Occasionally, a candidate or committee receives money that is not a contribution. Typical examples are bank interest, vendor refunds, and a reimbursement from another campaign for shared expenses. These funds are deposited in the campaign bank account and reported as an "other receipt" on a C-3 report.
What is Not a Contribution
This list describes things that are not reportable as a contribution and do not count against a contributor's limit:
- A contribution that is returned to the contributor within ten business days of receipt.
- Ordinary home hospitality, including coffee hours, cocktail parties, wine and cheese parties and similar gatherings where the purpose is to meet the candidate or organize a campaign and where no admission fee is charged or contributions expected from those attending.
- Personal services of the kind commonly performed by volunteers so long as no volunteer is being compensated by anyone in connection with his or her volunteer activity described below.
- Incidental expenditures by volunteers of $200 or less in the aggregate for the duration of the campaign. If this limit is exceeded, the entire amount is reported as an in-kind contribution and subsequent expenditures by the volunteer would be disclosed on future reports as additional contributions.
- A news item, feature, commentary or editorial in a regularly scheduled news medium that is 1) of primary interest to the general public, 2) controlled by a person whose business is that news medium, and 3) not controlled by a candidate or a political committee.
- Internal political communications from 1) a political party organization or PAC primarily to its contributors or members; 2) a corporation or similar enterprise primarily to its officers, management staff and stockholders; or 3) a union, association or other membership organization primarily to its members.
- Messages in the form of reader boards, banners, yard or window signs displayed on an individual's or entity's own property or property occupied by the individual or entity. However, if the individual or entity normally charges a fee to display a message, an in-kind contribution would occur if no fee or a reduced fee is charged for display of a political ad.
- Providing legal or accounting services if 1) the person or entity paying for the services is the regular employer of the person rendering the service, or the attorney or accountant is self-employed or doing the work on his or her own time, and 2) the services are solely for the purpose of complying with state election or public disclosure laws.
- Standard interest earned on money deposited into the campaign account.
Everything else of value received by the candidate or the candidate's committee for use in the election campaign -- including discounts on items purchased or services rendered -- and any other type of expenditure by a person done in such a way that it constitutes a contribution to the candidate is subject to limit and must be recorded in the campaign records and included on the appropriate disclosure report.
Personal services of the sort that are commonly performed by campaign volunteers are not considered contributions so long as the individual who performs one or more of these activities is not compensated by anyone for the services rendered.
This means that volunteers (who are not paid by anyone in connection with the volunteer tasks they perform) may do certain campaign work without having to report their services as in-kind contributions. If an individual takes paid vacation or leave time that he or she has earned and uses the time to assist on a campaign, the individual is not considered "paid" for campaign work, and is eligible to perform volunteer activities (without accruing a contribution to the candidate).
The Commission has defined these commonly performed campaign services to include:
- Office staffing;
- Doorbelling or leaflet drops;
- Mail handling (folding, stuffing, sorting and postal preparation);
- Political or fundraising event staffing;
- Creating, designing, posting to and maintaining a political committee’s official campaign website or online forum, so long as the individual does not ordinarily charge a fee or receive compensation for providing the service;
- Telephone bank activity (conducting voter identification, surveys or polling, and get-out-the-vote campaigns);
- Construction and placement of yard signs, hand-held signs or in-door signs;
- Acting as a driver for the candidate or campaign staff;
- Scheduling campaign appointments and events;
- Transporting voters to polling places on election day;
- Preparing campaign disclosure reports and otherwise helping to ensure compliance with state election or public disclosure laws*;
- Campaign consulting and management services, polling and survey design, public relations and advertising, or fundraising performed by any individual, so long as the individual does not ordinarily charge a fee or receive compensation for providing the service; and
- All similar activities as determined by the Commission. [WAC 390-17-405]
*Attorneys or accountants, whether they are being paid by their employers or are on their own time, may provide their professional services 1) to a candidate in order to assist the candidate in complying with state election or PDC laws, or 2) to a bona fide political party or caucus political committee for any purpose. However, these professionals may not provide similar services to any other type of political committee without a contribution ensuing – the committee must pay the fair market value of the services rendered or an in-kind contribution must be reported for the fair market value of the services rendered.