Investigation
The Caging Loop
How returned campaign mail at 300 Independence Ave becomes voter-challenge ammunition.
TL;DR
At 300 Independence Ave SE, the CPI 'Patriot's Row' hub, Compass Professional Inc. processes 'undeliverable' fundraising mail for committees like the Mike Johnson Leadership Fund. This investigation traces the closed loop: fundraising generates names, caging identifies who moved, and Cleta Mitchell's Election Integrity Network / EagleAI a few desks away can turn that data into voter-roll challenges.
What we found · 5 findings
1
Confirmed9Seven 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
More detail ▸ ▾Finding 9Seven Consulting is a single compliance/treasury vendor serving 340 distinct FEC committees, processed 3,239 disbursements totaling $4,131,575 (2019-01-01 to 2025-11-18). 99.5% of party-identified clients are Republican; 233 committees and $1.72M peak in the 2022 cycle. ZERO presence in graph_nodes / graph_edges / entity_network_metrics / er_resolved_clusters. Inference 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.
2
ConfirmedDHS gave a June 2025 briefing to Cleta Mitchell's Election Integrity Network on the federal citizenship verification database, direct executive-branch coordination with a private voter-suppression organization
1 piece of evidence ▸ ▾DHS access to citizenship-verification systems was being shared in real time with the legal architect of the 2020 Trump election challenge. Combined with Mitchell's stated belief that 'Democrats win elections only by cheating,' this connects federal infrastructure to the post-2020 voter-suppression operational apparatus. Why it matters: This is government-to-private-network information flow in a politically sensitive direction. Worth tracking which DHS official, what date specifically, what data was discussed, and whether comparable briefings have continued through 2025-2026. Source: DemocracyDocket 2025
unverifieddatasetIRS 990 (FY 2020): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
3
Confirmed9Seven 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
1 piece of evidence ▸ ▾Finding Across FEC Schedule B 2019-01-01 through 2025-11-18, the 676 federal committees for which Thomas Datwyler is current treasurer-of-record routed $5,872,895 to two vendors: 9Seven Consulting (Hudson WI 54016 and Washington DC 20003) and AxCapital, LLC (Kansas City MO 64112). 370 of the 676 Datwyler committees (54.7%) paid one or both. 9Seven Consulting collected 81.1% of its ENTIRE FEC revenue ($3.16M of $3.89M) from Datwyler committees; AxCapital, LLC collected 77.5% ($2.44M of $3.14M). 97.4% of all dollars to these two vendors are coded as 'compliance consulting,' 'accounting,' or 'reporting' on Schedule B. 9Seven Consulting filed 430 disbursement receipts under zip code 54016-0183, which is the exact PO Box 183, Hudson WI 54016 publicly listed as Thomas Datwyler's own treasurer-of-record address. Inference 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.
corroboratingfilingFEC 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
4
ProbableZiklag to CPI to Compass Legal to Valid Vote (EagleAI host): the disclosed pipeline, plus Donors Trust $310,000 to Valid Vote (TY2023)
13 pieces of evidence ▸ ▾Finding Ziklag (USATransForm, EIN 824819179) discloses NO Schedule I grant to EagleAI, Valid Vote Inc (EIN 883506185), or the Election Integrity Network in any 990 filing 2018 through 2023. The only disclosed Ziklag grant to a node tied to the EagleAI operation is $600,000 to Conservative Partnership Institute (EIN 821470217) in 2022. CPI in turn discloses $706,069 to Compass Legal Group Inc and $813,590 to Compass Professional Inc in 2023, plus $1,089,729 to Compass Legal Services, $949,443 to Compass Professional Inc, and $550,000 to Compass Property Management in 2022. Compass Legal Group LLC is the Cleta Mitchell entity that incorporated Valid Vote Inc (Georgia, formed 2022). Valid Vote revenue scaled $61,014 (2022) to $454,508 (2023) to $823,176 (2024). financial_transactions_990_p contains one row Donors Trust Inc to Valid Vote, $310,000, tax year 2023. Election Integrity Network Inc (EIN 882166493) received $20,000 from CPI in 2023 and was rebranded on its 2024 IRS filing to Election Integrity Action Inc. Inference Ziklag chose to route 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 Exposes a direct gap between public IRS disclosures and operational funding streams: Ziklag's 990 Schedule I omits a substantial portion of documented project expenditures by routing funds through non-filing LLC intermediaries, creating an incomplete tax disclosure record.
corroboratingfilingZiklag/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
unverifieddatasetIRS 990 (FY 2024): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2024): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2023): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
5
ConfirmedOnly 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 ($240,756.89, 23 payments, 2024-02-14 to 2025-12-19, treasurer Lisa Lisker), the Senate Conservatives Fund ($22,342.23, 11 payments, treasurer Paul Kilgore), and Tim Sheehy for Montana ($8,236.75, 2 payments, treasurer Katie Wenetta); Johnson's caging spend escalated 47% year-over-year ($97,419.89 in 2024 to $143,337.00 in 2025) with the single largest disbursement, $23,162.25, posted 2025-11-04, one day before the off-year election.
