E. Reporting the Intermediary of a Contribution An intermediary is a person or entity that makes a contribution on behalf of another person. For example, an employee who is reimbursed for a contribution by their employer is not the true source of the funds, but the intermediary of the employer’s contribution. A committee receiving a contribution of $100 or more from an intermediary must report the true source and the intermediary. The campaign statement will identify both the intermediary’s and the true source’s name and address, and, if applicable, the occupation and employer. Additionally, for contributions of $100 or more from an intermediary that is a limited liability company (LLC) that has qualified as an independent expenditure committee or major donor, include the name of the LLC and the full legal name of the LLC’s responsible officer as defined in Regulation 18402.2. If the contributor is an LLC that has qualified as a recipient committee, include the name of the committee and its principal officer as defined in Section 82047.6. For an LLC that has not qualified as a committee, include the name of the LLC and the full legal name of the individual primarily responsible for approving the contribution. If more than one individual shares in the primary responsibility of approving a contribution, at least one such individual must be identified. Failure to disclose the true source of a contribution is considered one of the most serious violations of the Political Reform Act.
Ex 4.10 - Berry and Vienna each made a $100 contribution from their personal funds to support Tina Baker for city council, with the understanding that they would be reimbursed by their employer. Berry and Vienna must tell the committee that they are acting as intermediaries on behalf of their employer. The committee must itemize the $200 contribution from the employer and also disclose Berry and Vienna as intermediaries.
Fair Political Practices Commission advice@fppc.ca.gov
Chapter 4.10
Campaign Manual 2 August 2023 Page 198
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