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  • FEC Record: Advisory opinions

AO 2022-05: Value of book allocated among recipients

June 30, 2022

The value of a research book paid for by the Democratic Senatorial Campaign Committee (DSCC) may be allocated equally to the DSCC and two authorized committees as long as the allocation reasonably reflects the benefit derived.


The DSCC plans to hire a consultant to write a research book regarding a sitting U.S. senator to inform its own strategy. The DSCC would also provide the book to two Senate campaign committees. The campaigns could either pay the DSCC for the value of the book or treat it as an in-kind contribution or coordinated party expenditure. The DSCC asked whether the value of the research book may be allocated equally to each of the three committees.


Under the Federal Election Campaign Act, a contribution includes “any gift, subscription, loan, advance, or deposit of money or anything of value made by any person for the purpose of influencing any election for Federal office.” The term “anything of value” includes all in-kind contributions, such as goods or services provided without charge or at less than the usual and normal charge. The “usual and normal charge” for goods is the price of those goods in the market from which they ordinarily would have been purchased at the time of the contribution, and the “usual and normal charge” for services is the commercially reasonable rate prevailing at the time the services were rendered.

The Commission’s regulations do not address the allocation of expenditures for a research book like the one at issue. However, given the similarities between polling results and the research book, the polling allocation regulations may serve as a model. Like a research book, a poll may be commissioned to be used by multiple committees and may cover issues or opposition candidates. A poll’s value to the recipient committees will depend on the information that it yields, with the recipients deriving varying degrees of benefit from it. The Commission’s regulations accommodate these varying degrees of benefit by permitting the committees to choose an allocation method that reflects the candidates’ respective uses of and benefit from the information.

In this matter, the Commission determined that the DSCC may allocate the cost of the research book equally to each of the three committees receiving it, if that allocation reasonably reflects the benefit derived.

Date issued: June 23, 2022; Length: 4 pages



52 U.S.C. § 30101(8)(A)(i)
Definition of the term “contribution”

52 U.S.C. § 30101(8)(B)(i)
Definition of “anything of value”


11 CFR § 100.52(a)
Gift, subscription, loan, advance or deposit of money – contributions

11 CFR § 100.52(d)(1)
Definition of “anything of value”

11 CFR § 100.111
Gift, subscription, loan, advance or deposit of money – expenditures

11 CFR § 110.1(b)
Contributions to candidates

11 CFR § 110.10
Expenditures by candidates


  • Author 
    • Mary Ann Baker
    • Communications Specialist