Reston Casino: Developer Linked To Obscure Political Donation, Campaign Filings Show

RESTON, VA — Christopher Clemente, CEO of Comstock Holdings, appears to have used a different entity to make a donation to the campaign committee of a candidate running for re-election in Loudoun County, according to campaign finance filings.

On Sept. 25, Patch broke the news that Comstock, the developer that owns the majority of property at the Wiehle-Reston East Metro Station, was planning to build a casino at or near the station, according to local officials.

On Aug. 31, CRS Commerce Center UB LC donated $10,000 to the campaign committee of Matthew Letourneau, according to campaign finance filings reported by the Virginia Public Access Project.

Letourneau, a Republican, represents the Dulles District on the Loudoun County Board of Supervisors. He faces Democratic challenger Puja Khanna in the Nov. 7 election.

In addition to being the most senior member of the board of supervisors, Letourneau is a member on the Metro Board, which oversees the Washington Area Metropolitan Transit Authority.

In June, Metro laid out a detailed financial plan to remedy structural funding issues that if unfixed will leave the transit system with a projected $750 million shortfall in fiscal year 2025.

Last week, State Sen. Dave Marsden (D-Burke), who chairs the Senate Transportation Committee, told Patch that one of the reasons to put a casino on the Silver Line was to help Metro financially.

Given Letourneau's status as a member of the Metro Board and Comstock's plan to build a casino on the Silver Line, the unusual way the $10,000 was donated deserves a closer look.

A search of the Virginia State Corporation Commission Clerk’s Information System found the following four corporations, which included the one that made the $10,000 donation:

• CRS Commerce Center Holdings
• CRS Commerce Center UB, LC
• CRS Commerce Center VI, LC
• CRS Commerce Center, LC

All four of the companies have the same registered agent, Corporation Service Company [100 Shockoe Slip, floor 2 Richmond, Virginia 23219-4100], and they share the same principal office address: 1900 Reston Metro Plaza 10th Floor, Reston, VA 20190. That address happens to be the same business address as Comstock’s offices at Reston Station.

Reston Casino: Read All of Patch's Reporting:

• Casino Planned Near Wiehle-Reston East Metro Station By Comstock
• Developer Brings Democratic Leaders To Site Of Planned Casino At Metro
• Reston Casino: Developer CEO's Relative Donates $1M To VA Candidates
• Casino At Reston Station: Share Your Opinion In Patch's Online Poll
• Reston Association Votes To Oppose Developer Plan To Build Casino

A search of the four companies on OpenGovUS confirms that Corporation Service Company is their registered agent. However, further down on the page under “Business History,” Clemente is listed as the registered agent and the Comstock offices (1900 Reston Metro Plaza, 10th floor) in Reston are given as the registered agent’s address.

The four companies were also listed on the US Federal Contractor Registration website, which includes information about entities registered to bid on federal contracts.

The physical address given for the four companies is 1886 Metro Center Drive, Floor 4, Reston, VA 20190-5288, according to USFCR, which is a building owned by Comstock. The point of contact is listed as Michael Gualtieri, who is Comstock's chief financial officer.

So far, CRS Commerce Center UB, LC is the only one of the four companies to have donated to any candidate or their campaign committee in 2023.

It wasn’t immediately clear why Comstock may have set up an additional company for donations. Patch reached out to Comstock and Clemente by email for comment about the donation and the four similarly named corporations. As of Monday evening, the request for comment remained unanswered.

"The situation that you're describing here is actually pretty common place, unfortunately," Saurav Ghosh, director of the Campaign Legal Center's Federal Campaign Finance Reform initiative, told Patch on Monday. CLC is a nonprofit that seeks to advance democracy through law.

"One of the main core values that we work to defend is transparency in elections, about who's spending money to influence their outcome or to influence the voters to vote one way or another," he said.

Ghosh explained that corporations or even wealthy individuals who have certain political goals may try to conceal their political contributions.

"For optics reasons or to avoid the perception that they're trying to essentially put a finger on the scale to achieve their desired policy outcomes, they often will try to conceal the fact that they're making a political contribution to crucial, influential policymakers or even to sway a ballot measure one way or the other in the hopes of advancing their company's goals," Ghosh said. "They often will try to avoid that being done openly and transparently."

In federal elections, it would be illegal for a company to set up a new entity, transfer money into it, and then have a shell company make contributions, while keeping the identity of the parent company hidden, according to Ghosh.

Since CRS Commerce Center UB, LC's contribution was made to a local official rather than the U.S. president or a member of Congress, the donation is regulated under state election law.

"Virginia is a fairly deregulatory state on campaign finance," Ghosh said. "They're no contribution limits. Contribution limits and corporate prohibition, these are things that states sometimes don't have. I think that's fine, but I'm not really familiar with any state that says, 'There's no need to disclose.' Disclosure and transparency are generally seen as less burdensome, less of an infringement if states want to view it that way, and key to voters being able to meaningfully vote."

Clemente and Comstock may well have been within their rights in making the donation the way they did under Virginia law.

Supervisor Letourneau told Patch on Monday that he was aware of the $10,000 donation from CRS Commerce Center UB LC, and he knew that it had come from Comstock.

"I'm not sure exactly why the donation was made. I think they support me in general, obviously, but I haven't had any specific discussions about any of those things," he said, referring Comstock's casino plans.

Patch asked Letourneau whether he thought the donation was meant to influence him in his role as a member of the Metro Board.

"In terms of Metro, we have an ethics protocol," he said. "I already have reported this donation through the board ethics process, and then I will rely on the ethics counsel to guide me if there's ever an issue that comes up that I either need to disclose or need to recuse myself from."

While the donation was not reported on the most recent disclosure form, Letourneau said it would appear in the next one.

As a supervisor, Letourneau has worked with Clemente on the Ashburn Metro Station development as well as other projects, but he doesn't know why Clemente made the contribution.

"We've had a longstanding relationship and worked together on some of these things," he said. "But that said, I've never made any specific promises to Chris Clemente or any other developer. People in the development community know, I call them like I see them. I don't always vote the way that they want me on particular applications and issues."