Answering Your Questions A. A labor union pays for a mailing advocating the election of a candidate for city council. The mailing list includes both union members and non-union members and 20% of the mailing costs are attributed to non-union members. Must the candidate report the full cost of the mailing as a non- monetary contribution? No. The candidate may pro-rate the cost and report as a nonmonetary contribution only the mailing costs for the non- union members. B. A representative of an environmental organization interviewed a candidate for county supervisor about issues affecting the environment. Later, the candidate learned that the organization paid for a radio advertisement advocating the election of that candidate. Must the candidate report a nonmonetary contribution? No. An expenditure is not made at the behest of a candidate just because a person interviews the candidate on issues affecting the person making the expenditure. As long as the candidate did not coordinate with the organization to produce the advertisement in any other way, the organization made an independent expenditure, not a contribution to the candidate.
Fair Political Practices Commission advice@fppc.ca.gov
Chapter 7.14
Campaign Manual 2 August 2023 Page 263
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