November 25, 2019

CREW called on the Department of Justice and the Office of Government Ethics to investigate Trump’s failure to report receiving pro bono legal counsel from Rudy Giuliani and making a loan to Trump International Golf Club Scotland Limited (“Trump Aberdeen”), on his public financial disclosure. 

On the news, Giuliani has repeatedly boasted about the legal services he provides for Trump. Based on the hourly billable rate charged by major law firms, in some cases more than $1,000 per hour, the value of Mr. Giuliani’s pro bono legal services to President Trump clearly would exceed the maximum threshold of $390 for gifts that can go unreported.

Similarly, the loan of over $50 million that Trump Aberdeen reportedly received does not appear on its financial statements as a loan from any Trump Organization company. Rather, Trump Aberdeen’s financial statements name “Mr. DJ Trump” personally, which would indicate that the loan was a personal loan from Trump himself. Trump is obligated to report personal loans of that size as an asset.

This would not be the first time that Trump has failed to report gifts or loans on his public financial disclosure report. In 2018, CREW filed a complaint over Trump’s failure to disclose a liability to his then-personal attorney Michael Cohen for a $130,000 hush money payment to adult film actress Stormy Daniels shortly before the 2016 election. OGE determined that Trump was required to disclose the liability and referred the matter to the DOJ.

Trump’s failure to disclose these huge loans and gifts on his tax returns needs to be investigated since his omission seemingly violates the law and undermines the integrity of the public financial disclosure reporting process.

Read the complaint here.