National Legal and Policy Center (NLPC) has filed a Complaint with the Federal Election Commission alleging that Rep. Maxine Waters (D-CA) violated federal election law in a transaction related to her so-called slate mailer earlier this year.

Former Los Angeles Mayor Antonio Villaraigosa, who was running for Governor in the Democratic primary, was included on the mailer for a fee of $25,000. His campaign did not pay. Instead, a group called “Families and Teachers for Antonio” did. (Villaraigosa lost the primary to California Lt. Governor Gavin Newsom.)

Whereas candidates like Villaraigosa may legally pay Waters’ campaign for the proportional costs of their inclusion on her slate mailer, it is not legal for such payment to be made by a third party like “Families and Teachers for Antonio.”

“Families and Teachers for Antonio” is funded by wealthy individuals like Michael Bloomberg, who kicked in a total of $3.5 million. On the very day that the group gave Waters $25,000, Bloomberg gave it $1 million. If Bloomberg wanted to make a direct contribution to Waters’ campaign, he would have been limited to $2,700, just like any other citizen.

This is the second Complaint filed by NLPC against Waters regarding her “slate mailer,” the first being on July 26, when Senator Kamala Harris (D-CA) was a co-respondent. The violation was a payment to Waters’ campaign fund from the Democratic State Central Committee of California (DSCCC) in the amount of $35,000 for the inclusion of then-Senate candidate Harris on Waters’ slate mailer in 2016.

Waters’ slate mailers have been a matter of controversy for years. They resemble a sample ballot distributed by political parties before and during elections, but contain Waters’ personal endorsements. She pioneered a new way to use slate mailers by seeking an Advisory Opinion from the Federal Election Commission in 2004 that allows her to use her federal campaign to also function as a State of California slate mailer committee while still maintaining eligibility as a principal federal campaign committee.

The Complaint alleges that the “Families and Teachers for Antonio” payment was not legal under the Advisory Opinion. In addition to a request for an investigation of these apparent violations, NLPC asks for an audit of Waters’ campaign committee.

The main beneficiary of the slate mailers appears to be companies controlled by Waters’ daughter Karen Waters, which have received hundreds of thousands of dollars to produce the mailers. It is unclear how much work this involves, and whether the payments are consummate with the market value of such services.

The Complaints are based on original research by Tom Anderson, director of NLPC’s Government Integrity Project, who is now examining other public documents related to Waters’ finances, and those of her daughter. According to Anderson, “It is critical to detect reporting violations because they are often the result of efforts to conceal more serious questionable activity. It has also been our experience that longtime incumbents in safe districts are the most corrupt. They can get away with something for many years, but then they get sloppy.”

Meanwhile, Waters continues to keep herself in the news. On September 30, she tweeted, “Kavanaugh, so many have come forward describing your abuse of alcohol. I think it is important that the American people know if you have ever sought treatment for alcohol abuse.”