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Federal Election Commission | United States of America
  • FEC Record: Advisory opinions

AO 2016-06: SSF may conduct proposed online activity

August 4, 2016

A trade association PAC may conduct proposed activities via what it has described as an "online candidate interaction and fundraising platform."

However, the Commission could not agree on whether this activity would result in in-kind contributions to the participating candidates.

Background
The Internet Association Political Action Committee ("IAPAC") is the separate segregated fund of the Internet Association ("IA"), a 501(c)(6) non-profit trade organization.

IA and IAPAC stated that they "have developed a virtual fundraiser platform" to allow the general public to "see [a] candidate in real time, ask questions, share their views, and … make a contribution to the candidate." The requestors noted that "[e]ach event will feature one candidate… and will be hosted by an IA staff person (likely IA’s president and CEO). The host will engage … with the candidate about …the Internet economy … [and] the candidate''s campaign." As part of the proposed activity, the host and the candidate may "urge listeners to vote for the candidate … and ask viewers to make contributions to the candidate."

Analysis
The Commission concluded that IAPAC may conduct the proposed activities. The Commission further concluded that IAPAC must pay IA for the staffing and software development costs in order to prevent IA from making a prohibited corporate contribution.

IAPAC must report its disbursements for these activities on their regularly scheduled reports, and IA must also report communication costs to its members on FEC Form 7 once those costs exceed $2,000 per election.

However, the Commission could not agree on whether the proposed activity would result in an in-kind contribution to the participating candidates.

Date issued: 08/1/2016; 2 pages.

Resources:

  • Author 
    • Isaac Baker
    • Communications Specialist

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This information is not intended to replace the law or to change its meaning, nor does this information create or confer any rights for or on any person or bind the Federal Election Commission or the public.

The reader is encouraged also to consult the Federal Election Campaign Act of 1971, as amended (52 U.S.C. 30101 et seq.), Commission regulations (Title 11 of the Code of Federal Regulations), Commission advisory opinions and applicable court decisions.