New here? NUPAC (Northern Utah Legislative PAC) is the fourth Utah leadership PAC documented in this project sharing the exact same treasurer — Kyle Palmer — who also runs House Speaker Leadership PAC and UHREC. All three pay his own company, Irish Elk LLC, for "PAC Administration" and "Fundraising Fees." This page covers what makes NUPAC distinct: its role funding Jill Koford's rise to the Senate seat once held by NUPAC's own co-founder, Ann Millner.
1. What Is This PAC?
NUPAC was created August 20, 2018. Its Statement of Organization lists Sen. Ann Millner (occupation "University Professor" — she was Weber State University's president 2002-2012) and Rep. Casey Snider (occupation "Rancher") as Primary Officers, with Kyle Palmer as CFO/Treasurer. All three officers list the identical phone number on the filing — likely just Palmer's number carried across the form.
Contributions by year. *2026 is partial. 2019 is not yet in hand.
27 of NUPAC's 29 total deleted entries (2022-2025) fall in the exact same report type — the "September 30th" filing — every single year, four years running. That's not scattered deletion noise; it's the identical report period getting scrubbed year after year. What specifically happens around NUPAC's September 30th filings hasn't been established, but the pattern itself is real and repeatable.
2. The Current Open Period
NUPAC's most recent reporting period (6/23-9/2/2026) is not yet closed — this is a running total, updated as new data arrives, not a final report. As of the latest pull it stands at $37,000 across 9 contributions, up from $32,000 as one new entry arrived on 9/2/26.
| Donor | Amount | Note |
|---|---|---|
| National Shooting Sports Foundation | $10,000 | Newtown, CT — firearms industry's national trade association |
| SelectHealth | $5,000 | |
| Lincoln Hill Partners PAC | $5,000 | |
| AFCU Development Fund, Inc. | $5,000 | America First Credit Union's development-fund entity |
| Compass Minerals | $5,000 | New as of 9/2/26 — a salt/minerals company, worth noting given its presence near the Great Salt Lake, an active Utah policy area |
| RAI Services Company | $2,500 | Reynolds American/tobacco — also a repeat UCL PAC donor |
| Comcast | $2,500 | |
| Lumen | $1,000 | |
| Utah AGC-PAC | $1,000 | Third distinct AGC-PAC amount this cycle across different PACs — normal multi-PAC giving, not a data error |
This running subtotal is not an ending-balance figure and should not be combined with the closed-period totals in Section 1 without confirming overlap — a filing-calendar limitation, not something further research can resolve before the next report closes.
3. The Palmer Pattern, Again
Kyle Palmer's role here is structurally identical to House Speaker Leadership PAC and UHREC, already documented elsewhere in this project: Treasurer of the PAC, and separately, principal owner of Irish Elk LLC, which the PAC pays for administration and fundraising work.
The billing structure repeats exactly every year: a modest ~$2,500 "PAC Administration" payment early in the year, followed by a much larger "Fundraising Fees" payment in May or June. This is the same rhythm already documented at UHREC and House Speaker Leadership PAC.
Kyle Palmer holds an officer or treasurer role on at least five Utah PACs simultaneously: NUPAC, UHREC, House Speaker Leadership PAC, UCL PAC, and Adams Leadership PAC. Confirmed payments to Irish Elk LLC across the four PACs with itemized data on file — NUPAC $88,525, UHREC $74,450, House Speaker Leadership PAC $109,225.10, UCL PAC $20,450 — totals $292,650.10, before Adams Leadership PAC is added.
Standard framing used throughout this project: Palmer "controls disbursements" or "serves as treasurer while being paid through a company he owns" — not legal conclusions. Every figure is attributed to the specific filing it comes from.
4. The Koford Pipeline
NUPAC seeded Jill Koford's first HD-10 run in 2022 (a loss to Rosemary Lesser) and her successful 2024 run, giving $42,500 total across five payments. When Millner declined to seek re-election to Senate District 5 in early 2026, Koford — a sitting member of Millner's own Higher Education Appropriations Subcommittee — filed for that exact seat and ran unopposed through convention.
| Source | Amount | Detail |
|---|---|---|
| NUPAC | $42,500 | 5 payments, 2022-2024 |
| Utah House Republican Election Committee | $60,000 gross / $50,000 net | 6 payments; one $10,000 gift was later returned |
| Weber County Republican Party | $28,000 | 3 payments |
| House Speaker Leadership PAC | $27,000 | 3 payments, Schultz's own PAC |
| Wilson Leadership PAC | $20,000 | 2 payments, former Speaker Brad Wilson's PAC |
Combined PAC/party total: $167,500 across five committees (net — the table above already reflects UHREC's $10,000 returned gift). Lifetime totals, all reports 2021-2026: $426,114.03 raised, $330,347.88 spent.
