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Mrs. Palin’s staff did not return a request for comment on the PAC’s spending policies.

Spreading Cain’s name

In Mr. Cain’s case, the single biggest recipient of his PAC’s money in the latest quarter was another Cain group: Cain Solutions Inc., which has received $213,000, including $75,000 in the latest reporting period alone. Because it is formed as a nonprofit and not a political committee, there is no way to know how that money was spent or to whom it might have been given.

“I have to talk slowly to make sure I get them right, there are so many of them,” Mr. Block said.

During the presidential campaign, the campaign purchased books by Mr. Cain from a for-profit company based at the same address as Cain Solutions.

Now, Cain Connections’ emails almost always attempt to sell books by Mr. Cain, linking to a book site that says it is paid for by the Cain Foundation, a 501(c)3 charity.

“Beyond the question of whether those solicited are being deceived about how the money will be spent, this case raises concerns about whether multiple entities are being used to hide the flow of money and, ultimately, to provide personal financial benefit to Herman Cain,” said Sheila Krumholz, executive director of the Center for Responsive Politics, which tracks campaign money.

“Otherwise, what is the purpose? Presumably, we would see evidence of this organization’s advocacy in political ads or other materials they’ve produced beyond mere fundraising appeals.”

Value of mailing lists

The status of Mr. Cain’s group as a super PAC allows it to sidestep criticism that its money is not going to political campaigns. By law, super PACs may not contribute directly to candidates.

But Mr. Cain’s organization also has found a way to turn around that process, providing exposure for candidates whose ideologies are agreeable to Mr. Cain and having them provide income to the Cain group by renting out its mailing list. It received $22,000 in list rental fees in the past three months.

Even so, attempts to build a mailing list and raise money have been so intensive that they have put the committee $100,000 in debt. That is on top of the $450,000 in debt left over from Mr. Cain’s presidential campaign, $175,000 of which is owed to the candidate himself, according to the latest FEC records.

While other former candidates, including Texas Gov. Rick Perry, have converted their campaigns into political action committees, Mr. Cain started fresh with one for his ex-candidate advocacy career.

The campaign gave the super PAC its mailing list at no cost, valuing it at more than $500,000, according to super PAC disclosures. That allowed Mr. Cain to leave his debt-saddled campaign behind but strip it of its most valuable asset. If the valuation is accurate, it could have been sold to pay off the presidential campaign’s debts.

But determining where any money goes into Mr. Cain’s various activities is difficult because of rampant “sloppiness,” Mr. Ryan of the Campaign Legal Center said. The presidential campaign did not even report giving away its list.

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