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1991-3: Compensation for Petitioning Efforts Made By Non-Legal Staff is Exempt from Spending Limits

June 11, 1991

An opinion has been requested whether the salary or fee paid to non-legal personnel, hired by a participating candidate to oversee and coordinate the circulation of designating or nominating petitions, is exempt from the expenditure limits of the New York City Campaign Finance Act.

The Campaign Finance Act exempts from the expenditure limits expenditures made for the purpose of complying with New York State Election Law. Administrative Code §3-706(4). Exempt compliance expenditures "include, but are not limited to, the costs of... circulating and filing designating and nominating petitions as required by the New York State Election Law." Campaign Finance Board Rule 1-08(e) (1). Compensation paid to non-legal personnel for overseeing and coordinating the petitioning efforts for a participating candidate are therefore exempt from the expenditure limit. Compare Advisory Opinion Nos. 1989-15 (March 23, 1989) and 1989-33 (July 19, 1989) (interpreting the compliance cost exemption prior to its amendment by Local Law No. 69 of 1991).