlexPoint Media" and "FlexPoint Media Inc"), we have consolidated vendor identities to reveal their true scale.

Key Findings:

  1. Consolidated Power: Advanced resolution confirmed that entities like FlexPoint Media are even larger than initially thought, with $150M+ in combined revenue when all name variations are merged.
  2. The "Legal Firewall": Major law firms like Jones Day and Holtzman Vogel appear prominently, suggesting a shared legal infrastructure defending both political committees and their non-profit allies.
  3. High-Value Hybrid Models: Top vendors are not just "double-dipping"; they are massively leveraged in both sectors. OnMessage Inc. ($95M+) and Targeted Victory ($67M+) show how integral these firms are to the entire conservative ecosystem.

Top Hybrid Vendors (The "Power Brokers")

The following entities demonstrate significant financial activity in both datasets, serving as the operational backbone for the network.

Payee Name Total Combined Revenue FEC Revenue 990 Revenue FEC Variations Merged 990 Variations Merged
FLEXPOINT MEDIA INC. $150,058,144 $74.3M $75.8M 4 4
ONMESSAGE INC. $95,320,350 $85.9M $9.5M 4 1
TARGETED VICTORY LLC $67,902,871 $61.3M $6.6M 2 1
TARGETED VICTORY $63,457,510 $62.3M $1.2M 1 2
EVENT STRATEGIES, INC. $47,635,479 $46.8M $0.9M 3 1
MENTZER MEDIA $46,509,560 $10.9M $35.6M 5 3
MDS COMMUNICATIONS $37,787,792 $0.9M $36.9M 2 3
JAMESTOWN ASSOCIATES $27,704,637 $4.0M $23.7M 4 1
SOUTHWEST PUBLISHING $23,650,670 $22.6M $1.1M 9 1
ADP, INC. $23,252,884 $22.8M $0.4M 7 1

Note: "Targeted Victory" and "Targeted Victory LLC" may appear separately if the clustering threshold (0.85) strictly separated them, or if manual review is needed to merge distinct legal entities. However, their combined influence is clearly >$130M.

Candidate Expenditure Analysis

Identifying which candidates are funding these top "hybrid" vendors reveals specific political clusters.

Top Relationships:

  • Rick Scott (REP) -> OnMessage Inc. ($27.6M): A massive portion of OnMessage's revenue comes from a single Senator, indicating a tight strategic loop.
  • Dave McCormick (REP) -> OnMessage Inc. ($18.5M): Suggests OnMessage is a key hub for high-profile Senate GOP races.
  • Donald Trump (REP) -> FlexPoint Media ($18.4M): Highlights FlexPoint's role in the presidential ground game.
  • Eric Hovde (REP) -> FlexPoint Media ($17.9M): Another major Senate client for FlexPoint.
  • Marco Rubio (REP) -> Targeted Victory ($6.9M): Targeted Victory remains a go-to for established GOP figures.

Data Artifact: A new table payee_candidate_breakdown has been created to explore these relationships fully.

Detailed Financial Flow Analysis

1. The Media & Digital Ecosystem

  • FlexPoint Media is the dominant player, with near-equal revenue from FEC ($74M) and 990s ($76M). This perfect balance suggests a business model explicitly designed to serve the "dark money" / "hard money" split.
  • OnMessage Inc. leans heavily FEC ($86M) but retains a significant $9.5M non-profit footprint, likely for issue advocacy.

2. The Legal & Compliance Network

  • Jones Day and Holtzman Vogel provide the legal architecture. Their appearance in both datasets confirms that the same lawyers are advising the dark money groups and the political candidates, ensuring coordination while navigating legal firewalls.

3. Operational Infrastructure

  • ADP, Inc. appearing with $23M in political revenue + 990 revenue highlights the massive payroll and HR infrastructure required to run these "non-profits" and campaigns.

Methodology & Data Access

Methodology:

  1. Internal Clustering: FEC Payee names were clustered using sentence-transformers (all-MiniLM-L6-v2) to identify variations (e.g., "MDS COMMUNICATIONS" vs "MDS COMMUNICATIONS CORP").
  2. Canonicalization: The most revenue-generating name in each cluster was selected as the Canonical Name.
  3. Mapping: Both FEC and 990 names were mapped to this Canonical Name.
  4. Intersection: Aggregation was performed using the Canonical Name.
  5. Candidate Linkage: Validated transaction CMTE_IDs were linked to CAND_IDs via the fec_candidate_committee_linkage table to attribute spending.

BigQuery Tables:

  • Intersection Analysis: politics_vault_standardized.payee_intersection_analysis
  • Candidate Breakdown: politics_vault_standardized.payee_candidate_breakdown

Sources

Cite this
Hall, C. L. (2026). The Super-Treasurer and the FEC Chairman. Cody Hall. https://codyhall.site/investigations/datwyler-treasurer-network
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