A few hours after a certain former Florida governor took to Facebook last month to announce he was going to “actively explore” a presidential run, a political action committee called the Conservative Action Fund blasted out an email to thousands of recipients urging them to “help us stop Jeb Bush today.”

The email, signed by the PAC’s chairman, Shaun McCutcheon, pleaded, “If you are a conservative like me who is tired of the special interest, political elites like Jeb Bush running the GOP, then I need your immediate help to make it clear that American conservatives reject a Jeb Bush candidacy.”

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Bush could be persuaded to stay out of the race, McCutcheon’s email asserted, if “hundreds of thousands of conservative, grassroots activists” signed petitions by Dec. 19 to be “hand delivered to Jeb Bush in a very public way” that would presumably shame him out of the race. “And after you sign the petition, please make a donation of $5, $15, $25 or more to help us get even more signatures?” the email concluded in underlined bold text embedded with a hyperlink that took readers to a petition landing page that asked for their emails and then their cash.

It was a slick and well-timed campaign, tapping into the angst of grass-roots conservatives who are as unhappy with GOP leaders like Senate Majority Leader Mitch McConnell and Speaker of the House John Boehner as they are with President Barack Obama and congressional Democrats.

And while the PAC’s treasurer told POLITICO that the email got an “extremely positive” response in petition signatures and contributions, more than one month later the Conservative Action Fund had yet to deliver any signed petitions to Bush. It did, however, send out a similar email this month urging recipients to sign a petition to “TELL MITT ROMNEY: SIT 2016 OUT” and then to make a contribution of “at least $17.76 today” to “help keep our efforts funded.”

The efforts bear some of the hallmarks of a phenomenon that watchdogs say is threatening the integrity of the campaign funding system, and that conservative leaders worry could seriously undermine their interests headed into 2016. Since the tea party burst onto the political landscape in 2009, the conservative movement has been plagued by an explosion of PACs that critics say exist mostly to pad the pockets of the consultants who run them. Combining sophisticated targeting techniques with fundraising appeals that resonate deeply among grass-roots activists, they collect large piles of small checks that, taken together, add up to enough money to potentially sway a Senate race. But the PACs plow most of their cash back into payments to consulting firms for additional fundraising efforts.

A POLITICO analysis of reports filed with the Federal Election Commission covering the 2014 cycle found that 33 PACs that court small donors with tea party-oriented email and direct-mail appeals raised $43 million — 74 percent of which came from small donors. The PACs spent only $3 million on ads and contributions to boost the long-shot candidates often touted in the appeals, compared to $39.5 million on operating expenses, including $6 million to firms owned or managed by the operatives who run the PACs. POLITICO’s list is not all-inclusive, and some conservatives fret that it’s almost impossible to identify all the groups that are out there, let alone to rein them in.

“These groups have the pulse of the crowd, and they recognize that they can make a profit off the angst of the conservative base voters who are looking for outsiders,” said the influential conservative pundit Erick Erickson, who has taken it upon himself to call out PAC operators and fundraisers he sees as scams. They are “completely a drain,” said Erickson, whose assessments of candidates and groups carry particular weight among tea party activists and the Republicans who court them. “The conservative activists feel like they’ve contributed to a cause greater than themselves, but the money goes to the consultants, and eventually the activists get burned out and stop giving money, including to the legitimate causes.”

In the run-up to the 2014 midterm elections, McConnell and Boehner tried to marginalize out-of-favor PACs, and McConnell’s allies last week

launched an unofficially endorsed super PAC to go along with one that Boehner’s confidants formed in 2011, partly to stem the flow of cash to competing PACs.

That technique has worked well for Democrats, who have mostly avoided the problem, though they also benefit from the lack of tea party-style insurgency on their side. That could change if the 2016 Democratic presidential primary inflames deep ideological divisions within the party.

But on the right, this industry appears only to be growing, according to conservatives who track it closely.

A couple of days after receiving the anti-Bush email from the Conservative Action Fund, Erickson took to his Red State blog to lament the trend. “It is a terrible blight on the conservative movement and on the tea party in particular that the hucksters have come up to cash in,” he wrote. “From the groups claiming to represent Ben Carson to the groups raising money for Allen West to now a group claiming to raise money to ‘Stop Jeb Bush,’ I think more and more older conservatives are getting scammed by con men living well off other people’s money. I doubt very much that much, if any, of the money is going to support these causes.”

