Since it was definitely, one way or another, influencing the campaign, it was a contribution. Spreading it out over time would make it a loan, definitely a contribution, regardless of whether Trump knew & approved. Way above the individual limit. Spreading it out and tucking it away just adds fraud to the list. Possibly wire fraud. If Trump or his campaign consulted on spreading it out and obfuscating the purpose, add conspiracy to the list.
The things that many people are weighing as mitigating factors or cleverness really just adds up to deeper doo-doo.
The best hope they have, IMO, is to put the whole thing on Trump himself. The FERC is 50-50 Dem-GOP, which means that they won’t be able to put together a majority against him. They’ll throw the book at Cohen.
