The Jan. 15 campaign finance reports for the 2015 San Antonio municipal elections are out. What they reveal is who’s been hard at work getting ready for the elections. What they also reveal is who supports whom in terms of money in the bank.

Just like any good story, however, there’s always a good subplot to be revealed and these reports have plenty of subplots in them. One of the biggest involves campaign finances that seem to drift between state and local regulations, namely those of Mike Villarreal and Leticia Van de Putte.

Before we get too deep in the money, let’s catch up with the backstory on this. Both Villarreal and Van de Putte have announced their candidacy for mayor of San Antonio. In fact, Villarreal resigned his office which is being sought by former District 1 Councilmember Diego Bernal, a Democrat, and Nuncio Previtera, a Republican. Van de Putte, on the other hand, has yet to resign from the Texas Senate and doesn’t plan to do so until the completion of a run-off election between Trey Martinez-Fischer and Jose Menendez.

Read more: Texas Senate, House Races Headed For Runoffs

To further complicate matters, remember that Van de Putte signaled her intentions to run for mayor after losing a bid for lieutenant governor to Dan Patrick. You’ll see why that matters in a minute.

Looking at the campaign finance reports for both Villarreal and Van de Putte, both are in a pretty good financial position going into 2015. Villarreal reports almost $190,000 on hand and Van de Putte lists more than $197,000 on hand at the Jan. 15 reporting deadline. But since both were state office holders prior to their declaration for mayor, the funds within the campaign accounts were also designated for the state offices.

This is where things get interesting. You see, whereas the City of San Antonio has campaign finance limits of $1,000 from either individuals or specific-purpose political action committees (SPACs), the state has no limits. In fact, it’s not uncommon for donors to give tens of thousands of dollars to state candidates in the course of a campaign year. So these accounts could reflect donations that exceed the limits imposed by the City in its attempts to control special interest influence.

Van de Putte also ran for lieutenant governor this past year. In that election, where the stakes were much higher, her campaign raked in more than $2 million. In fact, some donors gave as much as $100,000 to the campaign. At the Jan. 15 filing, that war chest still had almost $250,000 in it. That’s after transferring more than $500,000 to the state party right before the election.

Mayoral candidates Mike Villarreal (left) and Leticia Van de Putte spoke at the Alamo Beer Company brewery ribbon cutting ceremony. Photos by Iris Dimmick.

So, this starts to unfold some questions about where the money came from and might end up. So far, Van de Putte has transferred a little more than $17,000 from her lieutenant governor campaign fund to her current candidate fund. Manny Garcia, senior advisor with Van de Putte’s mayoral campaign, said that transfer was to reimburse the senatorial campaign fund for a prior transfer to her lieutenant governor campaign fund.

The City’s Campaign Finance Code allows a candidate to maintain a single candidate fund for both offices. But there is a limitation as stated in the code: “However, if the candidate seeks a municipal office which is subject to lower campaign contribution limits than the previously sought office, the candidate shall return all contributions in excess of the limits for the municipal office sought.”

Furthermore, the code states that “contributions transferred must be aggregated with any contributions made by the same donor to the committee receiving the transfer. Amounts that would cause a contributor to exceed his or her pre-election cycle contribution limit must be excluded from the transfer.”

What this means is that any contributions exceeding the city’s limits must be returned to the donor. The problem is that since Van de Putte is still a state officeholder, she continues to incur expenses in fulfilling the duties of that office. In fact, with regards to activities, it’s difficult to tell when she is acting in the role of state senator or candidate for mayor at functions. So any expenses could be construed to be for her role as a state officeholder, such as tickets to events or traveling around the city.

One of the challenges with the campaign finance reporting appears to be the system used by the Texas Ethics Commission (TEC). In the past, when a candidate maintained two campaign account for different campaigns, the campaign had used a field within the report to help denote which account the funds were either designated for or disbursed from. According to Garcia, the TEC has stated that field, usually used for identifying in-kind donations or expenses, could not be used for this purpose.

Without this designation, it is nearly impossible to determine which campaign the funds are for and what limits might apply. Since Van de Putte continues to represent her senatorial district in Austin, she continues to incur expenses and uses senatorial campaign funds to pay for those expenses.

Garcia said that to show compliance, the mayoral campaign submitted bank statements to the City of San Antonio. Absent of better campaign finance reporting, he said that’s the best approach they could come up with to prove compliance.

Villarreal has already resigned from his state office and has publicly stated in his report that no expenditures were paid from the account for the final acts as state representative. In other words, he’s closed the books as a state representative and all actions forward are for the mayoral race.

This is the first time since our city enacted these campaign finance regulations that such a situation like this has presented itself. It creates a challenge for San Antonio’s Ethics Review Board on what money is legal and what might cross a line.

It’s not clear what Van de Putte plans to do with her money in the Lieutenant Governor SPAC. Until she resigns the Senate, she can continue to transfer money into her candidate fund since she is still a state officeholder. That could give her a substantial financial advantage over Villarreal, even if the money was contributed to an entirely different race by people with different intentions for their contributions.

As you can see, Villarreal has a clear delineation of where money is coming from for his campaign. Van de Putte, while remaining a state officeholder, is faced with ambiguity due to reporting shortcomings. It’s just part of the fun we can expect with this mayoral race.

*Featured/top image: Mayoral candidates Leticia Van de Putte (left) and Mike Villarreal (right). Photos by Page Graham and Al Rendon, respectively.

Related Stories:

Following the Money in the Special Election

Call to Action from Departing San Antonian

Villarreal Backs Rideshare, Van de Putte Follows Suit

Texas Senate, House Races Headed For Runoffs