(The article first appeared in Broad + Liberty)

 

Bucks County has taken no action against two Falls Township supervisors concerning tens of thousands of campaign contributions they accepted from a labor union but failed to report, files show.

The apparent violations of campaign-finance law – too many to be isolated mistakes – are so sweeping they blemish the leadership of the Bucks County Board of Elections which oversees local campaign-finance enforcement. The board is led by Bob Harvie, a Democratic county commissioner who previously served as a Falls supervisor alongside the two men in question.

Federal records show that, since 2021, the International Brotherhood of Electrical Workers (IBEW) Political Action Committee donated $36,500 to Jeff Dence, one of five elected township supervisors, all Democrats. Dence, however, has not reported any of that money in his required campaign filings.

Similarly, since 2020, the IBEW donated $27,850 to township Supervisor Jeff Boraski. None of that was captured in local filings because Boraski disclosed none of it in a July 2020 report and has not submitted a single campaign filing since, despite his obligation to do so periodically.

The problem may run deeper.

Bucks County’s election office says it keeps campaign finance filings for five years. But because no reports before 2019 were preserved, it is therefore presently impossible to know how much more money Boraski or Dence may have failed to declare.

Federal campaign finance filings show the IBEW has donated a total of $82,850 to Boraski since he registered his committee in 2012. The union has donated $234,000 to the committees Dence has operated since 2009 – a tremendous sum considering his township’s population of only about 34,000.

 

Both Dence and Boraski are members of the IBEW Local 269 based directly across the Delaware River in Trenton, New Jersey, a union targeted in a multi-year probe by the Federal Bureau of Investigation.

The FBI has investigated accusations that Falls Township delayed issuing permits at the IBEW’s behest to pressure businesses into hiring union workers. In September 2022, Levittown Now reported that Harvie testified before the grand jury looking into the issue. IBEW PAC has given four- and sometimes five-figure sums to Harvie’s own committee most years going back to 2009, all of which he has reported. Harvie was a Falls supervisor (and sometimes board chairman) from 2008 to 2020 — serving with Dence and Boraski for most of that timespan.

Harvie currently chairs Bucks County’s three-member Board of Elections and has served on it as half of a Democratic majority for five years. During that time, the Board issued no letters to Boraski or Dence flagging unreported IBEW money, according to a Broad + Liberty review of Bucks’ compliance-letter files.

The county did send numerous letters to Boraski and Dence in 2019 and 2022 over failure to file reports on time, but it sent them nothing pertaining to unreported IBEW cash. While Boraski apparently stopped filing reports in 2020, the county has no record of mailing him compliance letters in 2021 or thereafter. (Election-office staff said compliance letters sent in 2020 do not remain on file.)

FEC records show Harvie and Dence once had a joint committee that received $9,000 from IBEW PAC in 2009. Neither Harvie nor his fellow Democratic County Commissioner Diane Ellis-Marseglia, nor Republican Commissioner Gene DiGirolamo responded to requests for comment.

(The IBEW PAC making the donations is a federal PAC that is national in scope. It gathers contributions from its many local affiliates and makes political contributions at the local, state, or federal level. IBEW Local 269 is a separate but affiliated organization and not solely responsible for the contributions mentioned in this article.)

County spokesman Jim O’Malley, addressing an inquiry sent to county Elections Director Tyler Burns, said the county examines potential problems with campaign-finance reports when it receives complaints about them.

“If and when a complaint is made, our Board of Elections office does look into these kinds of things,” he said.

Broad + Liberty originally reported on numerous compliance issues with both Boraski and Dence first in Sept. 2023, and then again in August 2024.

Dence’s Committees

IBEW PAC wasn’t the only campaign committee to give Boraski’s outfit money that he did not report; several of his former and current colleagues did too. Democratic Supervisor John Palmer’s committee gave $2,000 in October 2021, Friends of Jeffry Dence contributed $2,500 that November, and Friends of [former Democratic Supervisor] Jeff Rocco gave Boraski $1,000 in September as well as $900 in December of that year.

