Hillary Clinton has sent $150,000 in leftover funds from her presidential campaign committee to a limited liability company that was established to manage her book and speaking income, filings show.
Clinton registered ZFS Holdings LLC, a Delaware-based LLC, on Feb. 8, 2013, just days after leaving the State Department, records filed with the Delaware Division of Corporations show. Later, in April 2014, paperwork was filed with New York State's Department of State.
ZFS's listed agent on its Delaware forms is the Corporation Trust Company, a wholly owned subsidiary of Wolters Kluwer, a Netherlands-based global company that provides services to legal, business, tax, accounting, finance, audit, risk, compliance, and healthcare clients.
Clinton's LLC was established to manage her income, a spokesperson acknowledged during the 2016 presidential campaign.
"ZFS was set up when Secretary Clinton left the State Department as an entity to manage her book and speaking income," the Clinton spokesperson told the Guardian in April 2016. "No federal, state, or local taxes were saved by the Clintons as a result of this structure."
Payments from Hillary for America, Clinton's former campaign committee, to ZFS began well after the election was over.
The first transaction from the committee to ZFS was made on May 4, 2017 in the amount of $32,929.28, nearly six months after Trump had defeated Clinton. Each payment from the committee to ZFS was marked as "rent."
Seven additional payments were made ranging from $9,617.87 to $36,369.39. The most recent payment to ZFS, for $20,822.92, was made on March 15, filings show.
The campaign has pushed $149,456.78 to ZFS Holdings since early May of last year.
Once a campaign has concluded, politicians are not required to shut down their committees and can keep them running indefinitely, as the Center for Responsive Politics notes of unused campaign cash.
"Sometimes they do this to pay off campaign debt, or, to keep their war chest full if they were to ever seek office again," they write. "After paying down any debts, money is often spent to ‘wind down' the committee and pay off any office expenses."
"For those who still have cash on hand, the FEC sets guidelines regarding how candidates’ committees may spend campaign funds," they continue. "Other than the prohibition on personal use, there are few limitations. Punishments for violating the prohibition on personal use range from substantial fines to possible prison time."
Former politicians and candidates may use unused funds for the likes of donating money to a recognized charity, contributing to the campaign committees of other politicians, giving to a federal, state, or local party activity, or disbursements for winding down costs.
"The only disbursements allowed for the Clinton or any other losing campaign are for winding down the campaign," Cleta Mitchell, a partner in the Washington, D.C. office of Foley & Lardner LLP, told the Washington Free Beacon. "So the question is whether this is really for rent or whether the payments are to this entity for other types of work for Hillary, which would be personal use if it isn’t specifically tied to the winding down of the campaign."
"Personal use is illegal under federal campaign finance law," Mitchell said. "There are a number of questions that need to be answered to ensure that the campaign is using leftover campaign funds for a legally, permissible purpose."
The rent payments were directed to Clinton's LLC despite the campaign making no such payments—or any other payments—to the entity throughout the entirety of the 2016 election cycle, according to filings.
Jose Villareal, Clinton's campaign treasurer, did not return a request for comment.
Clinton has also sent hundreds of thousands in leftover campaign cash to her "resistance" group, Onward Together, which was formed in May 2017.
Clinton's campaign made an $800,000 contribution to the group in early May of last year, the Free Beacon previously discovered. The donation occurred on May 1, 2017: three days before the "rent" payments were first disbursed to ZFS Holdings.
UPDATE 5:25 P.M.: Following publication, Merrill said: "During the campaign the office was a campaign office. After the campaign, the office served as a personal office, a campaign wind-down office, and an office for Onward Together, so rent is split up accordingly."