January 10, 2023

The Honorable Michael Guest

The Honorable Susan Wild
Committee on Ethics
1015 Longworth House Office Building
Washington, DC 20515

Re:
Timely, Accurate, and Complete Financial Disclosure Reports

Dear Representative Guest and Representative Wild,

We write to request an investigation of George Anthony Devolder-

1 for

complete financial disclosure reports as required by law.

2 Over the past several weeks, extensive public reporting

admissions have shown that Mr. Santos misled voters in his District about his ethnicity, his
religion, his education, and his employment and professional history, among other things.

minimum, it is apparent that he did not file timely disclosure reports for his most recent
campaign. Moreover, his own public statements have contradicted some information included in
the 2022 financial disclosure and confirmed that the 2022 financial disclosure failed to disclose
other required information.

Given the revelations about his biography, as well as the public information pertaining to his
financial disclosures, Mr. Santos has failed to uphold the integrity expected of members of the
House of Representatives. We therefore respectfully request that you investigate this matter to
determine the extent of these violations and take appropriate action as soon as possible.

Failure to File Timely Reports

The Act requires individuals to file a financial disclosure report within thirty days of becoming a
candidate or on or before May 15 of that calendar year, whichever is later, and no later than

1
See FEC, Candidate Information of George Anthony Devolder-Santos,
https://www.fec.gov/data/candidates/?q=H0NY03083&is_active_candidate=true&has_raised_funds=true.
2
Ethics in Government Act, Pub. L. No. 95-521, 92 Stat. 1824, 1824 (1978).
thirty days before any election in which the candidate is participating.3 A candidate must then
file subsequent financial disclosures annually on May 154 of each year he or she continues to be
a candidate.5 An individual becomes a candidate when he or she has received contributions
aggregating in excess of $5,000 or made expenditures aggregating in excess of $5,000.6
Individuals are subject to civil penalties for knowingly and willfully falsifying or failing to file or
include any information that they are required to report pursuant to the Act. 7 Specifically, the Act
authorizes the Attorney General to bring a civil action against violators in any appropriate United
States district court. 8 Courts can also impose civil fines of up to $66,190 for a violation. 9

mmittee received more than $5,000 in

contributions in support of his candidacy for the NY-3 congressional seat.10 On April 17, 2021,
Mr. Santos filed his Statement of Candidacy, 11 and by that time, his campaign had raised over
$160,000 in contributions.12 As mentioned above, individuals who become a candidate for the
House of Representatives must file a financial disclosure report (or request an extension) no later
than 30 days after they raise or spend $5,000 toward their House race. 13 Accordingly, Mr. Santos
was required to file his first financial disclosure report by May 15, 2021, and a second financial
disclosure report on May 16, 2022.

Mr. Santos failed to file any financial disclosure report until September 6, 2022 (the
2022 .14 Nor did he seek an extension of his filing deadline. As a result, Mr. Santos
failed to file a single financial disclosure report prior to the Republican primary for the NY-3
congressional seat on August 23, 2022, notwithstanding his status as a candidate for 19 months
prior.15

In his financial disclosure related to his 2020 campaign, Mr. Santos stated that he received a
salary of $55,000 from his then-employer. In his 2022 campaign, however, Mr. Santos donated a
total of $705,000 to his campaign, $580,000 of which was made before he ever filed a financial
3
5 U.S.C.A. App. 4 § 101(c). Congressional candidates must file financial disclosure reports with the Clerk of the
House of Representatives. Id. § 103(h)(1)(A)(i)(I).
4
In 2022, this deadline was extended to May 16 to account for the deadline falling on a Sunday. See U.S. House of
Representatives Committee on Ethics, Instruction Guide - Financial Disclosure Statements and Periodic Transaction
Reports at 2 (2021),
https://ethics.house.gov/sites/ethics.house.gov/files/documents/FINAL%202021%20FD%20Instructions.pdf
5
5 U.S.C.A. App. 4 § 101(c).
6
See id. § 101(c); 52 U.S.C. § 30101(2).
7
5 U.S.C.A. App. 4 § 104(a).
8
Id. § 104(a)(1).
9
Id.; 2022 Civil Monetary Penalties Inflation Adjustments for Ethics in Government Act Violations, 87 Fed. Reg.
2523 (Jan. 18, 2022).
10
See Devolder-Santos for Congress, Amended 2021 April Quarterly Report (May 9, 2022),
https://docquery.fec.gov/pdf/272/202205099502712272/202205099502712272.pdf.
11
See Devolder-Santos for Congress, Statement of Candidacy (April 17, 2021),
https://docquery.fec.gov/pdf/781/202104179443792781/202104179443792781.pdf.
12
See id.; Devolder-Santos for Congress, Amended 2021 July Quarterly Report (September 12, 2022),
https://docquery.fec.gov/pdf/698/202209129528389698/202209129528389698.pdf.
13
5 U.S.C.A. App. 4 § 101(c); see also House Financial Disclosure Instruction Guide at 3-4.
14
Clerk of the House of Representatives, George Anthony Devolder-Santos Financial Disclosure Report (Sept. 6,
2022), https://disclosures-clerk.house.gov/public_disc/financial-pdfs/2022/10050385.pdf
15
See New York Times, New York Third Congressional District Primary Election Results (Aug. 23, 2022),
https://www.nytimes.com/interactive/2022/08/23/us/elections/results-new-york-us-house-district-3.html.
disclosure report for the 2022 election cycle. 16 Federal campaign law requires that candidates
only donate personal funds. By failing to file any financial disclosure report in 2021, and not
filing a report in 2022 until after donating significant funds to his campaign, it is impossible to
know whether Mr. Santos all of a sudden had the necessary resources to make personal
contributions to his campaign of nearly 13 times his previous annual salary.

