Candidates should follow these guidelines when participating in 1) joint fund raising efforts with other candidates and 2) in committees that support a slate of candidates.
Open a bank account exclusively for the joint fund raising activities. This bank account will not be registered with PDC. All contribution checks are made out in the name of the joint fund raising account. All joint fund raising expenses are paid out of this account. After expenses are paid, the remaining funds are distributed to all participants on a pro-rated basis. For example, if there are four candidates participating, each receives one-fourth of the net receipts.
Accompanying this payment to each candidate will be a list of contributor names and addresses and the full amount of each candidate's pro-rated share. For example, if a donor gave $500 to the joint fund raising effort of four candidates, the list would show this contributor giving each candidate $125. [Note that if a contributor's pro-rated amount to each candidate is $100 or more and the contributor is an individual, then the candidate will need to report the contributor's occupation and employer in addition to name and address.]
Each candidate uses the information on the list to complete his or her C-3 report that represents the deposit of the check from the joint fund raising account. It is understood that the C-3 will not match the amount of the deposit. (The difference will be the candidate's share of the expenditures for the joint fund raising.)
Then, on the candidate's next C-4, he or she will report on the Schedule A his or her portion of each expenditure made by the joint fund raising account. Again, if there were four candidates participating in a joint fund raiser, each would itemize the expenses made by the joint account showing one-fourth of each expense. Even though each candidate reports his or her share of the expenses on the Schedule A, no actual payment is made by the individual candidates to the vendors involved (since the vendors have already been paid by the joint account).
This method of handling joint fund raising eliminates establishment of a separate joint fund raising committee, while still satisfying the legal requirements that all expenditures be reported and all contributions to the effort are attributed to the individual candidates involved.
Alternatively, each candidate involved in a joint fund raising event could pay a set percentage of the expenses and receive a similar percentage of the funds collected at the event. For example if one candidate were responsible for 60% of the expenses at a joint fund raising event, then that candidate would receive 60% of the funds remaining after expenses are paid. Each candidate committee participating in the event would receive a pro-rated or proportional amount of the funds collected in relation to the expenses paid by that committee.
The law allows candidates to participate in committees organized to support a slate of candidates. Unlike joint fund raising efforts, slate committees do not pass along the money raised to the candidates involved, but rather directly spend the contributions received in a manner that equally benefits all the candidates participating in the committee.
Slate committees register and report like any political committee. On its C-1pc registration statement, a slate committee would check the "other" box in the purpose or description of committee section, and attach a sheet explaining that it is a committee organized to support a slate of candidates. The names and offices sought of the candidates participating would also be listed on this attachment.
The law requires that all contributions made by a contributor directly or indirectly to a candidate be considered as contributions to that candidate. As such, contributors to slate committees are, in fact, giving to the candidates who are participating in the committee. Therefore, prior to the due date of each C-4 report, the slate committee must provide each candidate with a list of its contributors, showing the name, complete address, date and the full amount of the candidate's pro-rated share of each contribution. For example, if a contributor gave $600 to a committee supporting a slate of six candidates, the committee would list this contributor as giving $100 to each candidate. Using the list provided by the slate committee, each candidate will then report, as in-kind contributions in Part 1 of Schedule B, his or her portion of from all contributions to the slate committee. The candidate will note that these contributions are through the slate committee, thus alerting the public that they should look at that committee's report for information on how the contributions were spent.
The slate committee will file regular C-3 and C-4 reports with PDC. The information supplied to the candidates involved is in addition to its regular reporting.