June 21, 2018
BY FAX: 202-224-7416
Honorable Johnny Isakson, Chair
Honorable Christopher A. Coons, Vice Chair
U.S. Senate Select Committee on Ethics
220 Senate Hart Office Building
Washington, D.C. 20510
RE:

Request for Investigation of Senator Mike Crapo (R-ID) for
Violations of the Ethics in Government Act and Senate Rule 34

Dear Chairman Isakson and Vice Chair Coons:
Campaign for Accountability (“CfA”) respectfully requests that the Senate Select Committee on
Ethics (“Senate Ethics Committee”) investigate whether Senator Mike Crapo (R-ID) violated the
Ethics in Government Act and Senate Rule 34 by willfully failing to disclose employer
information for his spouse, Susan Crapo, when he filed his Financial Disclosure Report for
Calendar Year 2017 with Secretary of the Senate on May 15, 2018.
Factual Background
Mike Crapo for U.S. Senate is the principal campaign committee for Senator Mike Crapo (R-ID).
Freedom Fund is a nonconnected committee and leadership PAC. Senator Mike Crapo is the
leadership PAC’s sponsor. Senator Crapo’s spouse, Susan Crapo, was employed throughout
calendar years 2015 and 2016 by both Mike Crapo for U.S. Senate and the Freedom Fund to
produce handmade gifts to be distributed to contributors at fundraising events for the two
political committees. In 2017, the two committees together paid Susan Crapo nearly $27,000 for
the donor gifts she had made during the prior election cycle. 1 Mike Crapo for U.S. Senate paid

1

Mike Crapo for U.S. Senate, FEC Form 3, 2017 April Quarterly Report, April 14, 2017, p. 68, available at
http://docquery.fec.gov/cgi-bin/paper_forms/C00330886/1160124/; Mike Crapo for U.S. Senate, FEC Form 3, 2017
October Quarterly Report, October 13, 2017, p. 62, available at http://docquery.fec.gov/cgibin/paper_forms/C00330886/1189458/; Freedom Fund, FEC Form 3X, 2017 12-Day Pre-Special Election Report,
Amended, August 2, 2017, p. 23, available at http://docquery.fec.gov/cgi-bin/forms/C00390674/1163130/; Freedom
Fund, FEC Form 3X, 2017 Year-End Report, January 31, 2018, p. 38, available at http://docquery.fec.gov/cgibin/forms/C00390674/1203325/.

611 Pennsylvania Ave., S.E. #337  Washington, D.C. 20003  (202) 780-5750
campaignforaccountability.org

 U.S. Senate Select Committee on Ethics
June 21, 2018
Page 2
Susan Crapo $20,581 during calendar year 2017 2 and the Freedom Fund paid her an additional
$6,276.3 According to the Idaho Statesman:
The money was for gift bags given to paying guests at the 2015 and 2016 Hook
'N' Bullet and Ski Fest fundraisers held near Sun Valley, Crapo's office told the
Statesman. “The items created and provided by Susan Crapo for the gift bags
during that time frame include homemade cinnamon bread; homemade raspberry
and strawberry jam; neck pillows; homemade salsa; fleece/fur blankets;
handcrafted semi-precious stone jewelry; pieced quilts; and homemade granola.” 4
Senator Crapo’s annual Hook ‘N’ Bullet fundraiser was the subject of an earlier Federal Election
Commission (“FEC”) enforcement proceeding in which the FEC found that the Freedom Fund
had failed to report nearly $45,000 worth of in-kind contributions and required the payment of a
civil penalty of $12,600.5
Despite reporting to the Federal Election Commission that both Mike Crapo for U.S. Senate and
the Freedom Fund had paid Susan Crapo during 2017, Senator Crapo failed to disclose that the
Freedom Fund employed Susan Crapo on his Personal Financial Disclosure Form for 2017. 6
This critical omission is all the more striking because Senator Crapo had disclosed Susan
Crapo’s employment by the Freedom Fund multiple times in previous years. 7
Violations
By failing to disclose the identity of Susan Crapo’s employer on his Personal Financial
Disclosure Report for 2017, Senator Crapo violated both the Ethics in Government Act of 1978
and Senate Rule 34.

