SSFs may solicit funds using any otherwise legal method of fundraising; however, no matter which method is used, the rules specific to all SSF solicitations must be observed.
Oral SSF solicitations, for example those done through a speech, a meeting or a telephone or in-person conversation, may be made only to members of the restricted class (and not to anyone else). The speaker must include all of the requisite notices in his or her remarks. Literature about the SSF may be offered when requesting contributions.
Solicitations at conventions or meetings
Connected organizations may make solicitations at a convention or meeting. The audience may include only a de minimis number of persons outside of the restricted class (e.g., speakers, featured guests). For example, an SSF may solicit contributions from a booth at a convention, provided that:
- The booth is not publicized prior to the convention other than to members of the restricted class;
- The booth’s signs inform contributors of the solicitation restrictions;
- The connected organization maintains a list of individuals in the restricted class;
- Funds are not accepted from individuals who are not solicitable.
An impermissible solicitation will occur, even if unintended, when a connected organization provides information beyond the restricted class on how to contribute to its SSF or when it encourages support of the SSF.
A pre-meeting mailing that mentions an SSF fundraising event or a booth is a solicitation. A sign saying “Ask Us for Information About the PAC Fundraiser” or informing attendees about a fundraising event is also a solicitation.
Prior approval for trade association SSFs
A trade association may also receive written solicitation approvals at the convention as long as they are signed by persons authorized by the corporations to make such approvals.