Such efforts could be particularly damaging to Republican chances in 2016. In recent elections, the party’s nominees have sometimes struggled to raise the sort of small donations necessary to sustain their campaigns, particularly at the presidential level, where presumptive nominees can face a funding gap in the run-up to the convention after they’ve tapped all their major donors for the primary but before they’re legally allowed to start spending a second round of big checks for the general election.

PACs like those that have drawn Erickson’s scorn don’t have to slog through a long campaign with repetitive fundraising appeals. They can, and do, quickly change focus to keep pace with the scandal of the moment — from Benghazi to Obamacare to liberal media bias to Islamic extremism. Old PACs associated with stale issues or politicians are shuttered, and new ones created to fill the void.

Among the more consistent themes of the PACs — much to the dismay of the GOP establishment — is the targeting of RINOs (Republicans in Name Only) and the boosting of ideologically pure Republican candidates, including many who stand little chance of winning. A particular focus is on politicians who are military veterans, tea party activists, African-Americans — or all three. Questions about profiteering have swirled around PACs and operatives who have claimed to be supporting African-American conservatives, including former Rep. Allen West, 2012 presidential candidate Herman Cain, fringe 2016 hopeful Ben Carson and two-time unsuccessful House candidate Deborah Honeycutt of Georgia. And a PAC called the Black Republican PAC spent less than 1 percent of the $700,000 it raised in 2014 on contributions to candidates or ads supporting them, according to government filings.

While operating expenses sometimes include travel or salaries for staff involved in get-out-the-vote or other political activities, most of the groups POLITICO examined do very little on-the-ground work, instead spending the majority of their cash on fundraising such as renting and soliciting from direct-mail and email lists. But defenders of the PACs contend that their fundraising efforts perform a valuable service for the conservative movement by mobilizing the grass-roots base, and that it costs money to raise money.

“Direct mail is expensive. Phone campaigns are expensive,” said Dan Backer, who serves as a lawyer, treasurer and strategist for the Conservative Action Fund and 14 other PACs included in POLITICO’s analysis. “Email is not as free as people want to pretend like it is. It’s really expensive. … And there’s a lot of money that goes into making these things legal so — I hate to say it — you pay for lawyers,” he added.

In 2014, Backer’s PACs — a roster including Draft Newt (created to coax the former House speaker into the Virginia Senate race), the Tea Party Leadership Fund (which urged Sarah Palin to run for Senate), Stop Hillary (to oppose the former secretary of state’s expected presidential campaign) and Stop Pelosi (which the Federal Election Commission called out for using the House Democratic leader’s name) — spent more than 87 percent of the $8 million they raised on operating expenses, including $419,000 to Backer’s own law firm, DB Capitol Strategies. By contrast, the amount the PACs spent on donations and ads was about $955,000 — or less than 12 percent of their total fundraising haul.

McCutcheon, the Alabama electrical contractor who chairs the Conservative Action Fund and signed the “Stop Jeb Bush” email, said Backer provides a valuable service to PACs. “It’s up to donors like me to decide if we want to buy, and, in my case, I did. I wanted to buy a lot,” said McCutcheon, who was among the top donors to Backer-linked PACs during the midterms, giving at least $34,000. “If anybody was getting scammed, it would be me. I’m one of the biggest donors to all of these things out there and will continue to donate,” he said, though he conceded there are unsavory PAC operators. “It’s just like in business. Anytime there’s money out there, there’s going to be some of them that are not legitimate.”

In an interview last month in Backer’s office in a third-floor walk-up over an architectural ceramics shop in the Republican consulting hub of Old Town in Alexandria, Virginia, Backer explained that his PACs have to spend more on fundraising because they’re mostly new and are trying to build supporter bases from scratch.

