A Miami-Dade Commission candidate took ‘invisible money’ from 2nd Amendment group linked to state GOP

Grant Stern
8 min readOct 2, 2020
Right: Miami-Dade Commission Candidate Raquel Regalado. Left: The UPS Store location of the Foundation for America’s Families in West Palm Beach, Florida.

A dark money group promoting Second Amendment rights and school choice, which is tied to the state GOP’s top politicians just donated a significant sum of cash to a struggling Miami-Dade Commission candidate’s Political Committee.

Former Miami-Dade School Board Member Raquel Regalado is facing a cash deficit in her race against former State Rep. and Pinecrest Mayor Cindy Lerner. But her newest pro-gun rights donor is so dark that the 501c4 social welfare organization, Foundation for America’s Families (FFAF) may represent an entirely new form of secret political financing, which I am labeling ‘invisible money.’

In fifteen years, Regalado’s big last-second donors have filed precisely one tax return with the IRS. Based solely on that return and open source information, the cash trail points squarely at the Republican Party of Florida’s leadership.

The candidate confirmed the source of funds in a telephone interview.

“It might be something from Tallahassee,” said Raquel Regalado on the phone while claiming there were bigger checks in this PAC from others in this last report.

There are not.

This summer, the Foundation for America’s Familie cut a pair of large checks to Regalado’s Citizens for Excellence in Miami-Dade Government chaired by Roland Sanchez Medina.

Regalado’s committee took the $20,000 in the form of two checks on August 31st and September 10th, 2020. That money comprised almost half of her last reported $41,000 haul, and for the last two years represents 14% of its $143,000 dollar haul for this year’s campaign.

FFAF donated one out of every seven dollars

Importantly, Raquel Regalado also confirmed by phone that she is registered to fundraise for her political committee (PC) named Citizens for Excellence in Miami-Dade Government. She had filed a financing statement this March saying that she raises money for this PC, but it was very poorly legible.

What makes these donations to her especially significant is that the Foundation for America’s Families has become the largest single donor to Raquel Regalado’s PAC by spending more than double the dollars of the next closest real estate developer or lobbyist. They paid out four times what even the NFL’s Miami Dolphins delivered to a candidate who could ultimately oversee the team’s high-maintenance relationship with the county.

Further investigation revealed the dark money trail ultimately leading right back to the highest levels of the state Republican Party establishment and Public Concepts LLC, a longtime Republican political consultancy before Regalado was contacted for comment.

“Voters will have a clear choice, my opponent who tries to hide her support by gun groups, or myself,” says her opponent Mayor Cindy Lerner, “who is supported by the organizations and elected officials who are dedicated to fighting against the impact of sea-level rise in our county and for equality for everyone.”

After asking her if she knew that a storefront foundation headquartered at a UPS Store just made a massive donation to her campaign, Raquel Regalado temporized rapidly, saying “Rolando Sanchez-Medina deals with it, he’s a Democrats.” She then pointed out that she and her opponent shared a couple of other donors in common, but didn’t address the substance of my question any further.

“I’ll get back to you after my radio program,” Raquel Regalado concluded at the end of our phone call.

She followed up via text message that afternoon when I shared my notes of our earlier discussion by falsely claiming via text that she was under the belief that our prior conversation was “off the record” when absolutely nothing would have indicated that, not in word nor in a written message. That’s when Raquel Regalado said she reached out to Sanchez-Medina.

Then, Regalado complained that this report would make her race partisan, notwithstanding her decision to seek funding from the state Republican Party apparatus.

Finally, she unleashed a fusillade of allegations against her opponent, without any supporting documentation or evidence. Given another 36 hours to comment with a formal statement, Regalado did not reply. I did not contact her PC chair since she indicated they had already discussed the issue. This is an extraordinary amount of time to provide a politician to produce their formal statement, but Raquel Regalado had no further comment.

The illustrious headquarters of the Foundation for America’s Families since 2015

The innocuously named Foundation for America’s Families (FFAF) is based in UPS store #427, located in a West Palm Beach, Florida strip mall.

It is a 501c4 social welfare organization nonprofit and has no significant paper trail aside from its corporate filings with Florida’s Secretary of State, a single tax filing since 2005. The Foundation doesn’t have a website or any other discernable public presence.

Its tax filings cite the group as a 2nd Amendment Rights group, in addition to advocating for school choice, family values, lower taxation, and several other generic goals listed for the sake of qualifying as a non-taxable entity with the IRS.

Excerpt the Foundation for America’s Families 2018 IRS form 990 showing their mission statement.

Based upon FFAF’s donations to Raquel Regalado’s PAC, it also appears that the Foundation could be falsifying its address in its corporate filings.

That’s because the reported address on their donations to Raquel Regalado doesn’t match its headquarters at UPS Store #437, but rather points to an office park in West Palm’s JFK North Medical Center, 5730 Corporate Way, Suite 214, West Plam Beach, FL 33407. Filing intentionally false information with the Florida Secretary of State is a third-degree felony.

