Trade Associations with Corporate Members Must Do the Two-Step

At last month's conference for trade associations, many questions were asked about the process for soliciting employees of corporate members of a trade association. It’s a two-step process: First, the trade association must seek and receive formal approval (written or electronic) from the member corporation. The request must include language explaining the prior approval requirements and restrictions set forth in FEC requlations. Once the corporate member grants "prior approval," the association may solicit the member’s individual executives and stockholders for PAC contributions. See 11 CFR 114.8 and Appendix C of the Campaign Guide for Corporations and Labor Organizations for more information about the specific requirements for prior approval requests.