But he bristled at efforts by fellow conservatives to cast his efforts as profiteering. “It drives me nuts when people say ‘Oh, scam PAC this, scam PAC that,’” he said. Singling out Erickson in particular, Backer pointed out that the pundit’s own email list is routinely rented for fundraising by PACs, including some represented by Backer. (Erickson said he has no control over to whom his email list is rented by the company that owns it, “and it horrifies me that the list sometimes get rented to some of these guys.”)

Backer, a jovial and fast-talking 37-year-old father of two young sons, got into the business in 2009, just as the tea party was gaining traction. He started DB Capitol Strategies in 2010, not long after graduating from George Mason University School of Law, after a three-month stint working for a firm defending people against mortgage foreclosure, some of whom he said “probably knew exactly what they were doing and really deserved to be foreclosed upon.” By contrast, he considers tea party PACs both a viable business proposition and a cause he can get behind.

“These guys need legal help, and they need to be able to afford that legal help — they don’t have big money — and so there’s not a market big enough there to justify a lot of lawyers practicing in that space,” he said. “So I kind of found a niche that I work to, but also very much is my philosophy.”

When POLITICO presented Backer with a printout listing all 40 committees he’d registered in the past five years, he said “Man, there’s a lot of dead PACs on here,” and began crossing off terminated entities, including a super PAC created to draft Fox News analyst Andrew Napolitano for president. It spent more than half the $11,000 it raised during the 2014 cycle on payments to Backer’s firm.

“I would love to do a draft presidential committee for all the guys who I think have something serious or good to say,” said Backer, who, unlike more traditional election lawyers, gets involved in his PAC’s fundraising and messaging. This month, he’s signed Conservative Action Fund fundraising appeals asking for cash — as well as for signatures on petitions to “Demand NBC Fire Al Sharpton” and to oppose an effort by “Obama and his goons at the FEC … to strip away your constitutionally protected freedom of political speech online.”

While there is no such effort — only a proposed dialogue about how the FEC’s regulations “may or may not fit with future innovations” online — the latter petition highlights Backer’s enmity toward campaign-finance rules that he sees as limiting the free-speech rights of his client PACs and others. “Free speech — freedom in general — matters to me on a deeply personal level,” he said, noting that his family came to the U.S. from Siberia when he was a baby and often talked “about what it was like to be in a place where the price of freedom was a government bullet to the back of your head.”

He’s filed more than a dozen legal or regulatory challenges to various rules on behalf of clients, and at least two of his cases have resulted in rulings that have expanded his clients’ ability to donate or raise money — including a case McCutcheon brought against the FEC challenging aggregate donation limits, which the Supreme Court ruled unconstitutional last year. Another lawsuit paved the way for the creation of hybrid PACs that include both regular and super PAC accounts, which Backer now sets up for many of his clients, including the Conservative Action Fund.

Backer suggested that in subsequent cycles, his client PACs will be able to spend more cash on donations to candidates because “we already have done the heavy lifting this cycle” of assembling vast databases of supporters. The databases — which are owned by the PACs and can be rented to candidates or other PACs — are in and of themselves a service to the conservative cause, he argued. “These small-dollar donors, they’re sustaining an infrastructure that is about communication and engagement,” he said. “And, frankly, having that infrastructure there is a massive benefit to candidates and campaigns.”

Among the beneficiaries of donations from the PACs he represents were losing tea party congressional candidates he also represented, including Sean Bielat of Massachusetts, Larry Grooms of South Carolina, Niger Innis of Nevada, Rob Maness of Louisiana, Nancy Mace of South Carolina and José Padilla of Nevada. After their defeats, Backer registered PACs for Bielat and Maness, and Bielat’s Beacon PAC in 2014 paid more to Backer’s firm ($11,000) than it spent on donations or ads boosting candidates ($7,000) before it, too, was terminated. Before his campaign, Innis had worked for Stop This Insanity — a nonprofit group represented by Backer that has faced past questions about self-dealing and profiteering — and Innis rejoined the group after his defeat.

Backer said he “always disclose[s] the dual relationship” and added it’s not “abnormal that I introduce my clients to one another,” given that they’re all working toward the same goal.

In fact, his network is far from the only one in POLITICO’s analysis with similar synergy.

