The New York Times created a graphic of the intermingled interests in Suite 555, but it overlooked at least one key player: Americans for Job Security, which spent $48 million in 2012. Founded by veteran GOP consultant Dave Carney and previously run by Dubke, AJS is now officially headed by Steve DeMaura. But according to a report by the Center for Public Integrity, Carney still “works in the background, drumming up business.” In the California case, for example, it was Carney who steered the fundraisers to AJR (which took a $1.5 million cut) and also directed them to use Crossroads Media for any ad work.

Crossroads Media has been described as “effectively an in-house ad agency for Rove’s political empire.” For the tenants of Suite 555, Bloomberg noted, keeping the media business in house was “potentially a way to increase their own personal take.”

If all this is too complicated to follow, it seems to be intentional. The thicket of interrelated groups makes it difficult to follow the money or discern how much anyone took home in 2012. Forti, for example, did not earn a salary from either Restore Our Future or Crossroads GPS. Did he volunteer his time? The consulting fees Black Rock Group collected from officemates who had to report then to the FEC or the IRS total more than $300,000, but there’s no way to know how much Dubke might have steered to the firm in the course of spending $161 million at Crossroads Media.

FEC rules prohibit “coordination” between a campaign and a super PAC, and when consultants work for both—as several did in Suite 555—“regulators should question whether they are operating independently,” campaign-finance experts told ProPublica. But without more robust spending disclosure rules such questions don’t go far.

Alexander Gage, founder and CEO of Target Point Consulting, another Canal Place Plaza tenant working for both the Romney campaign and the super PAC, told the New York Times, “it’s not like we’re a commingled office,” noting that a conference room separated his shop from Forti’s Black Rock Group. As for his wife, Katie Packer Gage—who was deputy campaign director for the Romney campaign, as well as a one-time partner in another suitemate that did business with both the campaign and the super PAC—Gage said she worked out of Boston and they didn’t discuss campaign specifics.

“I’m sure most of the individuals playing these roles are getting legal advice on what they can and cannot do,” said Rick Hasen, a law professor at UC-Irvine who runs the Election Law Blog. “The human brain being what it is, though, I think it is very difficult to separate those roles."

No One's Watching the Store

In their 2010 Citizens United decision, the justices maintained that full disclosure of campaign-finance activity would be an adequate safeguard against the ill effects of unfettered spending. But “the transparency the Supreme Court relied upon to justify this new framework has been sorely lacking,” says Sheila Krumholz, director of the Center for Responsive Politics. Mired in partisan rancor, neither the FEC nor the IRS has updated its regulations to deal with the new reality.