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Operating address: 300 Independence Ave SE, fundraising → caging → voter-challenge loop.
The story
One address, one machine
300 Independence Ave SE is a vertically integrated hub. Compass Professional Inc. and Compass Legal Group are listed in IRS Schedule R as 'shared services' entities for CPI and America First Legal, the for-profit 'plumbing' (caging, accounting, legal compliance) of the movement. The Election Integrity Network, run by Cleta Mitchell, is housed in the same building.
The loop
The intake: Compass Professional receives 'undeliverable' mail from national fundraising pushes (e.g., the Mike Johnson Leadership Fund). The scrub: it records who moved or died to keep FEC filings clean. The hand-off: that 'moved' data sits a few desks from EagleAI. The weaponization: a returned fundraising letter becomes a 'verified' data point flagging an address for a voter-registration challenge.
A $23,162 spike in November 2025 at this address is the kind of disbursement consistent with running that data-sorting machine.
Other evidence
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Key players
Cleta Mitchell
Managing member, Compass Legal Group; chair, EIN
Beneficial owner of the legal arm and leader of the voter-challenge network, the link between the caging plumbing and the challenge database.
Mike Johnson Leadership Fund
Leadership PAC
Speaker Mike Johnson's fund; its national fundraising generates the returned-mail dataset Compass Professional processes.
Source documents · 2
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.
10Reportscorroborating2.9 KB · markdownretrieved Mar 14, 2026Compass Professionals - Caging - Mike Johnson
Three FEC committees, all 2024, paid Compass entities with the explicit purpose label 'CAGING'.
Read full document ▸Collapse ▾download raw .md ↗
300 Independence Ave SE is the "Patriot’s Row" hub, the nerve center for the Conservative Partnership Institute (CPI) and its massive constellation of entities.
While Lisa Lisker (the treasurer for the Mike Johnson Leadership Fund) often operates out of Alexandria, the Compass entities you are tracking are baked directly into the CPI infrastructure at that Independence Avenue address.
The Connection at 300 Independence Ave SE
This address isn't just an office building; it’s a vertically integrated political machine. Here is how the entities you mentioned stack up at that exact location:
- Compass Professional Inc. & Compass Legal Group: IRS filings (Schedule R) explicitly list both as "shared services" entities for CPI and America First Legal. They are for-profit arms designed to handle the "plumbing"—caging, accounting, and legal compliance—for the movement.
- The Election Integrity Network (EIN): Run by Cleta Mitchell, this is the project housed within CPI at this same address. Its primary goal is "mapping" the voter rolls and training citizens to challenge registrations.
- Mike Johnson Leadership Fund: By using Compass Professional for caging, the Speaker’s fund is essentially piping its donor data through the same physical and digital infrastructure that houses the EIN.
Why the "Returned Mailer" Theory Gains Weight Here
When you look at the $23,162 spike in November 2025 at this specific address, the "voter caging" theory becomes more than plausible—it looks like a built-in feature of the building’s ecosystem:
- The Intake: Compass Professional (at 300 Independence) receives the returned "undeliverable" mail from Mike Johnson’s massive national fundraising pushes.
- The Data Scrub: They record who moved or died to keep the Speaker's FEC filings clean.
- The "Integrity" Hand-off: Because Cleta Mitchell’s EIN is in the same building (and she is a beneficial owner of the legal arm), that "undeliverable" data is just a few desks away from the people building EagleAI or other voter-challenge databases.
- The Weaponization: A returned fundraising letter is a "verified" data point. If a donor's mail is returned to 300 Independence Ave, that address can be flagged in the EIN system as a "potential illegal registration" for a local activist to challenge.
The "One-Stop Shop" Strategy
By centralizing the Speaker’s money (caging) and the movement’s legal strategy (Mitchell) at 300 Independence, they’ve created a loop:
- Fundraising provides the names.
- Caging identifies who has moved.
- Election Integrity Network uses those "moves" to purge the rolls.
The high fees you are tracking are the cost of running that massive data-sorting machine. It’s not just "accounting"; it’s the administrative cost of identifying thousands of voters who can potentially be challenged before the next election.
10Reportscorroborating5.8 KB · markdownretrieved Mar 14, 2026FEC Expenditure Analysis 2023-2024
Aggregate FEC Schedule B analysis covering the 2023-2024 cycle.
Read full document ▸Collapse ▾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:
- Donors give to PACs (e.g., Trump 2024, RNC).
- PACs pay "dues" and "rent" to CPI (Nonprofit).
- PACs pay "consulting fees" to Compass Legal (For-profit).
- 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
Data Provenance & Pipeline Integrity