None of the money the two groups have raised went directly to Trump or his campaign during the 2020 cycle. Even though Tunstall reports on his federal filings that his PACs have spent approximately $407,000 toward supporting Trump, a close analysis of those independent expenditures shows that approximately $380,000 of that money was spent on robocalls and operating expenses; about $27,000 was spent on advertising.

Tunstall, meanwhile, has been paid nearly double what he claims to have spent on supporting Trump.

Tunstall told CNN at the time that the robocalls using Trump’s voice were the result of a technical error and that his PAC had ceased to use calls like it. But he kept at it and over the next two years built the most prolific political robocall campaign in the country, according to data shared with CNN from NoMoRobo, a widely used application that blocks robocalls.

Tunstall’s two Trump PACs have placed an estimated 3.48 billion robocalls since October 2019, according to NoMoRobo. That averages out to about 184 million robocalls every month to Americans’ phones across the country.

Tunstall did not reply to CNN’s numerous attempts to contact him for this story.

A system ripe for abuse

PACs have been around since the 1940s and were designed to pool donations in support of a candidate or a cause. But in recent years, so-called scam PACs have become more prevalent.

Adav Noti, the senior director of litigation at the Campaign Legal Center, says a scam PAC is typically seen as one that “exists primarily to raise money that is then paid to the PAC’s own operators rather than to engage in bonafide political activity.”

There is no hard-and-fast rule that limits how much an operator can pay themselves, nor is there a legal definition of what exactly constitutes a scam PAC, making the line between what’s legitimate and what’s not fuzzy and hard to enforce.

“Self-enrichment is the defining characteristic of a scam PAC, regardless of what they’re saying they’re doing or in fact doing with the money,” said Paul S. Ryan, the vice president of policy and litigation at the watchdog group Common Cause. “Just saying that you spent the money on robocalls doesn’t negate allegations of scam PAC-i-ness.”

The Federal Election Commission, which regulates PACs, lacks criminal enforcement authority, leaving it up to the Department of Justice to bring prosecutions, and so far, the nation’s top law enforcement agency has focused on the most extreme violations, according to experts.

The Justice Department told CNN that it does not track the number of scam PACs it’s prosecuted. Noti, who tracks scam PACs closely, estimated that DOJ has prosecuted one to two cases a year over the last few years.

Experts who spoke to CNN said that Tunstall’s filings demonstrate the hallmarks of a scam PAC, which comes down to self-enrichment. His PACs appear to follow a simple, cyclical pattern: they raise money to pay for robocalls so they can raise more money to pay for more robocalls. Nearly all of the money not used to sustain the PACs goes toward paying Tunstall. Even the paperwork the PACs are supposed to file regularly with the FEC raises serious concerns, according to experts, and the PACs frequently miss reporting deadlines.

Tunstall has faced practically no consequences. The FEC has written his PACs more than two dozen letters raising issues with the PACs’ filings and has levied a little more than $14,000 in administrative fines against him. Tunstall has paid just $10 toward those fines and has avoided any civil or criminal penalties.

Tunstall’s operation is so egregious, it “could almost be construed as a performance art piece designed to showcase the FEC’s fecklessness,” said Rob Pyers, a campaign finance researcher who tracks scam PACs on Twitter.

“Hundreds of thousands of dollars of cash-on-hand have vanished off the ledger from one reporting period to the next,” said Pyers. “None of the expenditures during their first year of operation are accounted for, and about a third of the operating expenditures they have deigned to report have gone to enrich the PAC’s founder.”

To Pyers, though, the most recent amendment to Tunstall’s paperwork is another example of how his record-keeping is a “trainwreck.”

“Who knows what the cash situation actually looks like?” said Pyers.

“Hi, This is Donald Trump.”

When someone answers one of Tunstall’s robocalls, they are usually greeted by a recording of the former President saying, “Hi, this is Donald Trump.”

Typically, the calls splice together recordings of a series of public statements made by Trump. A narrator then urges listeners to donate to support Trump by pressing a number on their keypad. Those who do are transferred to a call center where they sometimes donate as little as $1 and as much as $8,000.

“This was a technical error if you heard this, there were many different variants that have been recently tested for different political ads regarding support for President Trump,” Tunstall wrote CNN in an email in 2019. “I’ve been instructed by multiple legal sources that using voice clips from politicians is acceptable and not considered ‘impersonating’ because politicians are public officials and do not have rights to their likeness like normal private citizens and celebrities do.”

Since then, the calls have included a sped-up recording at the very end that discloses the true nature of the robocall, telling listeners in a voice very quickly: “Paid for by Support American Leaders. Not authorized by any candidate or candidate committee.”

The phone number listed for Tunstall’s PAC in the calls is not a working number. Nor are numbers on the website for Support American Leaders PAC. His PACs can only be contacted one way: if you receive a call and are connected to the call center soliciting donations.

The period after the 2020 election in which one PAC parroted election lies proved to be one of the most lucrative fundraising periods. In just a few weeks, Support American Leaders raised $536,000.

Tunstall paid himself almost $177,000 during that period.

Late filings and $500,000 in missing money

A closer look at Tunstall’s PACs’ FEC filings reveals, at best, late paperwork and, at worse, missing funds.

During 2020, quarterly filings were routinely submitted months after they were initially due to the FEC. In one case, the PAC missed an FEC filing deadline by eight months.

The FEC sent four letters to each of Tunstall’s PACs notifying them they failed to submit their 2020 reports on time and warned that the PACs could face administrative fines.

A CNN KFile examination of the Support American Leaders PAC filings reveals that between the spending, filings and cash-on-hand, more than $500,000 is unaccounted for.

Among the dozens of letters the FEC has sent to the two PACs, one letter specifically noted the discrepancies between the cash-on-hand numbers between the 2019 filings referenced.

The law forbids the commission from disclosing any audits or enforcement actions until after the process is completed.

A symptom of a broken system

Election law experts see PAC operators like Tunstall as a symptom of an FEC that over the past decade has become dysfunctional thanks to fierce partisan deadlock, rendering it incapable of using the few tools it does have to regulate scam PACs. The result is a corner of the election economy where Tunstall can brazenly defraud people of millions of dollars.

“People complain to the FEC all the time about [scam PACs]. It’s a scourge of the current finance system,” said Noti, of the Campaign Legal Center, who previously worked in the FEC general counsel’s office. “The FEC doesn’t crack down on anything, but this, they would crack down on if they could.”

“It’s a matter of getting a law on the books that would let the FEC do it,” Noti said.

It may be years until the public has a clearer picture on whether the FEC ends up taking any enforcement action against Tunstall because their enforcement actions are confidential until complete.

It’s also possible he also may shut down his PACs before they are able to.

Some experts speculate that Tunstall’s recent actions, including his decision to list a negative balance for his PAC, could be part of a potential exit strategy where he shuts down his robocall operation and declares bankruptcy. Other experts suggested Tunstall’s actions followed a pattern of egregious bookkeeping and that it was unclear what the recent filings meant.

But a worst-case scenario, according to Ryan, who heads the watchdog group Common Cause, would play out like this: the FEC fines would continue to grow but a PAC “so deep in the red could just shut down. It could close its bank account, close its office or P.O. Box and, for all intents and purposes, disappear,” said Ryan.

And because PACs are typically corporations, said Ryan, “The people who set up the PAC are only personally financially liable under campaign finance law if they’ve knowingly and willfully violated the law.”

Tunstall, meanwhile, could continue to escape consequences from the FEC and any creditors the PAC may owe money to.

CNN’s Peter Valdes-Dapena contributed to this story.