Erickson failed to disclose required information regarding $105,000,000 worth of assets
End Citizens United (ECU) today filed a complaint with the Department of Justice (DOJ) against Mike Erickson, Republican candidate for Congress in Oregon’s Sixth Congressional District. The complaint centers on Erickson’s failure to file complete and accurate personal financial disclosures in 2022 and 2024.
“Mike Erickson’s personal financial disclosure is riddled with blatant omissions that violate federal law and House Ethics rules,” said End Citizens United President Tiffany Muller. “Given the scope of the finances in question—which totals at least $105,000,000—this is one of the most egregious cases of intentional withholding of information we have ever seen. This is not a mere oversight; it’s a brazen and calculated move to keep voters in the dark, especially considering that he filed these same exact forms accurately in two of his previous runs for office.”
The complaint lays out four different areas of Erickson violating federal law and House Ethics rules: 1) Failure to disclose underlying assets, 2) Failure to disclose interests in several LLCs, a revocable trust, a luxury vineyard, and assets held by his spouse or dependent children, 3) Failure to disclose positions, and 4) Failure to disclose sources of compensation.
Muller added, “Voters deserve a transparent, detailed financial disclosure report in order to understand what Mike Erickson stands to gain from being in Congress and identify any conflicts of interest. Transparency is not optional––it’s a legal requirement. We urge the DOJ to immediately investigate Mike Erickson and hold him accountable for withholding this critical information.”
The complaint:
1) Mr. Erickson failed to disclose required information regarding at least $105,000,000 worth of assets on his 2022 PFD and 2024 PFD
- Federal law requires candidates to disclose all assets held for investment or the production of income by themselves, their spouse, or their dependent children which (1) are valued at more than $1,000 at the close of the reporting period or (2) generated more than $200 in income during the reporting period.
- When reporting investment accounts, it is not sufficient to simply disclose the name and aggregate value of the portfolio or account. Instead, filers must report on Schedule A “all underlying holdings (e.g., stocks, bonds, or mutual funds) in [brokerage-managed, 401(k), 403(b), IRA, and 529 accounts] that meet the value and/or unearned income thresholds.”
- Committee Instructions reiterate this requirement repeatedly, noting that filers “must provide information about the specific holdings of the account in the same detail” as assets that are not held in an investment account. That information includes the name and value of the underlying asset as well as the type and amount of income it generated.
- On Schedule A of his 2022 PFD and 2024 PFD, Mr. Erikson did not disclose the underlying assets of his 401(k) account, the underlying properties held in “Erickson Properties,” the names of the institutions holding his deposits, or information related to his Fishing Charter “business” or AFMS LLC.
- Rather than complying with the straightforward requirements in the law and Committee Instructions, Mr. Erickson provided—at best—a partially completed Schedule A that includes vague assets descriptions such as “401K” (without a list of the underlying holdings), “Erickson Properties” (without listing the underlying properties), and “Cash” (without the name of the financial institution). This is an obvious attempt to hide the exact information Mr. Erickson is required by law to disclose to the public.
- With respect to his retirement account – which he merely reports as “401K” – Mr. Erickson’s decision not to disclose the underlying assets worth up to $5,000,000 means that voters are kept from knowing what Mr. Erickson’s exact financial interests are and whether they could pose a conflict of interest should he be elected to Congress. The Act was specifically designed to provide the public with this type of transparency, and Mr. Erickson knows that. When Mr. Erickson ran for Congress in 2006 and 2008, he listed the underlying assets of his 401(k) account. The fact that Mr. Erickson knows about the requirement to list the underlying assets of his investment accounts – and even complied with it in the past – makes his violations of the Act even worse.
- Likewise, the public is currently being shielded from information about the specific properties that Mr. Erickson owns – including the value of those properties, where they are located, and the amount and type of income he’s received from them. This, again, is crucial information that the public has a right to know.
- Mr. Erickson likely has not disclosed all of the required information regarding a boat he reported owning with a value of up to $5 million. On his 2022 PFD, Mr. Erickson added a description of the boat, stating “Description: Fishing Charter business.” However, Mr. Erickson does not otherwise disclose the identity of the fishing charter business, its location, the type of income it has generated, or the amount of income it has generated. If Mr. Erickson has an ownership interest in the unknown fishing charter business, he’s required under the Act to provide that information.
- These errors, taken together, appear to have resulted in the improper or incomplete disclosure of at least $105,000,000 worth of assets on his 2022 PFD and 2024 PFD.
2) Mr. Erickson failed to disclose his interest in numerous LLCs, a revocable trust, and a vineyard, and as well as any assets held by his spouse or dependent children on his 2022 PFD and 2024 PFD.
