political action committee (PAC) is an organization that pools campaign contributions from members and donates those funds to campaign for or against candidates, ballot initiatives, or legislation by, for example, making and buying campaign ads. 

A super PAC, officially known as an “independent-expenditure only committee,” may not make contributions to candidate campaigns or parties, but may engage in unlimited political spending independently of the campaigns. Unlike traditional PACs, super PACs can raise funds from individuals, corporations, unions, and other groups without any legal limit on donation size.


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Senator Ted Cruz (R-Texas) has four super PACs to raise money for his presidential campaign, which raked in a total of $37.8 million as of July 31, 2015 — a significant haul that puts Cruz in the top fundraising tier. The bulk of the money comes from just seven individual donors. Cruz’s four super PACs are:

  1. Keep The Promise I: $11 million; funded almost entirely by New York hedge fund magnate Robert Mercer.
  2. Keep the Promise II: a single $10 million donation from Toby Neugebauer, a Puerto Rico-based investor who is the son of Texas GOP Rep. Randy Neugebauer.
  3. Keep the Promise III: $15 million — all from Texas billionaire brothers, Farris and Dan Wilks, who made their fortunes in fracking, and their wives, JoAnn and Staci.
  4. Keep the Promise PAC: $1.8 million, nearly all from Texas-based donors, including Robert McNair, Sr., the chairman and CEO of the Houston Texans football franchise.

Politico reports that, as of July 31, 2015, super PAC Keep the Promise I had spent the most, shelling out $536,000. But what is most curious is that$500,000 of that was spent not for Ted Cruz, but to promote his fellow Republican and supposed rival Carly Fiorina’s presidential ambitions.

SM Gibson reports for Anti-Media, Sept. 28, 2015, a super PAC associated with Fiorina, CARLY for America Super PAC, has raised almost $3.5 million to date. 

Note: The super PAC was originally named Carly for America. In June 2015, the FEC forced it to change its name because the original name was in violation of its rules, which state that super PACs cannot use a candidate’s name because they are supposed to be “independent.” So Carly for America changed its name to CARLY (an acronym for Conservative Authentic Responsive Leadership for You) for America Super PAC.

What is curious is that among the hundreds of contributions pledged to CARLY for America, one is for $500,000, made on June 18, by the Cruz-affiliated Keep The Promise I super PAC, as shown in the latter’s itemized disbursements (see below).

Ted Cruz Super PAC disimbursements

Why would anyone seeking the presidential nomination for the Republican party donate such a large sum to a competitor? 

Even stranger, the large sum was donated to Fiorina on June 18 — when she was still a relatively unknown candidate and polling at 0%, according to a Washington Post–ABC News poll. It wasn’t until August 6 — when Fiorina performed well in the first GOP lower candidate debate — that she was on anyone’s political radar nationally.

The only explanation given by Keep The Promise I for its $500,000 “disbursement” or donation to CARLY for America is “other disbursement,” which of course is not an explanation.

That has prompted the Federal Election Commission (FEC) to send a letter to Keep The Promise I treasurer Jacquelyn James, dated Sept. 16, 2015, asking for “a brief statement or description of why” the $500,000 disbursement was made.  The letter warns that “Failure to adequately respond by (October 21) could result in an audit or enforcement action.”

So when you see TV ads touting Fiorina, they really should carry this inscription:

Carly Fiorina

See also “Republican Sen. Ted Cruz announces presidential campaign, but is he eligible?” and “Is Ted Cruz an advocate of a North American Union?“.

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Dr. Eowyn’s post first appeared at Fellowship of the Minds.