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1989-6: Accepting Checks from an Individual That Represent Contributions from Others

January 25, 1989

An opinion has been requested whether the costs associated with a fundraising event which are paid for by the persons who attend the event are considered to be expenditures made by a candidate subject to the expenditure limits of Administrative Code §3-706. The request states that neither the candidate nor an authorized committee of the candidate has entered into an agreement with the persons who provide the services connected with the fundraising event.

Campaign Finance Board Regulation §105(e) provides that "a disbursement for the purpose of promoting or facilitating the nomination or election of a candidate," which is not an independent expenditure, "shall be deemed to be a contribution to, and an expenditure by, any candidate...who made, authorized, requested, suggested, fostered, or otherwise cooperated in the disbursement."

It is the opinion of the Board that the payment of the cost of a fundraising event by a person attending the event is thus a contribution to and expenditure by a candidate, if that candidate authorized, requested, suggested, fostered, or otherwise cooperated in that payment.