This is the ninth story in an exclusive series about the funding behind politically active tax-exempt organizations that don’t disclose their donors. You can read the other stories in the series here.

So far in the 2012 election cycle, the political action committee of TCF Financial — a publicly traded holding company that owns Minnesota-based TCF Bank — has given away $105,500.

Most has gone to candidates and party committees. But TCF PAC’s largest contribution by far — nearly a quarter of what it has given away over the last year-and-a-half — is the $25,000 it gave on May 31 to Americans for Prosperity, a group founded and funded by David Koch. He’s one of the billionaire Koch brothers, mega-funders of the right who convene twice-a-year retreats with other wealthy Republicans to strategize and pledge money to the cause.



TCF’s pugnacious chairman and CEO Bill Cooper, a former Detroit street cop and head of Minnesota’s Republican Party in the late 1990s, has attended at least one of the Kochs’ conservative gatherings.

Americans for Prosperity is a 501(c)(4) organization under the framework of the U.S. tax code, which means that it’s a nonprofit “social welfare” group allowed to engage in limited political activity. Groups such as these — Stephen Colbert calls them “spooky PACs” — don’t have to disclose their donors, unlike their more famous cousins, super PACs. Increasingly, they have become the vehicles of choice for donors wanting to give six-, seven- or even eight-figure sums — anonymously — to political entities.

The Koch group reported spending $1.3 million in 2010 on ads attacking dozens of Democratic candidates. But overall, Americans for Prosperity and its affiliated foundation, with which it shares staff and overhead, claims to have spent about $40 million on election-related activities in that cycle. OpenSecrets Blog has written about contributions to 501(c)(4)s from other social welfare groups or charities, and corporations and individuals are known to give to them as well. Americans for Prosperity’s funders in 2010 ranged from the American Petroleum Institute, which gave $25,000, to the mysterious Center to Protect Patient Rights, which may have been created as a pass-through for donations to conservative groups; it gave Americans for Prosperity nearly $2 million.

TCF PAC’s $25,000 clearly is at the low end of that scale, and the gift isn’t anonymous. But it’s an unusual expenditure for a PAC to make. Standard corporate PACs, which are mostly funded by employee contributions, tend to stick to giving to candidates, leadership PACs and party committees. That’s partly because there are other ways corporations can fund outside spending groups, but not many legal ways they can help candidates other than through their PACs.

Asked about the donation, TCF spokesman Jason Korstange said, “It’s an expenditure for a group that is pro-business and pro-growth in America.” Korstange said the PAC has given money to other such groups, though he couldn’t name any. The PAC’s spending “includes both Democratic and Republican issues and candidates,” he said.

A review by OpenSecrets.org of the PAC’s disbursements in the 2010 cycle found that the candidates it gave to were mostly Republicans and mostly midwesterners. Wisconsin GOP Rep. Paul Ryan received $5,000 in April, for instance, and Minnesotan Chip Cravaack, also a Republican lawmaker, was given the same amount in January. The occasional Democrat makes the list, such as Rep. Gary Peters of Michigan, who has received a total of $3,000 from the corporate PAC this cycle. Republican party committees and a few leadership PACs received donations as well.

It doesn’t appear that any was given to 501(c)(4) groups other than Americans for Prosperity. Cooper, who’s said to have a strong libertarian streak, doesn’t seem worried about breaking a mold here and there. He sued the Federal Reserve and the Comptroller of the Currency last year in an attempt (unsuccessful) to block portions of the Dodd-Frank Act that limits how much banks can charge businesses each time a customer used a debit card. About 9 percent of TCF’s 2010 revenue, or $111 million, came from debit card fees, according to court documents cited by American Banker. The new caps on debit card charges, as well as restrictions on how banks cover overdrafts, sharply cut TCF’s income from fees this year compared with last. In the 2010 election cycle, TCF became one of the largest corporate contributors to independent spending committees in Minnesota, but in a roundabout way. The bank gave $250,000 in corporate funds (not through its PAC) to an LLC called State Fund for Economic Growth (SFEG), which then donated to two other groups called MN Forward and the Taxpayer’s League of Minnesota. The Taxpayer’s League was involved in a lawsuit challenging parts of the state’s campaign finance disclosure laws, while MN Forward supported the Republican gubernatorial candidate, Tom Emmer.

TCF was the sole donor to SFEG. But using the intermediary group appears to have allowed it to escape the sort of criticism Target received in 2010 when it gave money to a business advocacy group that used the funds to support a Republican candidate who opposed gay rights.

The PAC’s contribution to Americans for Prosperity, though, is anything but stealthy.

Researcher Robert Maguire contributed to this story.