Non-Political Communications A payment made at the behest of a candidate for a communication by the candidate or any other person is not a contribution to the candidate if the communication:
• Does not contain express advocacy;
• Does not refer to the candidate’s election campaign, or their opponent’s qualifications for office; and • Does not solicit contributions to the candidate or to third persons for use in support of or opposition to the candidate. Member Communications Payments made by an organization or its sponsored committee for a communication that supports or opposes a candidate are not contributions or expenditures as long as the communication is made only to the organization’s members, employees, or shareholders, or the families of its members, employees, or shareholders. The payments may not be for general public advertising, such as billboards, newspaper ads, or radio or television ads. If the organization’s sponsored committee makes the payments, the committee would report the payments as being made for general member communications. Payments made by a political party for a communication that supports a candidate are not contributions to the candidate as long as the communication is distributed only to the party’s members, employees, and families of its members and employees. The party must report the payments, however, as if they were contributions or independent expenditures.
Ex 7.11 - Your campaign consultant asks a labor organization to send a mailing supporting your election. The mailing will be sent only to the organization’s membership. The mailing is not a contribution to you. Later, the campaign consultant asks the organization to send the mailing to all registered voters in your district. The mailing to the voters is a contribution to you.
Fair Political Practices Commission advice@fppc.ca.gov
Chapter 7.12
Campaign Manual 2 August 2023 Page 261
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