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Using the facilities or resources of a corporation or labor organization

When using the facilities and resources of a corporation (including an incorporated trade association or membership organization) or labor organization, a campaign must pay the organization according to the rules described on this page. Otherwise, the use may result in a prohibited contribution from the corporation or labor organization.

Meeting rooms

Usual and normal rental rate

Candidates and political parties may, at the discretion of the organization, rent a corporation or labor organization’s meeting rooms at the usual and normal rate, provided reimbursement is made within a commercially reasonable time.

Provided by organization’s political committee

As with other facilities, if the organization’s political committee pays for the room as an in-kind contribution, it is advisable that payment be made in advance to avoid a prohibited contribution from the organization.

For free or at a discount

A candidate may be able to use the rooms for free or at a discount under the following conditions:

  • The corporation or labor organization customarily makes its meeting rooms available to civic and community groups;
  • The corporation or labor organization makes the rooms available to other candidates upon request; and
  • The corporation or labor organization makes the rooms available to the candidates on the same terms given to other groups (for free or at a discount if those are the terms offered to other groups).

Using staff, food services and mailing lists

A corporation or labor organization may only allow its food services and mailing lists to be used for candidate fundraisers if it receives payment in advance at the fair market value for the goods or services. Likewise, a corporation or labor organization may direct its personnel to work on these fundraisers, so long as employees are not coerced into providing on-the-job fundraising services if they do not wish to perform them. In all cases, advance payment by a source that may legally make a contribution or expenditure (such as the campaign or the organization’s SSF) is required in order to avoid a prohibited contribution by the organization. FEC regulations specifically require advance payments for:

  • The services of corporate or labor personnel directed to carry out candidate fundraising activities as part of their job;
  • The use of the organization’s list of clients, customers, vendors or other persons outside the restricted class for purposes of soliciting contributions or distributing invitations; and
  • The use of catering or other food services arranged for or provided by the corporation or labor organization.

Note, however, that if a corporation is providing the services (such as catering or personnel) in its ordinary course of business as a commercial vendor, payment does not have to be made in advance as long as:

  • The payment is at the usual and normal charge; and
  • The payment schedule conforms to normal business practice.

Otherwise, a prohibited contribution results.

Use of corporate or labor name or trademark

A corporation or a labor organization may not use the corporation’s names, trademarks or service marks to facilitate the making of contributions to a federal political committee, and a federal political committee may not knowingly accept or receive such facilitated contributions. For example, a campaign may not recognize the corporate (or labor) employers of individual contributors in connection with a fundraising event. These restrictions do not apply to the use of a name as part of the name of a political committee.