- In addition to inadequately disclosing information related to numerous assets, Mr. Erickson also failed to list any information about i) various LLCs he owns or manages, ii) a trust of which he or his immediate family may have a vested beneficial interest; iii) a luxury vineyard he and his wife reportedly own; and iv) any interests held by his wife or dependent children.
- Public records also indicate that several LLCs are owned by a “Michael K. Erickson Revocable Trust.” This trust is listed nowhere on Mr. Erickson’s 2022 PFD or 2024 PFD. If Mr. Erickson, his spouse, or his dependent children have a vested beneficial interest in any assets held in the trust that exceed $1,000 or that generated more than $200 in income during the reporting period, he would be required to disclose those interests on his PFD.
- Next, it appears Mr. Erickson failed to report his ownership interest in a luxury vineyard. As an initial matter, Mr. Erickson did not report an ownership interest in Erickson Cellars Vineyard, LLC despite being the sole member of that entity in 2022 and 2024. Archived website content for “High Style Vacation Homes” details the Erickson Cellar Vineyards by noting it produces between 100-120 cases a year of “fine Pinot Noir.” That profile lists the vineyard owners as “Mike and Katie Erickson.” If he and his wife are, in fact, owners of the Erickson Cellar Vineyards, the vineyard should have been disclosed, along with the value of their interest in the vineyard and the amount and type of income it generated during the reporting periods.
- Finally, Mr. Erickson failed to list a single asset held by his wife or dependent children. As mentioned above, the Act requires Mr. Erickson to not only list assets he holds, but also assets held by his wife or dependent children. It would be highly unusual for the spouse and dependent children of a filer like Mr. Erickson to not have disclosable assets or income – especially here where public information suggests his wife has an ownership interest in a vineyard. If Mr. Erickson’s wife or dependent children held any reportable assets or unearned income, his failure to disclose them would also be a violation of the Act.
3) Despite appearing to hold multiple positions, Mr. Erickson did not disclose any “positions” on Schedule E of his 2022 PFD or 2024 PFD.
- Mr. Erickson should have disclosed all positions held from January 2020 – April 2022 on his 2022 PFD and all positions held from January 2022 – April 2024 on his 2024 PFD.
- Publicly available information indicates that Mr. Erickson has held numerous positions during these reporting periods – yet he failed to list a single position on either his 2022 PFD or his 2024 PFD.
- First, according to Mr. Erickson’s own campaign website and LinkedIn profile, Mr. Erickson is the current CEO and President of AFMS, LLC and has held those positions for over 30 years. Annual reports filed by AFMS, LLC with the Oregon Secretary of State also indicate he is a managing member of the entity. Despite holding these reportable positions, none of them are listed on Schedule E.
- Second, as indicated above, Mr. Erickson served as a managing member of multiple LLCs during the relevant reporting periods – including Erickson Properties II, LLC; Erickson Properties III, LLC; Erickson Properties IV, LLC; Erickson Vacation Homes II, LLC, and Erickson Cellars Vineyard, LLC. If these positions amounted to an officer or proprietor role with the LLCs, he was required to disclose them.
- Third, Mr. Erickson is listed on the Maurice Lucas Foundation website as a Community Board Member. Mr. Erickson boasted about this position in a tweet during his 2022 campaign, and his campaign website also states that he is a “current” Community Board Member of the foundation.
4) Mr. Erickson likely omitted numerous sources of compensation in excess of $5,000 on Schedule J.
- Filers must report on Schedule J the identity of each source that paid more than $5,000 for services personally performed by the filer during the two preceding calendar years. This reporting requirement specifically applies when the filer has an ownership interest in the employer (e.g., a partner of a firm). In other words, if a filer provided services to a client during the preceding two calendar years and that client paid the filer’s employer more than $5,000 for those services, the filer must disclose the client’s name and a description of the filer’s services if the filer has an ownership interest in the company providing the services.
- Mr. Erickson reports an ownership interest in AFMS, LLC on his 2022 PFD and 2024 PFD. According to AFMS’s website, AFMS has worked with “1000s” of clients, including Honda, Sony, Under Armour, Starbucks, John Deere, Dell, McKesson, Disney, Johnson & Johnson, Guess, American Eagle, Best Buy, Fred Meyer, Bose, and Toyota. In 2022, public reporting stated that Mr. Erickson says “he advises some of the world’s biggest brands including Starbucks, John Deere, and Under Armour.”
- If Mr. Erickson performed services for any of AFMS’s clients that resulted in $5,000 or more in fees to AFMS during the relevant reporting periods, he was required to list them on Schedule J. Instead, Mr. Erickson merely lists “AFMS, LLC.” This, again, blinds the public to information they have a right to know – here, Mr. Erickson’s clients whose financial ties to him may very well create conflicts of interest should Mr. Erickson be elected to Congress.
Click here to read the full complaint.
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