The NRSC-Mississippi Thing Smells Fishier And Fishier

UPDATE #2: The national media is beginning to report on this situation, but not in the manner that actually addresses it. Yahoo! News…

Cruz’s comments represented a sharp departure from his neutral posture in GOP primaries – in itself, an unusual approach to his duties as vice chairman of the National Republican Senatorial Committee. The committee works to reelect incumbent GOP senators.

Cruz’s comments Monday came as the state Republican Party certified the results of the runoff, showing that Cochran beat McDaniel by 7,667 votes. That margin is about 1,000 more than the initial vote count on election night.

And a little more…

For now, the right is immersing itself ever deeper into the McDaniel cause. And not just verbally, as with Cruz. The Washington-based Senate Conservatives Fund, a super political action committee, is raising funds to support McDaniel’s legal challenge. Other out-of-state tea party support groups are supporting McDaniel’s effort. And the civil war in Mississippi’s Republican Party rages on, with no end in sight.

Neither the Yahoo! piece, nor the Hill piece yesterday which sounds similar notes while casting Cruz as unruly and disloyal and quoting anonymous party hacks as discrediting his contribution to the cause, focus on what it is the NRSC and Cochran camp have done to cause this scrutiny in the first place.

UPDATE: You might notice below that the Thad Cochran web ad that was posted on Facebook is no longer available for view.

We’re not going to hazard a guess as to why. Make of this fact what you will. (update to the update: it appears the ad is back up, at least for us; your experience may differ)

While we’re on this subject, a couple of very interesting posts at by Ali Akbar are worth reading. The first involves a response by Henry Barbour, who is the nephew of Mississippi’s former governor Haley Barbour and an RNC committeeman from Mississippi, to Ed Martin of Missouri concerning the latter’s questions about just what kind of tactics were used in the Cochran race. Barbour was, shall we say, abrasive in the e-mail Akbar publishes. And the second was Martin’s retort – which was to call for RNC chairman Reince Priebus to institute an investigation of the Cochran campaign and present the findings to the RNC’s member meeting next month.

If you characterized this as a “burgeoning mess,” you would not be wrong.

Meanwhile, last night Mississippi certified the results of the GOP Senate primary runoff. Which isn’t going to make Chris McDaniel go away, or any of the questions about this disaster.

ORIGINAL POST: Last night we had a post about Ted Cruz’ appearance on Mark Levin’s show last night in which he called for an investigation into the tactics used by Thad Cochran to win the Mississippi GOP senate primary runoff last month.

Since then, we’ve done some digging, including talking with a contact at the National Republican Senatorial Committee and getting answers we didn’t understand. Here’s where things stand.

It is the NRSC’s position that they paid one of their vendors, National Media Research, Planning and Placement, $175,000 for work on Cochran’s behalf. Some $82,000 went toward production ($13,000) and placement ($69,000) of an ad campaign containing this web ad…

There was also a 15-second radio ad produced. The link to it is here.

Having had a series of conversations with political consultants of our acquaintance, we’re not quite sure this is on the level.

National Media also placed radio ads for something called “All Citizens For Mississippi” which were basically race-baiting Democrat-style spots on black radio stations, though NRSC says their money didn’t pay for those spots. The problem is that “All Citizens For Mississippi” hasn’t made any FEC disclosures since filing a Statement of Organization with the FEC on June 6.

They’re big-time out of compliance with FEC rules. To wit…

48-Hour Reports

Once an individual’s or committee’s aggregate independent expenditures during a calendar year reach or exceed $10,000 with respect to a given election at any time up to and including the 20th day before an election, a 48-hour independent expenditure report must be filed with and received by the Commission by the end of the second calendar day after the independent expenditure communication is publicly distributed or otherwise publicly disseminated. These reports must include all independent expenditures with respect to that election that have not been previously disclosed. Additional 48-hour reports are required for subsequent independent expenditures related to the same election that aggregate $10,000 or more through 20 days before the election. 11 CFR 104.4(b)(2), (e)(2)(ii) and (f)109.10(c).

A political committee must disclose an independent expenditure reported on a 48-hour report a second time: on a Schedule E [PDF] filed with its next regularly-scheduled report. The committee may note on theSchedule E [PDF] that the expenditure was previously reported. 11 CFR 104.3(b)(1)(vii).

24-Hour Reports

Once an individual’s or political committee’s aggregate independent expenditures reach or exceed $1,000 with respect to a given election, and are made fewer than 20 days, but more than 24 hours, before an election, the independent expenditure must be reported to, and received by, the FEC within 24 hours of the time the communication is publicly distributed or otherwise publicly disseminated. These reports must include all independent expenditures with respect to that election that have not been previously disclosed. 11 CFR 104.4(c), (e)(2)(ii) and (f)109.10(d).