Kyle Palmer's dual role — NUPAC treasurer while directing a state economic office
Palmer served as Associate Director of the Unified Economic Opportunity Commission at the Governor's Office of Economic Opportunity, July 2021-January 2024 — full-time, by his own LinkedIn's description — while simultaneously running Irish Elk LLC and serving as NUPAC treasurer, also described as full-time on the same profile. During that overlap, NUPAC and the Koford campaign combined paid Palmer/Irish Elk $59,531.29.
A same-day round trip involving Stuart Adams
On 6/10/2026, Adams Leadership PAC gave NUPAC $5,000, and the same day NUPAC gave $1,000 to "Committee to Elect Stuart Adams" — money moving from Adams's own leadership PAC, through NUPAC, back to his own campaign committee, same date. This predates his June 23 primary loss.
5. UCL PAC — The Sister Entity
Utah County Legislative PAC (UCL PAC) is a separate PAC from NUPAC, registered 3/9/2025 at the same Layton address, with Palmer again serving as Treasurer/CFO. Its President is Rep. Stephanie Gricius. Palmer's Irish Elk LLC has drawn $20,450 from UCL PAC alone (2025-2026), on the same "PAC Administration" then "Fundraising Fees" cadence.
UCL PAC's donor base overlaps heavily with NUPAC's own world — Clyde Companies, Lincoln Hill Partners PAC, Adams Leadership PAC, and a personal-injury law firm cluster (Craig Swapp, Driggs Bill & Day, Robert J. DeBry, Siegfried & Jensen). It also gave House Speaker candidate committees the identical $1,000 same-day batch treatment already seen at NUPAC and HSLPAC — 20 candidates got $1,000 each in a single 6/3/2025 disbursement.
Several UCL PAC vendors and donors were independently identified this session: Majority 51, L.L.C. (a Provo family LLC run by Richard and Susan Jaussi, also tied to a property-management company, TPM Inc.); Tosh, Inc. (the Rawle family's parent company for Check City payday lending — a real donor relationship, though the specific bill checked against it, SB0230, does not touch payday-lending products); Consultus, LLC and Spring Canyon Capital LLC (both single-owner LLCs, no further connections found).
6. Worth Asking
- This is the fourth Utah PAC in this project sharing the identical treasurer and the identical vendor. At what point does "one consultant serving multiple clients" become a more accurate description as "one person administering a coordinated network of overlapping leadership committees"?
- 27 of 29 deleted entries across four years fall in the same specific report type. What is it about NUPAC's September 30th filings, specifically, that keeps needing correction — and would a reader be able to tell the difference between routine bookkeeping fixes and something else, without the underlying documents?
- Koford's rise traces a specific path: a NUPAC-funded state representative wins the exact Senate seat her own PAC's co-founder is vacating, unopposed. Is that a natural, earned succession, or does the funding relationship itself shape who ends up positioned to run unopposed?
7. Research Status
Still open:
- What specifically happens around NUPAC's September 30th report filings that produces a concentrated deletion pattern every year — not yet established.
- 2019 receipts are not yet in hand, leaving a gap in the otherwise complete 2018-2026 year-by-year total.
- Whether Charles L. Smith ($4,000 to Koford, 5/13/26, her largest single individual gift) can be identified.
- Whether the Kier-family donor cluster ($11,956.19 combined across Koford's filings) connects to Kier Development/Nordic Village PID — a real, documented donor group, not yet confirmed as tied to that specific project.
Sources
- Utah State Elections Office, CFIS campaign finance disclosures — NUPAC's full 2018-2026 DEX exports, Jill Koford's complete 2021-2026 raw DEX exports (846 rows), UCL PAC's 2025-2026 reports
- Go Utah / Governor's Office of Economic Opportunity press release, 8/13/2021 — Kyle Palmer's Associate Director appointment
- Kyle Palmer's own LinkedIn profile — role dates and full-time descriptions
- Utah Division of Corporations — Irish Elk LLC, Majority 51 LLC, Tosh Inc., Consultus LLC, Spring Canyon Capital LLC entity filings
- le.utah.gov — Jill Koford's official sponsor list and committee assignments
- Cross-referenced against this project's own House Speaker Leadership PAC, UHREC, and SD-5 Koford/Hernandez case files
