Hard to tell what advocacy group is doing with millions in donations from Combs’ campaign funds

Susan Combs

Former state Comptroller Susan Combs found herself out of office in 2015, sitting on $5.6 million in campaign finance funds.  She left the door open to other political possibilities, including a run at lieutenant governor.

But in June 2017, three weeks before the Trump administration nominated her as an assistant secretary for policy in the Department of the Interior, Combs gave $2 million of her campaign money to a nonprofit she established after leaving office.

With that, the Anywhere Woman Project went from Combs’ marginally funded group aimed at advancing women in business into a moneyed special interest player in the tax-exempt world.

The Anywhere Woman Project, registered as a 501(c)4 organization with the Internal Revenue Service, was launched in 2015 with $300,000 from Combs’ campaign fund with the purpose “to promote women … to help them recognize and seize opportunities … .” She gave another $950,000 to the group in 2016. 

Under IRS rules, 501(c)4 groups, known as social welfare operations, are allowed to give as much as half their money to political causes. Planned Parenthood and the National Rifle Association are famous 501(c)4s. Unlike 501(c)3 nonprofits, the groups are not obligated to give any of their money to charity, and they are also allowed to spend money on lobbying.

The group’s registered agent, Pate Garner, is a lobbyist whose 38 clients during the Texas Legislature’s last session included Airbnb, AT&T, police pension boards in Dallas and Houston, and Marathon Oil.

The use of leftover campaign funds to establish a 501c4 is rare, noted Ed Shack, a veteran Austin ethics attorney. But it’s also most likely a permissible use of the money.

“The restriction on the use of political contributions is [against] personal use,” Shack said. “You have six years to spend that money, and the personal use statute means spending it to benefit yourself or your family. That’s the regular standard.”

The 501(c)4s are established to do advocacy, Shack said.

“I can see that would be interpreted as proper use,” he said of Combs’ operation. “But it is unusual.”

Combs, who also spent $190,000 of her leftover campaign money to fund a website that compares and ranks K-12 schools, has exhausted the $5.6 million campaign fund she amassed during her eight years each as comptroller and agriculture commissioner.

But records show that while Combs insisted that she was spurred to fund her new endeavor due to outrage over comments made in the wake of a local election in Austin, she had instead considered her new organization for some time.

Combs, who did not respond to an emailed interview request for this story, told the Texas Tribune in 2016 that she started the Anywhere Woman Project after reading a news story about the first majority-female city council in Austin, elected in May 2015.

A consultant quoted in the story advised male council members to expect a lot of questions and noted that “women don’t want to deal with numbers.”

“That got me so angry,” Combs told the Tribune. “I thought, what were we doing in 2015 if we treat women as second-class citizens?”

However, records show that the Anywhere Woman Project was formed in April 2015, a month before the consultant meeting Combs cited to the Tribune was held.

It also takes months, at the least, for an organization to be granted nonprofit status by the IRS.

A woman answering the phone at Anywhere Woman Project said she was unable to answer any questions about the group.

In the first two years of the group’s existence, the Anywhere Woman Project gave out one $26,000 grant, according to the most recent tax filing available. That money went to Women’s Leadership Live, a group co-founded by Trump cabinet member Linda McMahon, head of the federal Small Business Administration. The organization aims to promote female entrepreneurship. Combs is a member of the Women’s Leadership advisory team.

Records show Anywhere Woman has trademarked several phrases, including “Where Women Dare” and “Herdacity.” The latter is an assumed name (called a DBA) of Anywhere Woman and an online portal that backs the activities of the Anywhere Woman Project.

Combs last year also dissolved her political action committee, called Texans for Positive Economic Policy. She gave $29,000 from the PAC to the Anywhere Woman Project.

The PAC took in $1.5 million in its three years and spent most of it on research, according to the group’s 990s – the nonprofit form for reporting income for tax purposes. Much of the research money went to the Texas A&M Office of Sponsored Research.

A Texas A&M spokeswoman did not respond to an email seeking comment. PAC records filed with the IRS say nothing about the purpose of the sponsored research.

Like the Anywhere Woman Project, the PAC’s donations were few. Among the recipients: the Texas Republican Party ($25,000), Lubbock’s Bayer Museum of Agriculture ($75,000) and the Mountain States Legal Foundation ($60,000), a conservative, nonprofit legal services group that has advocated in the past for the Second Amendment and claims to battle what it portrays as “government overreach” in land cases.

On federal political contribution forms since she retired, Combs has described herself as “retired” and as a “consultant/rancher,” “investments rancher” and “volunteer.”

Steve Miller can be reached at [email protected].


  1. Same woman whose office seems to have trouble returning funds to spouses and other family members from unclaimed funds.Yes, that’s her.


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