Coordinated Communications - Nonmonetary Contributions
When someone other than the candidate or their committee pays for a communication that is coordinated with or “made at the behest” of the candidate or their committee, the payment for the communication is a nonmonetary contribution to the affected candidate. Coordination – “Made at the Behest” A payment is coordinated with or “made at the behest” of the candidate or committee under each of the following situations: • It is made at the request, suggestion, or direction of, or in cooperation, arrangement, consultation, concert, or coordination with the candidate or committee on whose behalf, or whose benefit the expenditure is made. • The candidate or committee has made or participated in making any decision about the content, timing, location, mode, intended audience, volume of distribution, or frequency of placing the communication. • A creator, producer, or distributor of the communication, or the person paying for the communication has had a discussion with the candidate or committee regarding the content, timing, location, mode, intended audience, volume of distribution, or frequency of placing the communication. There is a rebuttable presumption that an expenditure funding a communication is coordinated with or “made at the behest” of a candidate or committee if: • Committee’s Needs. It is based on information about the candidate’s or committee’s campaign needs or plans provided by the candidate or committee to the person making the expenditure, such as information concerning campaign messaging, planned expenditures, or polling data. • Agent. It is made by or through any agent of the candidate or committee in the course of the agent’s involvement in the current campaign. “Current campaign” means the period beginning 12 months prior to the date of the primary or special
Fair Political Practices Commission advice@fppc.ca.gov
Chapter 7.3
Campaign Manual 2 August 2023 Page 252
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