End Citizens United (ECU) today filed a complaint with the Department of Justice (DOJ) against Matt Gunderson, Republican candidate for California’s 49th Congressional District. The complaint centers on Gunderson’s failure to file complete and accurate personal financial disclosures in 2023 and 2024. This has resulted in Gunderson failing to disclose up to $60 million worth of underlying assets, while simultaneously self-funding his campaign with more than $2 million.
“Matt Gunderson’s personal financial disclosures are a giant red flag that should alarm voters with just a week from Election Day,” said End Citizens United President Tiffany Muller. “By failing to properly disclose his financial assets, he’s denying voters from being able to identify any conflicts of interests or see what he stands to gain from being in Congress. This isn’t just a case of oversight; it’s a deliberate move to hide important information from the public, which is particularly troubling given that he’s self-funding his campaign. We call on the Department of Justice to immediately launch an investigation and hold Gunderson accountable for this egregious violation.”
The Complaint:
- Mr. Gunderson appears to have failed to disclose up to $60 million worth of underlying assets related to three of his investments—GSM Development, NGS Properties and NGS Properties II—from both his 2023 PFD and 2024 PFD.
- According to state business records, all three of these companies are limited liability companies, which Mr. Gunderson describes on his PFD as “real estate holding” companies.
- Further, Mr. Gunderson appears to have failed to disclose an interest in GSM Rental Group, LLC on his 2023 PFD and potentially his 2024 PFD, too.
- In 2022, Mr. Gunderson ran for state Senate in California. In that election, he filed a statement of economic interest, wherein he reported holding an up to a $1 million interest in GSM Rental Group, LLC as of April 22, 2022. According to California business records, GSM Rental Group, LLC is an “active” business in the state, and Mr. Gunderson is currently listed as the “agent” for the business. Despite this, GSM Rental Group, LLC is nowhere to be found on Mr. Gunderson’s 2023 PFD or his 2024 PFD.
- Federal law requires House candidates to disclose their ownership interests in real property, including “[t]he identity and category of value of any interest in property held during the preceding calendar year in a trade or business, or for investment or the production of income, which has a fair market value which exceeds $1,000 as of the close of the preceding calendar year.” This information should be reported on Schedule A of a candidate’s PFD.
- Instructions provided by the House Committee on Ethics (the “Committee Instructions”) explain that if a filer holds an interest in a privately held company that was established for the purpose of holding investments (including real property investments), it’s not enough to simply disclose the identity of the privately held company. Instead, the filer must disclose each of the company’s underlying assets in which the filer’s interest (or that of their spouse or dependent child) had a value of more than $1,000 at the end of the reporting period or that produced more than $200 in rental income. For each asset that meets the reporting threshold, the filer must list the name of the asset; a description, including the location (if applicable); the value of the interest; and the amount and type of income it generated during the reporting period.
- Despite this clear law and guidance, Mr. Gunderson appears to have failed to disclose millions of dollars’ worth of underlying assets. Mr. Gunderson’s 2023 and 2024 PFDs indicate that Mr. Gunderson has ownership interests in three limited liability companies which seem to exist for the purpose of “holding” real estate investments. Per the Committee Instructions, Mr. Gunderson should have provided a description of each individual property held by GSM Development, NGS Properties and NGS Properties II in which his interest (or that of his spouse or dependent children) exceeded $1,000 or which produced more than $200 in income. By failing to do so, Mr. Gunderson has denied voters access to crucial information related to up to $60 million of his assets.
- Additionally, the law instructs that Mr. Gunderson should have included GSM Rental Group, LLC as an asset on Schedule A of the 2023 PFD and the 2024 PFD if he had an interest of over $1,000 in the business at the close of either of the applicable reporting periods or the business generated more than $200 in rental income during those years. The facts here strongly suggest Mr. Gunderson should have disclosed an interest in GSM Rental Group, LLC on both PFDs. Mr. Gunderson was within the reporting period for the 2023 PFD at the time he reported his up to $1 million interest in GSM Rental Group, LLC to the state of California (in April 2022). In fact, it seems probable that Mr. Gunderson still retains his ownership interest in GSM Rental Group, LLC, as he is currently listed as an “agent” for the business, as described above. Since the reporting period for the 2024 PFD ended in August 2024, he was likely required to include the asset on that report, as well. This appears to be yet another multi-year reporting failure by Mr. Gunderson.
Click here to read the full complaint.
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