Accordingly, we ask that you immediately investigate Mr. Santos for his failure to file the
required financial disclosure report in 2021, and for his untimely filing in 2022.

Failure to File Complete and Accurate Reports

contains a number of concerning omissions and potential false statements.

First, the Act requires filers to disclose each financial institution that held deposits valued at
more than $1,000 if the total value of the accounts exceed $5,000 at the end of the reporting
period. 17 In the September 2022 Report, Mr. Santos disclosed a checking account balance of
more than $100,000 and a savings account balance of more than $1,000,000, but he did not
identify the name of either banking institution. 18 Furthermore, the national average interest rate
for savings accounts is 0.19 percent. 19An interest rate of 0.19 percent on an account that has $1
million would provide $1,901.66 in income. The Committee should investigate whether Mr.
Santos failed to properly report interest income as required by law.

Second, the September 2022 Report disclosed that he owned an apartment in Rio de Janeiro,
Brazil valued between $500,000 and $1,000,000. Yet in recent media interviews, Mr. Santos
who at one point had claimed that he owned 13 properties admitted that he did not own any
property at all.20 If Mr. Santos does not, in fact, own any property, then the representation of
ownership over the Rio de Janeiro apartment is false and a clear violation of the Act.

Third, Mr. Santos also disclosed that he received dividends valued at more than $1,000,000 in
both 2021 and 2022 from his s which
21
he formed in May 2021 after he announced his candidacy for 2022. The September 2022
Report d . According to public reports,
the financial data company Dun & Bradstreet estimated that Devolder only had revenue of

16
See Devolder-Santos for Congress, Receipts,
https://www.fec.gov/data/receipts/?data_type=processed&committee_id=C00721365&contributor_name=George+S
antos&two_year_transaction_period=2022; Devolder-Santos for Congress, 2022 Post-General Report at 82 (Dec. 8,
2022), https://docquery.fec.gov/pdf/330/202212089548011330/202212089548011330.pdf.
17
House Financial Disclosure Instruction Guide at 21.
18
George Santos Disclosure Report.
19
See Matthew Goldberg, What is the Average Interest Rate for Savings Accounts?, Bankrate (Jan. 5, 2023),
https://www.bankrate.com/banking/savings/average-savings-interest-
rates/#:~:text=The%20national%20average%20interest%20rate,percent%2C%20according%20to%20Bankrate's%2
0Dec.
20
See Emily Brooks, Eight Outstanding Questions Surrounding George Santos, The Hill (Dec. 28, 2022),
https://thehill.com/homenews/house/3790085-eight-outstanding-questions-surrounding-george-santos/.
21
Id.
$43,688 as of July 30, 2022.22
per year is highly suspect.

Fourth, Mr. Santos recently explained

23
- Yet the Act requires candidate

years that gener

on Schedule J.24
from disclosure but a filer must indicate that certain confidential clients are not reported and state
the specific reason for the nondisclosure. 25

A recent public report identified several purported clients of Devolder as large Republican
donors, which Mr. Santos confirmed. 26 Yet Mr. Santos neither identified any clients for whom he
personally performed services nor indicated that he could not report any clients due to
confidentiality.27

Fifth
preceding calendar year and the current calendar year through the date of filing. 28 Since Mr.

2021 and earned income for January 1, 2022 through September 6, 2022. Yet in Schedule C,
George Santos lists the same exact salary of $750,000 for both 2021 and 2022 (through the date
of filing),29
earned through Devolder.30 Moreover, Devolder was administratively dissolved on September
23, 2022 by the State of Florida because Mr. Santos never filed the required annual statement for
the company,31
any income from it, and the accuracy of the income he allegedly earned and disclosed.

2022, after wide-spread reports that Mr. Santos fabricated aspects of his background and
employment.32
have paid Mr. Santos a $750,000 salary and more than $1,000,000 in dividends.

22
Michael Kranish et al., Rep.-elect George Santos Acknow
finances, Washington Post (Dec. 26, 2022), https://www.washingtonpost.com/politics/2022/12/26/george-santos-
resume-wealth/.
23
See Brooks, supra.
24
House Financial Disclosure Instruction Guide at 39.
25
Id at 40.
26
See Roger Sollenberger, , The Daily Beast (Dec. 28,
2022), https://www.thedailybeast.com/george-santos-massive-campaign-loans-may-not-be-legal.
27
Id.
28
House Financial Disclosure Instruction Guide at 31.
29
George Santos Disclosure Report.
30
See Sollenberger, supra.
31
See Florida Division of Corporations, Devolder Organization LLC,
http://search.sunbiz.org/Inquiry/CorporationSearch/EventHistory?aggregateId=flal-l21000206150-d2719327-f0cc-
424e-8b6c-
04026a110c67&entityId=L21000206150&CurrentPage=0&SearchTerm=DEVOLDER&InquiryType=EntityName
&inquiryDirectionType=CurrentList&SearchNameOrder=DEVOLDERORGANIZATION%20L210002061500&Li
stNameOrder=DEVOLDERLAWFIRM%20L160001128740 (last accessed Jan. 5, 2023).
32
Devolder Organization LLC, 2022 Florida Limited Liability Company Reinstatement (Dec. 20, 2022),
http://search.sunbiz.org/Inquiry/CorporationSearch/GetDocument?aggregateId=flal-l21000206150-d2719327-f0cc-