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  • FEC Record: Advisory opinions

AO 2023-01: Use of campaign funds for travel expenses

May 1, 2023

U.S. Representative Nanette Diaz Barragán may use campaign funds to pay for certain expenses incurred in connection with events held by the Congressional Hispanic Caucus (CHC), including travel expenses for CHC members, staff and other invited event participants.


Representative Barragán (CA-44) is the Chair of the CHC, which is an official Congressional Membership Organization. As CHC Chair, she is planning a series of policy events that will take place throughout the country.

To enable CHC members, speakers, and necessary administrative staff to attend the events, Representative Barragán proposes to use funds from her principal campaign committee, Barragán for Congress, to pay their ordinary and necessary travel expenses. Her committee would pay these individuals’ travel expenses only if:

  • The primary purpose of their travel is to participate in the event; and
  • The travelers have agreed not to engage in any campaign activity during their trip other than through incidental contacts.


Under the Federal Election Campaign Act (the Act) and Commission regulations, campaign funds may not be converted to personal use by any person. The use of campaign funds “to fulfill any commitment, obligation, or expense…that would exist irrespective of the candidate’s election campaign” or duties as a federal officeholder is considered personal use.

The CHC is an official Congressional Membership Organization, and the proposed events will be official CHC events designed to allow its members to hear from constituents and stakeholders and to discuss the organization’s legislative and policy work. Representative Barragán’s official duties as CHC Chair include helping the organization carry out its legislative objectives. Since legislation and public policy are bona fide official officeholder responsibilities, the CHC events will be directly connected to Representative Barragán’s duties as a federal officeholder.

The attendance of speakers and CHC staff is necessary for the successful execution of the CHC events. The Commission has previously concluded that campaign funds may be used to pay the travel expenses for persons whose attendance is “necessary for the successful execution” of an event. Additionally, in this case, no campaign funds will be used to pay for any personal or collateral expenses, and the individuals travelling will not engage in any campaign-related activity during their trip.

As a result, the Commission concluded that the proposed use of campaign funds for these travel expenses is permissible under the Act and Commission regulations.

Date issued: April 19, 2023; Length: 8 pages


  • Author 
    • Don Michael
    • Communications Specialist