CNN
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Nevada Republican Senate candidate Sam Brown created a political action committee to “help elect Republicans” but most of its funds were spent paying down debt from his failed previous campaign. The group donated less than 7% of its funds to the candidates it was set up to support, according to campaign finance records – a move one campaign finance expert likened to using the PAC as a “slush fund.”

Brown formed the Duty First PAC in July 2022, saying the organization would help Republicans take back Congress. A month earlier, Brown lost the Republican Senate primary to Adam Laxalt after raising an impressive $4.4 million for his upstart campaign, but his campaign was left with more than $300,000 in debt.

Now Brown is running again in Nevada as a top recruit of Senate Republicans.

A former Army captain, Brown made lofty promises when launching his PAC, Duty First.

“With your support, we will: Defeat the socialist Democrats. Help elect Republicans who believe in accountability to the Constitution and service to the people. Stand with the #DutyFirst movement, chip in with a grassroots contribution today,” he said in a tweet announcing the PAC.

“We’ll ensure that the socialist agenda of the Democrats does not win in November, and the Republicans continue to be held accountable to defending our Constitution and defending our conservative principles. The country’s counting on us,” Brown said in an accompanying video for the PAC’s launch in July 2022.

Since then, the PAC raised a small amount – just $91,500 – and used the majority of their money – $55,000 – to repay debt from Brown’s failed campaign for Senate, which Brown had transferred over. Campaign finance experts told CNN this falls into a legal gray area.

Of the $90,000 spent so far, just $6,000 made its way to five Nevadan Republican candidates’ committees. An additional payment for $1,000 was listed as going directly to congressional candidate Mark Robertson as a contribution but lists the amount as being directly paid to the candidate at his home – not to his committee.

Instead, the Duty First PAC made over a dozen debt payments. A combined $23,000 was spent on website and software services used by Brown’s Senate campaign. Another $11,275 went towards paying down the failed campaign’s credit card, with an additional $3,000 spent on credit card interest fees.

Duty First paid off over $1,200 in credit card debt accrued at a country club near where Brown previously lived in Dallas, Texas, and ran for the state house in 2014. A spokesman for the Brown campaign said in an email to CNN the “facility fee” charges were for a fundraiser “hosted by supporters of Sam’s campaign.”

The most recent FEC filing shows Brown is now trying to dispute over $80,000 in remaining debt from the previous campaign, which the spokesman said “will be resolved in due course.” A majority of the disputed debt owed is for direct mail services used by Brown’s previous campaign.

Duty First PAC is also responsible for eventually repaying Brown $70,000 that he personally loaned his committees.

The spokesperson for Brown’s campaign defended the PAC’s spending.

“The PAC promised to support conservative candidates in Nevada, and it did exactly that by donating to every Republican candidate in Nevada’s federal races during the 2022 general election,” they said.

According to a CNN analysis of Duty First PAC’s FEC filings, of all the money raised, less than 7% went to candidates. When considering Brown’s personal loans, debt the PAC took on from Brown’s campaign, and expenditures, fewer than 2% of the PAC’s funds went towards candidates in 2022

The money not spent on debt went to a variety of consulting and digital marketing expenses. The PAC spent $1,090 on a storage unit, more than it donated to the winning campaign of Republican Rep. Mark Amodei.

Despite this, Brown played up his PAC’s donations to candidates in interviews and in posts on social media.

“I have pledged to help defeat the Democrats in Nevada,” he added in an email, announcing the launch of the PAC.

The PAC’s donations were from grassroots donors, who typically donated $50 or less.

Just a day before the 2022 midterm election, Brown announced donations to several candidates running for office in Nevada.

Records with the FEC show the 2022 donations to House candidates were made on October 31, while the donation to Laxalt’s Senate campaign was made in early September.

“The Duty First PAC proudly supports conservatives fighting for Nevada,” he said in a tweet after making the donations on November 7, 2022. “This past week, we donated funds to the four Republicans working to take back the House. Join us in supporting them right now!”

Later, following the 2022 midterms in a late November interview on a local Nevada radio station, Brown played up the PAC’s work and said it would continue to work between election cycles.

“Duty First is here to kind of work between the cycles, so to speak and help candidates who are running,” Brown said. “In fact this cycle, you know, we had raised money and supported all of our Republican federal candidates, Adam Laxalt, as well as the four Congressionals.”

“And so, it’s our way of pushing back against the Democrat agenda and their representation,” Brown said. “But, also, it gives Duty First supporters and people that believe in our mission, a sort of platform to remind Republicans what we’re about.”

Campaign finance experts CNN spoke to said Brown marketing the Duty First PAC as a way for people to financially support conservative candidates was a “creative way” for Brown to pay off old campaign debts behind the scenes.

“It creates a situation where contributors to a PAC may think that PAC is doing one thing, which is supporting political candidates, when in fact what it’s doing is being used to pay off long standing debts from a previous campaign,” said Stephen Spaulding, vice president of policy at Common Cause and former advisor to an FEC commissioner.

Since the FEC has not issued an advisory opinion that would “apply to that candidate and any other candidate that has a very similar situation,” Spaulding said transferring debts between campaign committees and PACs is a gray area in campaign finance law. In Brown’s case, his candidate committee was rolled into a PAC, Sam Brown PAC, that was associated with his candidacy, which the campaign finance experts agree is a common maneuver for candidates. But what struck the experts as odd was that Brown terminated the Sam Brown PAC, and transferred his outstanding loans and debts to the Duty First PAC.

Brown’s 2024 candidate committee, Sam Brown for Nevada, is an entirely new committee with its own FEC filings, despite having the same name as his previous committee. This committee, formed in July 2023, is not affiliated with the Duty First PAC, nor is it obligated to pay off the remaining $271,000 in previous campaign debt and loans.

“Unfortunately, Sam Brown, like too many other politicians, has given almost no money to other candidates and, instead, has used his PAC as a slush fund,” said Paul S. Ryan, executive director at Funders’ Committee for Civic Participation. “Many donors would understandably be upset if they learned their money wasn’t used to help elect other candidates like Brown – the reason they made their contributions,” he added.