By Adam Pagnucco.

Council Member Will Jawando is using public financing to run for county executive.  Participants in public financing agree to accept contributions from individuals of up to $500 per cycle in return for public matching funds available for contributions from county residents.  They also agree to not accept contributions from corporations, unions, most other campaign committees and any other organizations in return for taxpayer support.  These rules have been in place since 2018, when MoCo first used public financing for elections.

Now a media outlet is alleging that Jawando skirted these rules by tapping money from a preexisting traditional account to supplement his publicly financed campaign.  Are these allegations correct?  And if they are, is Jawando following the law?

Maryland Bay News, part of Mike Phillips Media, broke the story that Jawando had raised and spent money from his traditional campaign account in the months before opening a public financing account to run for county executive.  Jawando used traditional financing to run for his second term on the county council in the 2022 cycle and, as of this writing, has not closed the account.  Maryland Bay News wrote about the spending of both accounts in this cycle.  After describing Jawando’s fundraising in public financing, the outlet wrote:

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The traditional committee, meanwhile, raised $48,932 in a single month — March 2025 — including five contributions of the $6,000 legal maximum. Among the max-out donors: a construction company executive, a Sullivan & Cromwell attorney, and a Houston-based sales executive.

That money was spent almost immediately. By early April 2025, the traditional committee had paid $13,000 to a research firm and $21,824 to a digital media company. Then it went largely dormant — until its vendor payments created questions about the PEF committee that came later.

Over the full course of the race, the traditional committee has spent $409,598. The PEF committee has spent $169,314. By that measure, the legacy big-money operation has outspent the public financing campaign by more than two to one.

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This account is partially wrong and partially correct.  It’s true that the traditional committee (started in 2020) has recorded expenditures of $409,598.64 throughout its existence.  $363,399.94 of that total was spent in the 2022 cycle, when Jawando had no public financing account and was therefore not bound by the requirements of that program.  (The outlet incorrectly stated that Jawando ran for governor; he actually ran for reelection to the council.)  However, the traditional account did spend $46,198.70 in the current cycle, including $38,638.73 in 2025.

That money is worthy of discussion.

Back in January, Jawando’s traditional account filed its most recent report.  From 1/9/25 through 1/14/26, that account raised $48,932 in contributions and spent $38,639.

The contributions were raised from March 1 through March 31.  Seven of them were maximum contributions allowed under state law ($6,000).  Four more were $1,000 or more.  No contributions of this size would have been allowed under public financing.

The expenditures were made to a group of vendors from March 30 through April 28.  Their purposes included media (online advertising), media (consulting fees), other expenses (online advertising), other expenses (legal fee/compliance/administrative), other expenses (bank charges) and other expenses (other).  The screenshot below shows who received the payments.

The full report can be downloaded at the link below.

Jawando Traditional Account Report 2026 Annual

Jawando established his public financing account on May 2, 2025 – just four days after his last expenditure from his traditional financing account.  There is no evidence that the two accounts were spending money at the same time, which would have been a clear violation of the public financing law.

Is the above conduct legal?

Sec. 16-24 of the county’s public financing law states:

(a) Except as provided in Section 16-27, a participating candidate may use the eligible contributions and the matching public contribution for a primary or general election only for expenses incurred for the election. A participating candidate must not pay in advance for goods and services to be used after certification with non-qualifying contributions received before applying for certification unless the expenditure is permitted by Executive regulation adopted under Section 16-21.

Because participating candidates “must not pay in advance for goods and services,” Jawando’s traditional account spending merits examination.  However, there is a big caveat: the executive regulation cited above permits some spending in advance.  The Summary Guide for Montgomery County’s Public Election Fund comments on what is allowed and what is not:

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Assets that the candidate has paid for and received prior to filing their notice of intent to participate in the Program can be used but only in a limited capacity. Otherwise, pre-purchasing by a non-public financing committee for campaign materials or items is prohibited.

Example 1: On March 1, 2025, Candidate A contracts with a bus manufacturer to build a custom campaign bus and pays $100,000 in full for the bus to be built and delivered on July 1, 2025. On April 1, 2025, Candidate A files a notice of intent to participate in the Public Election Fund with the State Board. On July 1, 2025, upon receipt of the pre-paid campaign bus, Candidate A would be in violation of the Public Election Fund regulations which prohibit the advanced purchase of goods and services with ineligible contributions received outside of the Program.

Example 2: On March 1, 2025, Candidate B contracts with a web developer to create a campaign website for the cost of $10,000 and pays in full at the time. On March 21, 2025, the website is completed with an ongoing monthly fee of $99, which began on March 21, 2025. On April 21, 2025, Candidate B files their notice of intent to participate in the Public Election Fund with the State Board. Upon filing this notice of intent, Candidate B now pays the monthly website fee of $99 from the candidate’s publicly funded campaign account. This is considered to be an allowable expense. The candidate does not have pay for a new campaign website.

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This is a gray area and a definite weakness in the county’s public financing program.  Given the fuzziness of this standard, I will offer no opinion on whether the above conduct is legal.  The only entities who can determine whether Jawando’s traditional account spending are in compliance with county law are the State Board of Elections and the Office of State Prosecutor.

I asked Jawando’s campaign for comment on Monday.  As of this writing, I have not received a response.

This is the third time I have written about potential expenditures on Jawando’s executive campaign outside of his public financing account.  On November 5, I reported that Jawando’s U.S. Senate account gave $115,000 to an organization that later endorsed him.  And on November 13, I reported that Jawando’s federal accounts paid an individual who performed work on his executive campaign.  Additionally, Council Member Kristin Mink has been distributing flyers on his behalf, but if there is a problem there, I don’t know of any evidence that Jawando is responsible for it.

Regardless of legal questions, the above constitutes a pattern of conduct.  It’s time for state authorities to determine whether these activities are consistent with Montgomery County’s public campaign financing law.