But while Boraski appears to have accepted donations from various funders and simply filed no reports, Dence’s handling of IBEW funds looks much more complicated.

While his current committee is called “Friends of Jeffry Dence,” the union instead reported contributing to “Friends of Jeff Dence,” a separate committee headquartered in the same locale but at a different address — and now closed.

Per a campaign-finance report the Bucks election office received on February 5, 2021, Dence terminated the committee. Available records do not show it was ever reopened.

A key question, then, is whether Dence continued to let IBEW PAC money flow into the same bank account once associated with his defunct committee or whether he received the funds into his current organization without declaring them. Neither Dence nor Rocco, who serves as Dence’s campaign treasurer, responded to an email asking about these matters.

All the while, because Boraski and Dence haven’t reported receiving federal IBEW money, they haven’t reported if or how it has been spent.

Philadelphia-based Republican election lawyer Matt Wolfe told Broad + Liberty that it’s a possibility that an entity like the IBEW could send a local candidate’s committee checks without noticing if the checks are being deposited or cashed, though he views that as “not likely.” Clerical error on IBEW’s part, he said, is also possible, though made “much less likely” when a candidate still has an operational committee as Dence does.

“Generally, even with clerical errors, it shows up in reports,” he said.

And while a clerical error will occasionally happen, Boraski and Dence’s omissions are so numerous as to cast doubt on that possibility.

Wolfe also explained that a local committee might hypothetically receive funds from a national outfit and specify that those checks be paid to a different political committee that is reporting the contributions, though that’s “not really the way you’re supposed to do it.”

Ultimately, he said, situations like Dence’s and Boraski’s tend to warrant investigation by legal authorities, usually the state attorney general’s office, though concerned parties could reasonably notify the Pennsylvania Department of State or the county Election Board as well.

“The whole system is predicated on transparency,” Wolfe said. “And it sounds like the IBEW is doing its job but clearly these players in [Falls Township,] Bucks County are thumbing their noses at the requirements of the law.”

Unexplained expenditures

To a lesser extent, other Falls supervisors’ campaign filings were also opaque. Numerous expenditures on reports submitted by Dence, Palmer, and their colleague Erin Mullen (D), another significant recipient of (properly reported) IBEW funds, fail to include a required description. The line provided for that purpose often read “Misc. Expense Reimbursement,” “campaign expense,” or just “expense.” In one case, Dence’s committee paid $224.28 to Rocco last March and left the description space blank.

Broad + Liberty filed voucher request forms to obtain copies of the receipts for all of the expenditures in question. While Dence, Palmer, and Mullen provided either receipts or check copies in every case, that often didn’t clarify the expenses’ purpose. Dence provided only check copies with phrases like “campaign expenses” and “expense reimbursement” written in the memo line. Dence’s check to Rocco said only “Campaign Reimbursement” in that space.

Dence also made campaign payments to himself, most of only about $300 or less, described vaguely as reimbursements. Mullen’s voucher-request responses provided more clarity, and none of her expenses appeared out of the ordinary — items like palm card printing, sign manufacture, design, and office equipment.

Still, Wolfe said, campaigns need to make sure they properly describe all payments on their campaign finance reports so any member of the public can easily discern their purposes.

“You need to be more descriptive than that,” he said.

Boraski, of course, has not described any expenditures — because he hasn’t reported any expenditures (or anything else) in over four years. Depending on whether he decides to run for re-election this year, the already substantial number of reports he apparently needs to file could grow even larger.

The supervisor has just entered the last year of his second six-year term. If he seeks reelection, he will need to submit nomination paperwork by mid-March.

Jeff Boraski, his wife and treasurer Dawn Boraski, and his former board colleague and campaign chairman Rocco all failed to respond to requests for comment. IBEW PAC also did not return an inquiry.

(Note: The $36,500 figure described as received and unreported by Dence does not include a $5,000 contribution IBEW PAC made in October 2021. While Dence reported that amount that autumn and did not correct it later, FEC records strangely indicate that payment was voided or returned.)