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Conduits

Frequently Asked Questions

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Questions Answers
El. Bd. Op. 2003-01

The filing, with the State Elections Board, of a challenge to a candidate’s nomination, is an act for political purposes and the spending of more than $25 in the submitting of that challenge requires that the person challenging file a registration statement with the Board. The spending by an individual of more than $100 of his or her own money to submit a challenge to a candidate’s nomination precludes the individual from exempt status and requires the individual to file a campaign finance report. Whether or not nomination challenge expenditures are an in-kind contribution or an independent expenditure, or are neither, they are permissible political expenditures and should be reported. (Issued to Don M. Millis, March 28, 2003)

This opinion was reviewed by the Government Accountability Board pursuant to 2007 Wisconsin Act 1 and was reaffirmed on March 26, 2008.

El. Bd. Op. 2006-01

Ancillary events, like a golf outing, held in conjunction with a political fundraiser are treated as part of the fundraiser unless the registrant/beneficiary of the fundraiser is able to show that the fundraiser was a separate and independent event. In determining whether ancillary events are separate and independent from a political fundraising event, PAC/Conduit events to raise money for the PAC are evaluated differently from events held to raise money for a candidate. Compensation for time and travel for persons paid to attend fundraising events is not considered a contribution to the beneficiary of the fundraising event unless the compensated attendee performs, in the course of the fundraiser, services for the beneficiary of the fundraiser. (Issued to Peter C. Christianson, January 18, 2006)

This opinion was reviewed by the Government Accountability Board pursuant to 2007 Wisconsin Act 1 and was reaffirmed on March 26, 2008.

El. Bd. Op. 1974-01

Local union affiliate which acts solely as a conduit in collecting and transferring predetermined contribution to state organization need not register as a political committee. (Issued to Alfred G. Goldberg, July 30, 1974)

This opinion was reviewed by the Government Accountability Board pursuant to 2007 Wisconsin Act 1 and was reaffirmed on October 6, 2008.

El. Bd. Op. 1976-15

Corporate conduits: A corporation which acts solely as a conduit in collecting and transferring predetermined contributions of its members to a state organization does not violate the prohibition on contributions by corporations. §11.38, Stats., Ops. El.Bd. 74-1, 75-6,76-3, 76-6. (Issued to Robert H. Friebert, December 17, 1976)

This opinion was reviewed by the Government Accountability Board pursuant to 2007 Wisconsin Act 1 and was reaffirmed on October 6, 2008.

El. Bd. Op. 1978-01

Subcommittees of political committees: Local unions may terminate separate registrations and become subcommittees of political action committee operated by a regional affiliate, so long as subcommittees do not engage in financial activity independent of the parent committee and a single depository and treasurer are used. Such subcommittees may act as fund-raising agents for the regional committee, provided they exercise no discretion in transfer of funds to the committee and meet the statutory time deadlines for reporting and transmittal of collected funds to the committee treasurer. §§11.10, 11.26 (2)(c), Stats. (Issued to Lee Cullen, March 16, 1978)

This opinion was reviewed by the Government Accountability Board pursuant to 2007 Wisconsin Act 1 and was revised to reflect statutory changes allowing the subcommittee 15 days to report and transmit a contribution to the affiliated PAC. 1979 Wisconsin Act 328; §11.06(4)(c), Stats. The opinion below was reaffirmed by the Government Accountability Board on October 6, 2008 and fully incorporates the revisions directed by the G.A.B.

El. Bd. Op. 1986-01

JOINT FUNDRAISERS; a political action committee and a conduit may not conduct a joint fundraiser where the contributions are deposited in a single check in an escrow account and an allocation formula is used to divide the contributions. §§11.05(9) and 11.14(1) and (2), Stats. (Issued to Mr. James Buchen, April 30, 1986.)

This opinion was reviewed by the Government Accountability Board pursuant to 2007 Wisconsin Act 1 and was reaffirmed on October 6, 2008.

El. Bd. Op. 1989-01

Interest income from conduit and PAC depository accounts, properly invested under §11.25(3) Stats., may be used in the same manner as other funds in the account, including payment of administration and solicitation expenses of a conduit if the conduit agreement so provides.

This opinion was reviewed by the Government Accountability Board pursuant to 2007 Wisconsin Act 1 and was reaffirmed on October 6, 2008.

El. Bd. Op. 1998-01

A registered conduit may transfer funds from members’ accounts to political committees (PAC’s) and those transfers will be treated as the contributions from the individual members who authorized the transfers to the PAC in the amount authorized by each member.

This opinion was reviewed by the Government Accountability Board pursuant to 2007 Wisconsin Act 1 and was reaffirmed on October 6, 2008.

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