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Identifying coordinated expenditures
Identifying coordinated expenditures
A coordinated expenditure occurs when someone
spends money to influence the election of a City candidate and
does so in cooperation, consultation or concert with the campaign.
For example, a coordinated expenditure occurs if the expenditure is made at the request or suggestion of the campaign or following instructions from the campaign. A coordinated expenditure also occurs if someone republishes materials created by a campaign.
Example: Charlotte is running for City Council. Her best friend from college, Wilbur, texts her and says he is going to spend $10,000 on flyers urging his neighbors to vote for her. Charlotte respond with a thumbs up emoji. Wilbur’s payment for the flyers would be a coordinated expenditure and therefore an in-kind contribution that exceeds the City’s limits by $6,900.
For more examples of how coordinated expenditures arise, check out Subpart I of Regulation No. 1. For a discussion of independent expenditures, click here.
Coordinated expenditures are in-kind contributions
Coordinated expenditures are in-kind contributions
Coordinated expenditures are in-kind contributions from the person or committee who makes them to the candidate they benefit. Additionally, because coordinated expenditures are in-kind contributions, the amount spent is subject to the City’s contribution limits.
Can candidates run as a slate or otherwise split costs for campaign literature and activities?
Can candidates run as a slate or otherwise split costs for campaign literature and activities?
Yes, so long as each campaign:
Pays its fair portion of the costs;
Makes payment no later than 14 days after any other campaign; and
Obtains and maintains appropriate documentation, including invoices and printer’s samples, which shall be provided to the Board upon request.
Will a payment to be on a sample ballot result in coordinated expenditures?
Will a payment to be on a sample ballot result in coordinated expenditures?
No. So long as a campaign pays an amount commensurate with the services provided and the political committee or other person offers similar services to other campaigns, payments to print and distribute sample ballots (or for other GOTV activities) are not in-kind contributions or coordinated expenditures that count toward the City’s contribution limits.
Example 1: Piglet PAC spends $50,000 to print and distribute 100,000 copies of a sample ballot promoting ten candidates in the May 2021 primary election. Each of the candidates pays Piglet PAC $5,000 - $7,500 to be on the ballot. Candidates who pay more have their names printed in red and in larger type. Because each candidate paid the usual and normal charge, the amount Piglet PAC paid to print and distribute the ballot is not an in-kind contribution subject to the contribution limits.
Example 2: Eeyore PAC spends $50,000 to print and distribute 100,000 copies of a sample ballot promoting ten candidates in the May 2021 primary election. Eight of the candidates pay Eeyore PAC $5,000 - $7,500 to be on the ballot. Candidates Owl and Kanga do not make any payment to Eeyore PAC, but at their request Eeyore PAC leaves them on the ballot. Under these circumstances, Eeyore PAC has made two in-kind contributions of $50,000 each to Owl and Kanga. For each candidate, the contribution exceeds the limits by $37,400.
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