Roy Moore suffered a historic defeat in Alabama, but it’s unclear whether a political action committee that formed to help his campaign will carry on the fight — and continue to do it in mysterious ways.

On Dec. 1, I published an article about the newly-formed Club for Conservatives PAC and a confusing web of fundraising screeds, mailing addresses, URLs and a mysterious treasurer who doesn’t appear to have an online profile despite averaging over 1,000 words in each request for money. Treasurer Brooke Pendley and other members of the Pendley family did not return emails, phone calls and Twitter messages when contacted for clarity about the group.

The plot has since thickened.

Club for Conservatives sent out at least four more fundraising emails with the subject lines:

• The RINOS have egg on their face (Dec. 5)
• BREAKING: Sen. Jeff FLAKE switches parties (Dec. 6)
• Trump: “VOTE ROY MOORE!” (Dec. 8)
• TRUMP: If you see Gloria Allred, you know something’s wrong (Dec. 10)

Pendley had signed all emails from Nov. 13 to Dec. 1, but the Dec. 5 and 6 emails were signed by “Club for Conservatives, National Office.” Pendley returned to sign the Dec. 8 and 10 emails (although without a photo). 

New domain, same story

Tracking down the Club for Conservatives has become even trickier as details surrounding the group change.

For example, the initial 10 emails went out from info@supportroymoore.com, but three of the four most recent messages came from info@standwithjudgemoore.com. That domain was registered on Dec. 1 through GoDaddy, although the registrant’s information is masked and the URL points to supportroymoore.com (and the original landing page).

A Dec. 7 email (“God says Jerusalem is Israel’s Capital!”) from Solution Fund PAC also went out with the info@standwithjudgemoore.com email address.

The Dec. 10 Club for Conservatives PAC email came from info@kaydaly.com. As the initial story explained, there are connections between North Carolina attorney Nate Pendley and conservative activists Jack and Kay Daly.

For example, Nate and Betty Pendley each contributed $2,700 to Kay Daly’s congressional campaign on March 31, 2016. Nate and Jack worked together for GOP Rep. Thaddeus McCotter of Michigan.

New FEC filing, more questions

A new filing by Club for Conservatives PAC with the Federal Election Commission brings minimal clarity to the group’s whereabouts and treasurer.

Club for Conservatives PAC listed a Lexington, Kentucky, address on its Oct. 17 statement of organization, but the group is not a client of the co-working space at that location.

The PAC filed a Form 99 Misc. Report to the FEC on Dec. 7 listing the same Charlottesville, Virginia, address that appeared at the bottom of some of the initial fundraising emails. That Charlottesville address turns out to be for Mailbox Express, located in a strip mall, where customers can register a regular PO Box or virtual mailbox. The most recent handful of fundraising emails didn’t include a mailing address or contact information at the bottom.

Club for Conservatives PAC was initially organized with the FEC by “Ms. Brooke Pendley,” which looked to be a version of Alexa Brooke Pendley, one of Nate Pendley’s daughters, even though the headshot on the initial fundraising emails looked like a different daughter. But the recent FEC report (which announced it would operate as a hybrid PAC) was filed by Alexa Brooke Pendley.

As the initial story explained, Alexa Brooke registered to vote as a Republican in Forsyth County in Oct. 2015 with the same Clemmons address as Nate and Betty Pendley, according to the North Carolina State Board of Elections & Ethics Enforcement website. Alexa Brooke voted in the 2016 elections, but there isn’t a record of her making a political contribution on the FEC website, and evidence of other political involvement is hard to find.

What now?

The FEC does not comment on individual committees or circumstances. But according to one campaign finance source, filing a FEC report with a different address and slightly different name for the treasurer is an unusual practice for a committee.

The FEC can’t act until or unless a formal complaint is filed. (So far, there has been none.) Then, the commissioners would decide whether to investigate through an inquiry. The FEC could decide to conduct a for-cause audit, but since Club for Conservatives PAC is less than three months old, it hasn’t had to file a quarterly report yet, and there hasn’t been time to miss a deadline or raise copious amounts of money that might increase awareness and suspicion.

The committee’s end-of-year report, filed in January, could bring clarity to the group’s founder and mission. But without a specific political opponent, it’s possible that no complaint is filed at all.

The penalty for not having a legitimate treasurer is unclear, considering current and former FEC sources can’t remember a comparative case from the past. But the bottom line is the treasurer is authorized to raise and spend money for the PAC, and if that person isn’t legitimate, then the group is fraudulently raising money and subject to penalties.