A pair of PACs registered to Randy Goodwin in 2014 raised $4.2 million and reported spending less than $17,000 on advertising and contributions to other campaigns or committees. And the majority of the contributions they did make simply went from one of the PACs (Republican Majority Campaign) to the other (Justice-PAC), though $999 also went to the successful campaign for a San Diego Superior Court judgeship of one of the PAC’s operatives, Gary Kreep.

In the 2014 cycle, Republican Majority Campaign paid $91,000 to Goodwin (who also collected $6,000 from Justice-PAC) for management and fundraising and $39,000 to Kreep for consulting, legal services and rent. Kreep didn’t respond to messages left at his courthouse office, but Goodwin said that when Kreep declared his judicial campaign “he resigned his positions of authority with the PACs and ceased all managerial duties.”

Goodwin — who, like his PACs, is based in Santa Ana, California — said he “would strenuously object to the ‘scam PAC’ characterization.” He pointed out that his PACs spent more on advertising in previous cycles and blamed fundraising struggles for the negligible 2014 political spending. “Fundraising is at its heart an entrepreneurial activity. Sometimes it succeeds in bringing in net dollars which can be devoted to supporting candidates, and sometimes it doesn’t,” he said, explaining that he planned to ramp up activity headed into 2016 and hoped to “be able to increase our net dollars going into campaign donations and independent expenditures.”

Likewise, 10 conservative PACs registered to Scott Mackenzie — including Tea Party Majority Fund, Black Republican PAC and several with military-themed names — combined to spend 92 percent of the $17.5 million they raised on operating expenses, and less than 1 percent on donations and ads. In fact, the amount the PACs spent on ads or donations boosting candidates ($1.2 million) was less than the amount spent on fees to a trio of fundraising firms with which Mackenzie has been associated ($1.7 million).

Erickson has reached out to Republican candidates to make the case that Base Connect, one of the firms with which Mackenzie has been associated, will not provide a good return on investment and has suggested he’d withhold endorsements from candidates who retain the firm.

Base Connect CEO Kimberly Bellissimo did not respond to messages left at her firm, while Mackenzie did not make himself available for an interview. On its website, Base Connect acknowledges that direct-mail fundraising — its specialty — “is not the fastest way to raise money, or the least expensive,” but it asserts that its critics only underscore its effectiveness. “Both the Left and Establishment RINOs would like to see Base Connect go away,” the website asserts, contending that’s because “direct mail can be dead-on effective for movement conservative candidates who aren’t independently wealthy, or who don’t have legions of wealthy friends to make contributions.”

At least one former Base Connect client agrees with Erickson — about both the firm and the pernicious influence of scam PACs on the conservative movement.

Base Connect has “found a way to keep” the majority “of all the money they raise right there,” said Drew Ryun, president of the tea party-oriented Madison Project PAC and Madison Action Fund super PAC. The PAC — as well as the campaigns of his father, former GOP Rep. Jim Ryun of Kansas — used to pay Base Connect’s predecessor, BMW Direct, to handle their fundraising until Drew Ryun began questioning how much of the cash they raised was going back into payments to the firm. “It’s like Peter robbing Paul. And you never know which one is Peter and which one is Paul, other than that you’re not one of the two.”

While he said his groups have been able to keep much more of the cash they raised since switching to a different fundraising firm, Ryun added, “all these scam PACs out there have made it harder and harder for legitimate conservative groups to raise money because the donors don’t know who is legitimate and who is not.” That confusion hurts conservative and tea party groups like his “because it allows the establishment machine to try to lump everybody together and call us all ‘scam PACs.’”

GOP operatives tried to tar Ryun’s groups as a self-enrichment scheme during the midterms despite the fact that the groups ended up spending more than $950,000 of the $5.2 million they raised on ads, campaign contributions and get-out-the-vote efforts supporting tea party primary challengers to incumbent Republicans, including McConnell.

Of course, political groups’ overhead varies based on all kinds of factors, including their donor portfolios (it generally costs less to raise cash from major donors) and types of advocacy (there’s generally less overhead in advertising than infield work). One of the more prominent big-donor-funded advertising super PACs, the Karl Rove-conceived American Crossroads, during the midterms spent an impressive 70 percent of the $31.3 million it raised on ads and donations.

