PACs — Dark Money and Felon Treasurers
Overview
Three political committees connected to the Banks network — two traditional PACs and one 501(c)(4) dark money organization. Convicted felons serve as treasurers and officers across all three.
Bank on Banks for Michigan
| Field | Value |
|---|---|
| Treasurer | Joseph Holland (drug trafficking conviction) |
| Total raised | $22,225 |
| Campaign finance fines | $14,500+ |
Holland — a convicted drug offender (Controlled Substance — Possession) — serves as treasurer for this PAC while also holding Secretary and Treasurer positions at Purpose Foundation.
Bank on Wayne County
| Field | Value |
|---|---|
| Treasurer | Brian Roderick Banks (9 convictions) |
Banks serves as treasurer for this Wayne County-focused political committee while simultaneously running charter schools and management companies in the same jurisdiction.
OFA Michigan (501(c)(4) Dark Money)
| Field | Value |
|---|---|
| Type | 501(c)(4) social welfare organization |
| EIN | 87-2342269 |
| Address | PO Box 361183 |
| Officer | Joseph Holland |
OFA Michigan operates as a dark money vehicle — funding political mailers without the disclosure requirements of traditional PACs. Holland serves as an officer.
Violations Summary
| Committee | Violation | Amount |
|---|---|---|
| Bank on Banks for Michigan | Campaign finance fines | $14,500+ |
| Bank on Banks for Michigan | Holland as treasurer | Felon in fiduciary role |
| Bank on Wayne County | Banks as treasurer | Felon in fiduciary role |
| OFA Michigan | Dark money operations | Undisclosed mailers |
Network Structure
Bank on Banks for Michigan ── Holland (treasurer) ── $14,500+ fines
Bank on Wayne County ──────── Banks (treasurer)
OFA Michigan (501c4) ──────── Holland (officer) ─── dark money mailers
Verify
- Michigan campaign finance: cfrs.michigan.gov
- IRS EIN lookup: apps.irs.gov/app/eos — EIN 87-2342269
All sources are public records. Full documentation in the git repository.