Stop the Reimbursements/Corporate and Lobbyist Credit Card Payments!

Earlier today, the Wisconsin State Elections Board issued an informal staff opinion on an increasingly common "golf outing" fundraising practice - make a candidate contribution with a PAC/individual (nonlobbyist) check but then pay for your own greens fees and dinner directly to the golf course using whatever funds you want - including corporate and individual lobbyist funds. This practice has several obvious (and intended) effects including increasing the "net" political contributions to the candidate, increasing the time before a candidate "PACs out", and allowing for organizations to preserve PAC (and conduit) funds by using corporate or individual lobbyist funds that otherwise couldn't go to a candidate committee.

Based on the opinion of the Elections Board's staff, this fundraising practice is NOT permitted under Wisconsin law. A copy of the informal opinion is attached, requested by Quarles & Brady for an unspecified client. In sum, the opinion concludes that the practice may result in unreported corporate (or lobbyist) campaign contributions.

As a result of this informal opinion, we assume that candidates and political parties will structure their respective events in a different manner, running all of the expenses through the campaign committee (for example, the annual Doyle golf outing) or creating two distinct events: a golf outing and a fundraiser (for example, many corporate and trade association PAC/conduit fundraisers). However, if you receive an invitation for an event or plan on attending an event under the impermissible format, corporate or individual lobbyist funds should NOT be used to pay for these expenses.

As always, please let us know if you have any questions or need any additional information on this topic.

Additional information:

September 28 Meeting Notice

September 7 Informal Advisory Opinion