independent expenditures, also identify the candidate, committee, or ballot measure supported or opposed by the expenditure in the “Description of Payment” column on Schedule E or F. When a primarily formed committee makes a payment for a communication that expressly advocates support for or opposition to the candidate for whom the committee is formed, the payment is reported as a contribution or independent expenditure. As discussed in Chapter 6, the determination is based on whether the payment was made at the behest of the candidate. If the payment is an independent expenditure, additional forms, such as the Verification of Independent Expenditures (Form 462) and the 24-Hour/10-Day Independent Expenditure Report (Form 496), may be required. (See Chapter 10 for additional information.) If a primarily formed committee makes payments for contributions or independent expenditures to support or oppose other candidates, officeholders, committees, or ballot measures, it may qualify as a different type of committee (i.e., a general purpose committee), which has different reporting obligations. Contact the FPPC for assistance. Subvendor Payments (often reported on Schedule G) When an agent or independent contractor (such as a campaign worker, consulting firm, or advertising agency) makes an expenditure, or incurs a debt, of $500 or more on behalf of the committee, the expenditure must be reported in the same detail as if it had been made directly by the committee. These are commonly known as “subvendor payments.” The committee must also obtain and keep receipts, invoices, and other documentation for subvendor payments. (See Chapter 2.)
Examples of subvendor payments that must be itemized include:
• Development of campaign strategy;
• Media placements – television, radio, cable, digital (specifically listing the TV or radio stations);
• Commissions paid to media firms for media placements;
Fair Political Practices Commission advice@fppc.ca.gov
Chapter 9.47
Campaign Manual 2 August 2023
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