“There is an element of education that needs to take place — how to hold not just elected officials accountable, but outside groups accountable,” said Ryun, who suggested groups like his could voluntarily release more detailed spending summaries than are required by the FEC to prove they’re spending donor money responsibly. But he admitted even that might not do the trick. “Honestly, I don’t see it ending. Even if they get called out, these scammers can just disappear behind some other front with new PAC names and new company names and keep doing what they’re doing. The temptation is too much for these guys who see how much money they can make this way.”

While various watchdog groups and government agencies evaluate the efficiency of apolitical charities — generally rewarding those that keep administrative costs at 25 percent or less — there is no similar oversight of political groups.

The FEC, which is tasked with regulating PACs, last year essentially conceded there was nothing it could do to clamp down on profiteering PAC operators. It is “not a matter within the Commission’s jurisdiction,” the agency wrote in dismissing complaints by former Rep. West’s campaign against four PACs — including one run by Mackenzie and another by Goodwin and Kreep — that West accused of defrauding donors by raising money under the false pretense that it would be spent in support of his 2012 reelection campaign, which he lost narrowly.

While the FEC cited Goodwin’s Republican Majority Campaign for “less-than-complete” disclaimers making clear it wasn’t associated with West’s campaign, the commission merely issued a warning. Goodwin told POLITICO his PAC did only one fundraising email mentioning West and “anyone could see that we were making a good-faith effort to comply with those [disclaimer] requirements.” More generally, FEC investigators concluded the four PACs, which raised a combined $14.3 million in 2012, “spent very little of the money they raised to support West. Rather, the funds appear to have been spent primarily on additional fundraising, much apparently to vendors in which some Respondents’ officers may have held personal financial interests. Also troubling are the accounts of donors who mistakenly contributed funds to some respondents while intending to contribute directly to West. Nonetheless, we cannot agree with Complainant that this conduct constitutes a fraud within the reach of the Act or Commission regulation.”

FEC Chairwoman Ann Ravel called the case “frustrating,” explaining to POLITICO that “we looked very carefully at trying to find a way that we could do something about what seemed to be outright fraud, but it was not within our purview. … I think it’s a loophole.”

In a little-noticed report to Congress, the FEC last month suggested that the relevant laws in the West case — which pertain to “fraudulent misrepresentation” — be strengthened and expanded.

Ravel explained that “the goal is for there to be oversight on the Commission of matters where it is the campaigns themselves and by extension the donors that are being defrauded.”

Such legislation seems unlikely, given that one of the few things Congress has been able to agree on recently is weakening campaign-finance restrictions.

In the meantime, the lack of clear financial guidelines about PAC activity has led to a Wild West-type atmosphere in which operatives and donors debate among themselves which groups are legitimate and which are not.

Mackenzie explained to the FEC attorneys investigating West’s complaints that the hefty payments to his firms were necessary because “fundraising is expensive and getting more so every year.”

That’s especially true for anti-establishment groups, Backer argued, since they can’t depend on ties to conservative megadonors like the billionaire industrialist brothers Charles and David Koch or Las Vegas casino mogul Sheldon Adelson.

We don’t have Koch money, we don’t have Adelson money. I would give somebody else’s right and left nuts to have any kind of that money for some of our work.

“We don’t have Koch money, we don’t have Adelson money. I would give somebody else’s right and left nuts to have any kind of that money for some of our work. I really wish we did have larger dollar donors to support these efforts, because of the cost of fundraising,” said Backer, who has taken some steps into the big money world. He attended a March fundraiser for Innis’ campaign at Adelson’s sprawling Las Vegas estate, along with McCutcheon, who is a significant donor in his own right but told POLITICO he was “mesmerized” by Adelson’s “huge fish tank and a great bird cage filled with all these birds that must have been from Africa.”

While operatives typically go to greater lengths to keep big donors happy, Backer said he feels the same obligation to his small donors.

“It is not a legal obligation. It is a moral obligation to be a good steward of the money of donors,” he said. “Especially in the grass roots, where that $5, $10, $20, $30 — that’s a lot of money to some people. I read these shaky, handwritten letters, and I want to make sure that we do everything as efficiently as possible.”