Of course, it could be an entirely accidental disclosure of its real address, because public records tie the group’s JFK North office park address to a major GOP political consultancy favored inside the highest levels of Florida’s Republican politics.

Since 2005, the IRS website for nonprofit tax filings shows that FFAF has only filed a single return for the 2018 calendar year.

Considering its long history and only having a single tax return filed puts the Foundation for America’s Families prospectively behind its filing for the tax years 2015–2017. With nothing on file for 2019, it means that nobody knows what the FFAF has been doing, or who is donating to the group over most of the most recent five-year period when it has been active.

In fact, FFAF reported on their sole tax return having $100,196 cash on hand at the start of 2018, and over $47,000 in expenses in 2017, despite not having filed a prior tax return.

Then in 2018, they magically obtained $700,000 in revenues with no listed donors on their tax returns. Those funds were spent in the amount of $494,905 on expenses though its directors — including Mrs. Dolbow — reported no income for their labors. Additionally, FFAF’s listed an expense of $115,000 for “consulting” without a detailed breakdown and $5,445 for “direct mail,” even though it has no website or discernable public presence.

However, the Foundation’s largest single reported disbursement in the last fifteen years of $315,000 went to a 501c3 charity named the Foundation for Equality in Jupiter, Florida. Based inside the lovely cul-de-sac home with boat launch on the Loxahatchee River of one Richard Myers Johnston, a real estate broker with 30-years experience, the Foundation for Equality appears to have no publicly visible acts whatsoever.

The Foundation For Equality has also only filed one single tax return in its existence, where it discloses to the IRS that it’s a charity entirely run by members of the Johnston family.

But Richard Johnston is no stranger to politics. He is one of two partners in the GOP consulting firm Public Concepts, LLC, founded in 1991, which at one point operated in 25 states. Its website consists of nothing more than a contact form with its address 5155 Corporate Way, Suite D2, Jupiter, Florida.

While Public Concepts’ known address is in Jupiter, near Mr. Johnston’s home, Yelp.com associates the political consulting firm with the same 5730 Corporate Way, Suite 214, West Palm Beach address listed on Raquel Regalado’s donations. There is a reasonable explanation for that association since Palm Beach County property records list the 5730 Corporate Way office condo’s owner R&R Partners with the same address listed on Public Concepts’ website. R&R’s Secretary Richard M. Johnston signed the condo association’s certificate of approval in 1996 when his partnership bought the property.

There is another set of telling links between the FFAF and the state’s Republican Party of Florida that runs through the now-defunct Republican PAC Citizens First.

Former Florida Senate Majority leader Bill Galvano was one of the major contributors to Citizens First, which in turn hired Johnston for most of its political advertising work, according to Politico.

FFAF’s longest-tenured director and incorporator, Kathy Dolbow, is an accountant for Public Concepts according to her LinkedIn profile.

While Dolbow was running Citizens First as its treasurer, she was slapped with a Florida Election Commission complaint and audit. Then Dolbow had the privilege of being represented by the Florida GOP’s notorious former General Counsel, one with an unforgettable name in state politics, Emmett “Bucky” Mitchell IV.

Among Bucky Mitchell’s many claims to fame as a lawyer, he got caught authoring a voter suppression bill while serving as the Florida GOP’s general counsel. It’s pretty unlikely that Mitchell’s involvement with FFAF would happen were Dolbo not running Florida GOP affiliated entities. Florida’s Democratic political groups would definitely not hire a lawyer best-known for conducting a voting roll purge during the 2000 election from inside the Jeb Bush Administration in order to favor George W. Bush over Al Gore.

The rest of the FFAF’s listed payouts give more oblique clues to the shopping mall-based foundation’s political aims. Another $20,000 cash injection from FFAF landed in the Florida Education Empowerment Political Action Committee (FEA PAC). That’s a DC-based Florida PAC that donated over $400,000 to the state-level Florida Republican Senatorial Senatorial Campaign Committee during the last election cycle. Tampa venture capitalist John Kirtley runs the FEA PAC to advocate for school choice and vouchers for kids to skip public schools and attend private charter schools on the taxpayer dime. Kirtley’s PAC donated over $5 million to charter school advocates across Florida just from 2010–2017. Step Up for Students is the private company Kirtley founded to administer the scholarships and served as vice-chairman of the American Federation for Children, a charter school advocacy group formerly led by current Secretary of Education, Betsy DeVos. The Foundation also disbursed a $25,000 grant to “Floridians Against Guns,” which is odd for a group founded ostensibly to promote Second Amendment rights. Lastly, the city of Bradenton, Florida, benefitted from a $20,000 grant from FFAF for unspecified reasons.



Grant Stern

Miami based columnist and radio broadcaster, and professional mortgage broker. Executive Editor of OccupyDemocrats.com. This is my personal page.