2

Mike Crapo for U.S. Senate, FEC Form 3, 2017 April Quarterly Report, April 14, 2017, p. 68, available at
http://docquery.fec.gov/cgi-bin/paper_forms/C00330886/1160124/; Mike Crapo for U.S. Senate, FEC Form 3, 2017
October Quarterly Report, October 13, 2017, p. 62, available at http://docquery.fec.gov/cgibin/paper_forms/C00330886/1189458/.
3
Freedom Fund, FEC Form 3X, 2017 12-Day Pre-Special Election Report, Amended, August 2, 2017, p. 23, available
at http://docquery.fec.gov/cgi-bin/forms/C00390674/1163130/; Freedom Fund, FEC Form 3X, 2017 Year-End
Report, January 31, 2018, p. 38, available at http://docquery.fec.gov/cgi-bin/forms/C00390674/1203325/.
4
Cynthia Sewell, Idaho Statesman, $192,000 for his wife. 81 Uses of a lobbyist’s home. Crapo election funds draw
scrutiny, June 20, 2018, available at http://www.idahostatesman.com/news/politics-government/statepolitics/article212695139.html.
5
Federal Election Commission, MUR 7052 (Freedom Fund).
6
Sen. Michael D. Crapo, Personal Financial Disclosure Form for 2017, filed May 15, 2018, available at
https://efdsearch.senate.gov/search/view/annual/36aab264-fad2-4e13-a964-d31d5f7c6498/.
7
Sen. Michael D. Crapo, Personal Financial Disclosure Form for 2014, filed May 14, 2015, available at
https://efdsearch.senate.gov/search/view/annual/72784fa2-9d55-4b71-aa04-cbf7a674e024/; Sen. Michael D. Crapo,
Personal
Financial
Disclosure
Form
for
2013,
filed
May
15,
2014,
available
at
https://efdsearch.senate.gov/search/view/annual/29b23b92-074f-4d45-902e-e56da7294c4b/.

 U.S. Senate Select Committee on Ethics
June 21, 2018
Page 3
Ethics in Government Act and Senate Rule 34
Title I of the Ethics in Government Act of 1978, as amended, 5 U.S.C. app § 101 et seq., and
Senate Rule 34 both require Members of the Senate to file annual financial disclosure reports
with the Secretary of the Senate. These reports must include, inter alia, “the source of items of
earned income earned by a spouse from any person which exceed $1,000” during the preceding
calendar year. 5 U.S.C. app. § 102(e)(1)(A). The Financial Disclosure Instructions for Calendar
Year 2017 clearly informed Senator Crapo to “[r]eport the name and address of the source, type,
and the actual amount of non-investment and earned income aggregating $200 or more from any
one source. For your spouse, report the name and address of the source and type of income, but
not the amount.”8
It is unlawful for any person to knowingly and willfully fail to report any information that person
is required to report under the Ethics in Government Act. 5 U.S.C. app. § 104(a)(2)(A)(ii). Such
a violation of the Ethics in Government Act is punishable by a civil penalty of up to $50,000. 5
U.S.C. app. § 104(a)(1).
Conclusion
Senator Crapo clearly violated the Ethics in Government Act of 1978 and Senate Rule 34 by
failing to disclose that Susan Crapo was employed by his leadership PAC, the Freedom Fund,
during calendar year 2017. The Senate Ethics Committee should open an investigation and take
appropriate disciplinary action against Senator Crapo for violating Senate Rule 34. If the Senate
Ethics Committee determines that Senator Crapo’s omission of this information was knowing
and willful, the Committee should refer the matter to the Attorney General for further
appropriate action, including the imposition of an appropriate civil penalty.

Sincerely,

Daniel Stevens
Executive Director

8

U.S. Senate, Select Committee on Ethics, Financial Disclosure Instructions for Calendar Year 2017, page 12 (March
2018).