B. Is an independent expenditure reportable by the committee for the candidate or the ballot measure named in the communication? No. Because the communication is not made at the behest of the candidate or ballot measure committee, the expenditure for the communication is not reported by the affected candidate or measure committee. The person making the independent expenditure has the reporting obligations. C. Is a candidate’s controlled committee making an independent expenditure when it pays for a communication that supports the controlling candidate and supports or opposes a ballot measure listed on the same ballot? No. This type of expenditure considered to be a direct campaign expenditure to promote one’s own election. D. May a committee pro-rate the value of a communication that contains both an independent expenditure and a non- political message? Yes. The committee should value the independent expenditure as the portion of the costs directly associated with sending the message that expressly advocates support or opposition of a candidate or ballot measure.
Fair Political Practices Commission advice@fppc.ca.gov
Chapter 11.22
Campaign Manual 2 August 2023 Page 391
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