A political committee must disclose a last-minute independent expenditure a second time on a Schedule E [PDF] filed with its next regularly scheduled report. The committee may note on the Schedule E [PDF] that the expenditure was previously reported. 11 CFR 104.3(b)(1)(vii).

The fact that All Citizens For Mississippi hasn’t made a disclosure, and used the same media buyer the FEC used, doesn’t look good. That has people saying it was NRSC money which made that media buy, and failure to disclose such would be not only pretty disgusting stuff for Republican voters to see but could open up a major legal problem as well.

The other piece to this is the $13,000 for production of what you see above and the $69,000 for placement. Of four political consultants we talked to, only one said he thought it was within the realm of legitimate possibility to spend $69,000 on a digital media buy in Mississippi in four days (but he did say that was a VERY high-end figure) – and he said the $13,000 number for production was so off the wall as to be suspicious.

When we brought that to the NRSC, they said they can’t itemize the ad buy because it was an independent expenditure and the rules against coordination get in the way of those kinds of disclosures, but they scoff at the suspicion our people expressed.

“A $20 CPM isn’t out of the ordinary,” was one of the things we were told.

If you don’t know anything about advertising, “CPM” means cost-per-thousand. As in impressions. In the digital advertising space, an impression would be recorded every time somebody pulls up a web page with your ad on it. Generally speaking, the more targeted your ads are, the higher the CPM rate will be. If you go through Google, let’s say, you can buy ads targeted to people who visit certain sites or kinds of sites, or who search particular keywords, and you can also target based on geography and other factors, and the further you narrow things down the more you might expect to pay for those impressions.

And $20 is an insane amount of money for a digital buy.

A consultant we’re friendly with told us this when we asked him about the $20 CPM statement…

It’s entirely feasible to spend a $20 CPM, but you’d be a moron to do or authorize that. But then again, this is politics and there’s a lot more $$$ than sense as it relates to digital marketing — and ESPECIALLY on the right.

A fully integrated campaign across various channels would have some high $$ ads (i.e. $12 CPM for the most premium ads possible on Facebook, maybe a little higher on some other networks). But no matter how you optimize (reach or hitting specific people), it’s pretty damn tough to get to $20 CPM, even accounting for profit.

To give you an idea, we run blended campaigns right now at a $5 CPM, and that’s a fair price when you account for management, maintenance, and creative work involved. By a blended campaign, I mean that the client gets some reach, the benefit of some behavioral targeting, and some other bells and whistles. Sometimes, additional requirements from a client pushes the price up to as much as a $10 CPM. But at $20, people would laugh at us and we’d be out of business. Maybe we need to get into politics. 😉

The consensus seems to be that one of two things is true.

Either the NRSC is an absolutely, gobsmackingly horrible steward of its donors’ money and it blows cash out to its vendors in so profligately wasteful as to explain how so many senatorial elections have inexplicably gone by the wayside – something which has been alleged many times in the past; or…

There’s a real problem here.

That All Citizens For Mississippi FEC disclosure had better come soon. If it doesn’t, people are going to start thinking there’s something major that would have to be in that disclosure they don’t want anybody to know about. And when the NRSC’s media buyer is making the buys for All Citizens For Mississippi – the address for which is the same address for the New Horizon Baptist Church in Jackson (which is Ronnie Crudup’s church, and Crudup has been the subject of a ton of scrutiny as this race has gone on, and not much of it good) – it gets more and more difficult to say there is no connection between the NRSC and those race-baiting ads on black radio.

Again – it’s entirely possible that there’s an innocent explanation for this. We would very much like to see that explanation. Hopefully we’ll get something we can update this post with.

Because it needs to be understood that we’re in an age where Dinesh D’Souza might very well go to jail for having moved $15,000 to a candidate using straw donors in a race where the outcome was never in doubt. In the past, violations like that would meet with a fine, but they want to put D’Souza in JAIL for it.

Dinesh D’Souza is certainly a stone in the Obama regime’s shoe, but he’s no particular threat to their governance.

The NRSC is trying to take away the Democrats’ control over the Senate, and most people think they will. Does anybody really think Eric Holder’s Department of Justice wouldn’t absolutely maximize the political effect of prosecuting the NRSC and/or the Thad Cochran campaign by announcing investigations and/or indictments immediately before the election? That’s how Ted Stevens lost to Mark Begich in Alaska, by the way – you don’t think the Obama administration wouldn’t use whatever problems with disclosures and/or coordination issues – or better yet, election fraud – as a cudgel against Cochran and the Republican Party?

This is rapidly becoming a mess. What Cochran has done is ring a bell that can’t be unrung. And he might well have dragged the NRSC into an untenable situation.

Ted Cruz is the NRSC’s Vice Chairman for grassroots outreach, and he’s calling for an investigation of Cochran’s campaign. This situation isn’t going away any time soon.

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