How unidentifiable donors are funding Montana’s anti-dark money initiative

The Montana-based group promoting a ballot initiative that would make campaign finance more transparent obscures its own financial backers with a murky fundraising structure, according to publicly available campaign finance filings reviewed by Montana Free Press.

The Transparent Election Initiative is a nonprofit organization pushing to “stop corporate and dark money cold” in elections. The group is currently aiming to pass a citizen’s initiative — known as The Montana Plan, or I-194 — that would prohibit political spending by “artificial persons” such as nonprofits, corporations, trusts, trade associations and others. The nonprofit is set up by former Montana Commissioner of Political Practices Jeff Mangan.

Until late April, nearly all of The Montana Plan’s hundreds of thousands of dollars in donations have come from the nonprofit — the Transparent Election Initiative — which does not have to disclose its donors.

“Dark money” refers to political funding from undisclosed sources that are often concealed by groups that are organized as tax-exempt 501©(4) nonprofit organizations. Such groups, commonly known as C4s, are defined for tax-code purposes as social welfare organizations. They can advocate for policy positions, and support or oppose candidates for office, as long as politics is not the organization’s primary purpose. The groups are not legally required to reveal the donors that provide their funding.

There is bipartisan concern about dark money based on the lack of public transparency about the identities and agendas funding messaging and campaigns.

“Dark money is creating a situation where individuals and organizations, perhaps corporations, are trying to influence elections and policy via spending, but the voters don’t know who is trying to influence them and can’t really make informed decisions without knowing who is trying to influence them and what their motivations are or what they may stand to gain financially from it,” Brendan Glavin, director of insights at OpenSecrets, a nonprofit that tracks the influence of money in politics, said in an email.

As organizers wrap up signature gathering aimed at qualifying I-194 for the November ballot, campaign finance reports show that the ballot initiative organization, The Montana Plan, is almost entirely funded and operated by the Transparent Election Initiative (TEI), a C4 run by the same people.

“The irony isn’t lost on me,” Mangan told MTFP.

Tom Moore, a Washington D.C.-based fellow with the Center for American Progress who helped develop the initiative and is working with Mangan said the two of them “joked at the beginning that we should’ve named it Montana’s Last C4” — a reference to the group’s goal to eliminate C4s’ involvement in campaign contributions.

The organization’s use of a C4 that almost entirely funds and operates the initiative campaign has raised the eyebrows of Montana’s current commissioner of political practices, Chris Gallus, who is questioning whether TEI is appropriately registered as what state campaign finance regulations refer to as an “incidental committee,” which does not have to disclose its donors.

Ballot issue committees — the classification of The Montana Plan — do have to publish donor information, such as full names and addresses.

I-194 has secured a number of high-profile endorsers including former Republican Gov. Marc Racicot, former Democratic Gov. Steve Bullock and former Democratic Sen. Jon Tester. Pete Buttigieg, the Biden administration’s transportation secretary and a possible 2028 Democratic presidential candidate, endorsed the Montana Plan and headlined an event promoting it in Butte last month. New York City Congresswoman Alexandria Ocasio-Cortez also endorsed The Montana Plan when she was stumping in Missoula for Western District U.S. House candidate Sam Forstag, who also endorsed the initiative and ultimately won the Democratic nomination in the race.

According to campaign finance filings, TEI is doing most of the organizing work for the ballot issue committee, The Montana Plan, and funneling cash donations to the group. The use of TEI to receive donations and do the work means the public can’t see where the ballot issue committee is getting its money. If donations were received directly by The Montana Plan, donor disclosure would be legally required.

Between the start of 2026 and late May, the ballot issue group had received $112,000 in cash from TEI.

TEI has also contributed nearly $60,000 in “in-kind” donations by securing legal services, space rentals, supplies and other expenses starting in July of last year.

Until late April, nearly all of The Montana Plan’s donations were coming through TEI, but that started to change in recent weeks. According to the most recent campaign finance filing, which spans late April through late May, The Montana Plan began receiving direct donations from more than 200 individuals that were not routed through TEI, and therefore were not concealed. During that same time frame, The Montana Plan was still receiving cash infusions from TEI to the tune of $70,200.

TEI does share limited information about donors on its website, where it provides donors’ first names and the first initial of their last name. Mangan pushed back against the suggestion that his anti-dark money initiative is itself funded by dark money, citing those partial disclosures.

“What we have spent has been fully disclosed in my mind,” Mangan said in a phone interview.”

By releasing incomplete donor names, Mangan told MTFP, The Montana Plan and TEI are conducting the campaign in a way that voters “should be applauding.” Asked why they don’t list donors’ last names, Mangan said organizers don’t want “somebody to scrape and use them in an untoward way.”

“Our goal is to balance transparency about our funding with protecting the privacy of individual supporters, especially since the overwhelming majority of contributions are small-dollar donations, which hardly supports any allegation that we are attempting to conceal our funding sources,” Mangan said in an email. “We do not believe it is responsible to publish full names and information online in a format that can easily be scraped or repurposed for solicitation, fundraising, or other unintended uses.”

Glavin pointed out that while most C4s don’t release even partial donor information, there is still a meaningful difference between TEI’s strategy and legally required disclosure.

“You’re forced to take them at their word on it,” Glavin said. “There’s nobody looking over their shoulder like with the [Federal Election Commission], say.”

Both the Federal Election Commission and the Montana Commissioner of Political Practices have the authority to levy punishments against groups that don’t fully disclose donors they are required to publish.

Qualifying a statutory or constitutional initiative for the ballot is a multi-step process that includes getting approval from the state to gather signatures. Mangan explained that he did not feel comfortable asking for donations to The Montana Plan until the organization had successfully secured that approval. Instead, he explained, he solicited donations through the C4, TEI, in part because that group has more flexibility to spend its money on similar efforts — such as in other states — in case the Montana initiative did not qualify.

“There’s no way ethically I would raise funds for the ballot issue if there’s not a ballot issue in place,” Mangan said.

But other groups working to get initiatives before voters later this year have consistently routed their donations through the ballot committees, both before and after the state cleared the initiatives to start signature gathering. That means the public can see the individuals and organizations donating to those initiatives.

After receiving inquiries from MTFP about the I-194 campaign’s funding structure, Gallus told MTFP he inquired with Mangan, his predecessor, about the group’s operations. In a letter dated May 21, Gallus asked Mangan for more information to help determine if TEI’s classification as an incidental committee (which does not have to disclose its donors) is “appropriate.” Mangan has until July 10 to respond.

“Given the special treatment [C4s] receive, I have a duty to inquire about it from time to time when I receive information that causes me to at least be a little curious about it,” Gallus said in a May phone interview with MTFP.

If Gallus determines that TEI must reclassify as a different type of committee, the group may have to retroactively publish its donors, explained Scott Cook, a compliance specialist with the Montana Commissioner of Political Practices’ office.

Mangan said he’s “confident” that TEI is properly registered as an incidental committee, and that he plans to answer all of Gallus’ questions.

Mangan said in a Thursday phone interview that organizers have collected more than the necessary 30,100 signatures needed to put the initiative on November ballots. The signatures still need to be certified by the Montana secretary of state to officially qualify.