# Safety and Affordability PAC 22.4M House IE October 2026
On **2026-10-28 and 2026-10-29**, [[Safety and Affordability PAC]] (FEC **C00960443**) spent
**$22,415,534.51** on independent expenditures across **23 House candidates in nine states**, disclosed
on one 24-hour notice — **file 2043989**, form `F24N`, received **2026-10-29T19:58:37**.
**Four weeks earlier this committee's entire disclosed existence was a single $1,281,250.00 notice.** It
has now filed $17.0 million ([[Safety and Affordability PAC 17M Multi-Race IE October 2026]]) and
$22.4 million within seven days of each other, and **its funders remain undisclosed and will stay that
way until after the votes are counted.**
## 🔴 42% of it is reported as dollar-matched pairs
| Race | Supported | Opposed | Amount each |
|---|---|---|---|
| NY (House) | [[Mike Lawler]] | [[Cait Conley]] | $1,496,250.00 |
| AZ (House) | Thomas James Feely | Amish Shah | $1,411,078.00 |
| OH (House) | Derek Merrin | [[Marcy Kaptur]] | $620,280.00 |
| NY (House) | [[Mike Lawler]] | [[Cait Conley]] | $450,000.00 |
| NY (House) | [[Anthony Constantino]] | [[Blake Gendebien]] | $360,000.00 |
| AZ (House) | [[Juan Ciscomani]] | Joanna Mendoza | $187,500.15 |
| NC (House) | [[Laurie Buckhout]] | [[Don Davis]] | $114,666.66 / $114,666.67 |
| NC (House) | [[Laurie Buckhout]] | Tom Bailey | $114,666.66 / $114,666.67 |
**Mirrored dollars: $9,508,882.96 — 42.42% of the notice.** Eight pairs, each putting an identical sum
for one candidate and against an opponent, almost always to the cent.
⚠️ **What this does and does not mean.** The pairs are **not double-counted**: each line is a genuine
Schedule E item and the notice total includes each once. What they break is the *reading* of a
support/oppose split. When one invoice is reported as two lines facing opposite ways, a figure like
"$X spent against candidate Y" describes an accounting convention as much as an advertising buy. Any
support-versus-oppose total drawn from a notice reported this way is softer than it looks.
**The North Carolina triple is a shape this wiki has not recorded before.** One $114,666.66 line
supports [[Laurie Buckhout]] while **two** lines of $114,666.67 each oppose two different candidates —
[[Don Davis]] and Tom Bailey. A single sum split three ways across one race.
**It is the second committee to report this way, and both use the same compliance shop.**
[[No Going Back PAC]] carried fourteen such pairs worth $4.1 million on
[[No Going Back PAC 34.9M Multi-Race IE October 2026]]. Both committees file from
**C/O Bulldog Compliance, 100 Cummings Center, Beverly MA**, with **Charles Gantt** as treasurer. That
makes the pattern most likely **one compliance shop's bookkeeping convention** rather than two
committees independently inventing it — which is the narrower, duller and better-evidenced explanation.
It establishes no coordination between the committees.
## Where it went
| State | Amount | Share | Lines |
|---|---|---|---|
| New York | $4,733,780.31 | 21.12% | 7 |
| Michigan | $3,483,062.80 | 15.54% | 2 |
| Arizona | $3,197,156.30 | 14.26% | 4 |
| Ohio | $2,780,188.20 | 12.40% | 4 |
| North Carolina | $2,684,060.30 | 11.97% | 5 |
| Colorado | $1,681,873.00 | 7.50% | 3 |
| Maine | $1,638,007.20 | 7.31% | 2 |
| Wisconsin | $1,617,407.00 | 7.22% | 2 |
| Pennsylvania | $599,999.40 | 2.68% | 2 |
| Direction | Amount | Lines | Share |
|---|---|---|---|
| Opposing a candidate | $17,775,759.70 | 24 | 79.30% |
| Supporting a candidate | $4,639,774.81 | 7 | 20.70% |
**The largest single line is $3,053,062.80 against William Lawrence** in Michigan.
⚠️ **A filing names a candidate, a state and an office; it does not give a party.** For the party and
standing of any candidate above, see that race's own page.
## Two firms placed 99.5% of it
| Payee | Amount | Share | Lines |
|---|---|---|---|
| [[Del Ray Media LLC]] | $16,043,747.00 | **71.57%** | 22 |
| [[MHB Media Inc]] | $6,250,507.20 | **27.88%** | 8 |
| Whistlestop Strategies LLC | $121,280.31 | 0.54% | 1 |
**This is the tightest vendor concentration on any eight-figure notice in the window** — two firms, 30
of 31 lines, 99.46% of the money. It is the same pair, in the same order, as the committee's
$17.0 million notice seven days earlier, where [[Del Ray Media LLC]] took 78.4% and
[[MHB Media Inc]] 21.6%.
[[Del Ray Media LLC]] also placed **$16,085,911.15** for [[Congressional Leadership Fund]] on the very
same expenditure date ([[CLF 39M House IE October 2026]]) — **$32.1 million for two committees in one
day**, and the two committees' target lists overlap on [[Don Davis]], [[Cait Conley]],
[[Rebecca Cooke]], [[Manny Rutinel]], [[Marcy Kaptur]], [[Christina Hines]], [[Bob Brooks]],
[[Paige Cognetti]] and Amish Shah — nine of this notice's twenty-three candidates.
**That overlap was already on the record.** The committee's own page recorded in early October that its
first three targets were all on CLF's list. It is now nine, at twenty times the money, through a shared
buyer. The wiki records this as procurement overlap and target convergence; **it establishes no
coordination**, and a shared media buyer is a commonplace of this industry.
## Why it matters
**A committee with no disclosed funders is now spending at party-committee scale.** $39.4 million
across two notices in seven days puts [[Safety and Affordability PAC]] within striking distance of
[[Congressional Leadership Fund]]'s own daily rate, with none of the disclosure. Its first Form 3X —
the report that would name who paid for it — is not due until after the election.
**Where it is spending is as telling as how much.** Nearly $4.7 million into two New York districts, in
a notice that also supports [[Anthony Constantino]] on the same day he put
**$1,000,000 of his own money** into his campaign ([[Constantino 1M Self-Funding NY-21]]).
## Verification
All 31 Schedule E lines are unflagged originals on an `F24N` notice: no amendment form code, no memo
code (field 42), no duplicated line, one election code (`G2026`). Thirty lines are dated **2026-10-28**
and one — a $430,000.00 Colorado line — **2026-10-29**. The notice totals **$22,415,534.51**, and the
per-state, per-candidate and per-payee tables above each reconcile to it to the cent. The mirrored-pair
figure is derived from the support/oppose indicator (field 26) and the line amounts, pair by pair.
⚠️ **First read.** Derived on 2026-10-30 from the first full day of a restored FEC filing index; see
[[FEC Electronic Filing Outage October 2026]]. Form 24 notices are re-checked at T-2 and T-3 for late
arrivals and amendments.
## See Also
- [[Safety and Affordability PAC]] · [[Del Ray Media LLC]] · [[MHB Media Inc]]
- [[No Going Back PAC 34.9M Multi-Race IE October 2026]] · [[CLF 39M House IE October 2026]]
- [[Constantino 1M Self-Funding NY-21]] · [[NY-21-2026]]
- [[Independent Expenditure]] · [[Super PACs]] · [[Dark Money]] · [[2026 Midterms Hub]]