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Donald Trump’s campaign manager, Kellyanne Conway, was asked in an interview on CNBC Monday morning to defend the Republican nominee’s lack of a paper trail for his claims of charitable donations. As documented in extensive reporting by the Washington Post‘s David Fahrenthold, there is scant evidence that Trump has given any significant amount of his own money to charity.

Conway started her response by saying she had personally observed Trump signing checks. Then she switched to a novel defense of Trump’s generosity: His presidential campaign qualifies as a charitable contribution to the country.

“And the fact is that the idea that somebody who has made such a tremendous sacrifice to run for president—basically a huge sacrifice: didn’t need the money, didn’t need the fame, didn’t need the power, didn’t need the status—and you’ve got a lot of deals that didn’t get done, I’m sure, in the Trump Corporation because the guy at the top is running for president,” she said. “Those are tremendous sacrifices. He’s been incredibly generous.”