The Bernie Sanders campaign in April accused Hillary Clinton of “looting” her joint fundraising committee to fund her presidential campaign, effectively circumventing rules that cap donations at $5,400 per person.

Clinton’s joint committee, called the Hillary Victory Fund, can raise $358,500 per person because it’s supposed to share money with the Democratic National Committee and state parties.

The Sanders campaign pointed to news reports that the fund has been covering expenses for the Clinton campaign instead of spending on down-ballot races.

The Clinton campaign called the charges irresponsible.

But if the Sanders campaign is right, it wouldn’t be the first time something like this happened.

Previously unreported details from campaign filings dating to Clinton’s first presidential bid show that, between 2008 and 2009, a similarly intentioned “leadership PAC” called Hill PAC directly enriched her own campaign and campaign staffers considerably more than it did those of other candidates.

Hill PAC dates back to 2001, but was dormant while Clinton ran for president. She relaunched Hill PAC after suspending her campaign in June 2008 and tossing her support to Barack Obama.

In an October 2008 article headlined “Democrats Have Reason to Celebrate: Hill PAC Is Back,” the Washington Post cast it as a big win for down-ballot races.

“We’re throwing everything we’ve got into making sure [Obama] stands before the nation as a president with the political strength to break the gridlock, get things done, and start progress going in America again,” Clinton wrote to supporters in October. “And with a filibuster-proof Senate, we’ll be able to bring the change this country so desperately needs.”

A Hill PAC email sent the day before the election read: “I hope you will take action by joining us in this final push,” just above a button to contribute.

But only 11 percent of the relaunched Hill PAC’s spending ultimately went to candidates, filings show. Between June 2008, when Clinton dropped out of the presidential race, and the PAC’s termination the next summer, Hill PAC raised about $3.9 million but contributed just $421,500 to candidates.

Most top leadership PACs dedicate close to half of what they raise to other candidates in competitive races, according to OpenSecrets.org. In the years after its founding in 2001, Hill PAC spent a larger proportion of its expenditures on contributions to other candidates — but still considerably less than the average leadership PAC. It spent 27 percent on others in 2002, 17 percent in 2004, and 16 percent in 2006, according to FEC filings.

The relaunched Hill PAC spent twice what it gave in contributions to other campaigns on salaries to its own staffers, almost all of whom had worked for Clinton’s campaign or her Senate office. For instance, Clinton campaign treasurer Shelly Moskwa was paid about $11,000 more by Hill PAC in 2009 than the treasurer of Hill PAC itself, Allison Wright. Hill PAC also paid nearly $400,000 in consulting fees to firms founded or closely associated with campaign staffers. The campaign and Hill PAC even shared an Arlington office.

Neither Wright, now executive director at the U.S. National Commission for UNESCO, nor former Hill PAC director Capricia Marshall, now ambassador in residence at the Atlantic Council, replied to several emails and calls for comment.

But Clinton press aide Nick Merrill told The Intercept that looking at direct donations alone “is not an accurate reflection of the efforts and the efficacy of the PAC.”

“The 11 percent number is misleading,” he wrote in an email. “HillPAC determined that one of the fastest and most productive ways of using the list to benefit candidates was to email supporters — in many instances urging them to make contributions directly to candidates.”

For instance, Merrill said Hill PAC facilitated $750,000 in direct grassroots donations in the months before November 2008 — twice as much as the PAC gave directly to candidates. Such donations would not have run through PAC coffers, however, and are therefore not verifiable via FEC records.

The Intercept examined over a dozen emails sent by Hill PAC from July to November 2008, each soliciting contributions through hyperlinks that took donors to the PAC’s website. A cached version of the PAC’s site shows both “candidates” pages that link to ActBlue, a clearinghouse for small donations to Democratic candidates, and a “contribute” page that appears to solicit contributions to the PAC.

Merrill also credited Hill PAC with “recruiting thousands of volunteers in a HillPAC grassroots field organizing program called ‘Hillary Sent Me’” who went “door-to-door campaigning across the country in seven targeted states,” as well as paying for Clinton’s travel costs “as she traveled cross country in support of the Obama ticket, including 70 events for that ticket alone.”

Merrill said she “campaigned and fundraised for over 80 other candidates in nearly 30 states, including 16 Senate and 60 House candidates, and, in the process, raising millions of dollars for Democrats.” Clinton headlined events where “over $10 million dollars was raised for the Obama-Biden ticket,” he said.

But the event schedule he cited to support that figure pointed to fundraisers hosted by the White House Victory Fund, a joint fundraising committee unaffiliated with Hill PAC. And at one of the events cited by Merrill, Obama asked donors to contribute to Clinton’s campaign on pledge cards located under their seats, according to a CNN report. “Senator Clinton still has some debt,” Obama told the audience.

What FEC records show is that Hill PAC’s single largest payment went to Clinton’s campaign, which was about $25 million in debt, including $13 million Clinton lent it herself, when Clinton dropped out in June. While Hill PAC couldn’t legally donate more than $5,000 to Clinton’s campaign account, it was allowed to pay for goods or services from the campaign.

Hill PAC paid $822,492 to the Clinton campaign to rent its list of supporters and their contact information. That alone was nearly twice the amount Hill PAC contributed to down-ballot candidates.

The campaign told the Wall Street Journal in 2009 that Hill PAC paid to use the list for the November election. But filings show Hill PAC didn’t actually pay for the list until January 19, 2009.

Two days after Hill PAC’s payment to her cash-strapped campaign, Clinton was confirmed as secretary of state in the Obama administration.

Hill PAC did not contribute to any candidates after that, and dissolved in July.

“The evidence does suggest Hill PAC was used primarily as a slush fund to subsidize Clinton’s presidential campaign, using money raised outside of the limits that apply to the campaign itself, rather than as a fund to support other candidates,” said Brendan Fischer, a campaign finance expert at the Campaign Legal Center, a nonpartisan group that supports campaign finance reform.

Fischer said that, in regards to the list payment, “if there was a functioning FEC,” it “could have followed up and asked for the contract between the Clinton campaign and Hill PAC or any of these other groups to determine whether the delayed payments were pursuant to an agreement. But of course we don’t have a functioning FEC.” (The Federal Election Commission is in a near-perpetual 3-3 deadlock, with Republican commissioners refusing to enforce the laws.)

Merrill insisted that Hill PAC “was always operated with the highest of ethical standards, and implications to the contrary from those with partisan motives is wholly without merit.”

He said the list rental price, at approximately $600 per 1,000 names, represented the “fair market value” for a multiple-use rental. He said “pricing validation from commercial vendors was used, along with the most recent past presidential campaign at the time, which was Kerry ’04.”

Around the same time, the Clinton Foundation, the Democratic Congressional Campaign Committee, the DNC Federal Fund, the Presidential Inaugural Committee, and the American Democracy Institute paid $274,297, which Merrill said was the rate for a one-time rental. Other groups paid less.