Posted on 10/21/2016 9:09:02 AM PDT by SubMareener
HILLARY FOR AMERICA POLICY ON FUNDRAISING AGENTS
Federal campaign law defines an “agent” as an individual who has been conferred actual authority by a candidate or campaign committee to solicit funds on its behalf (hereinafter, “fundraising authority”). Hillary for America (“HFA”) may choose to confer such authority on certain individuals who are not employees. The list of campaign fundraising agents could include individuals who agree to host sanctioned fundraising events on HFA’s behalf; individuals who offer to raise funds on HFA’s behalf and whose offer is accepted by HFA; and individuals whom HFA asks to raise funds on its behalf and who accept HFA’s offer. Individuals who raise funds for HFA without the approval of HFA staff or individuals who raise funds for HFA in contravention of an instruction not to do so will not be considered agents of HFA, notwithstanding their representations to prospective donors or how those representations are understood.
The following rules will govern the campaign’s fundraising agents. These are in addition to any policies conveyed by HFA to its agents in other documents or materials.
1. HFA will not confer fundraising authority on any individual who is compensated (whether as an employee or a consultant) by a Super PAC that makes substantial expenditures to influence the presidential election. Such individuals are not authorized to raise funds on HFA’s behalf.
2. An individual’s fundraising authority expires on the earlier of the following: (1) when the fundraising agent informs HFA that s/he is terminating her/his fundraising agency; (2) when HFA informs the individual that it is terminating the individual’s fundraising agency; or (3) when the individual’s contemplated fundraising activity for HFA ends. For example, when an individual has been conferred fundraising authority for a specific event, that authority terminates immediately after the event. As another example, when an individual has been conferred authority to raise a specific amount of funds, that authority terminates immediately as soon as those funds are raised.
3. HFA will have employees who are fundraisers. At this time, HFA does not intend to retain consultants to raise funds nor does it intend to have volunteer fundraising positions (e.g. “National Finance Chair” or “Regional Finance Chair”).
4. HFA will recognize individuals who raise a certain amount of funds by placing them in honorary groups (e.g. “Finance Committee”). Placement in these honorary groups does not suggest that the individual has any additional fundraising authority. Moreover, there may be some individuals that remain in these honorary groups notwithstanding the fact that their fundraising agency has been terminated.
SUPER PAC POLICY ON FUNDRAISING AGENTS
Super PAC recognizes that it may designate an individual as a fundraising agent who is currently serving as a fundraising agent for a federal officeholder or candidate. Federal law provides that an individual serving as a fundraising agent for a federal officeholder or candidate may legally raise funds outside of federal source restrictions and contribution limits, as long as the fundraising is not undertaken in that individual’s capacity as an agent for the federal officeholder or candidate.
The guidelines below govern fundraising activity by such individuals. It does not apply to anyone other than these individuals. It does not apply to individuals who were fundraising agents for a federal officeholder or candidate in the past, but have terminated that agency. Such individuals would not be considered fundraising agents for a federal candidate or officeholder under federal law. Super PAC encourages, though does not require, individuals who have ceased their fundraising activities for a federal officeholder or candidate to formally terminate their agency relationship with the officeholder or candidate prior to raising funds for the Super PAC.
1. The individual may not use campaign resources (e.g. staff, facilities, donor lists, or campaign materials) while raising funds for the Super PAC.
2. The individual should not identify herself as being associated with the campaign while raising funds for the Super PAC. For instance, if the individual has a fundraising title with the campaign or serves on an honorary committee, that should not be referenced while raising funds for the Super PAC.
3. The individual may not tell the prospective donor that s/he is soliciting funds on behalf of or at the request, suggestion, or direction of the candidate, a campaign staffer, or any campaign agent. Nor should the individual suggest this through phrases such as, “It would mean a lot to Candidate for you to give to the Super PAC” or “I know that Candidate would appreciate it if you gave to the Super PAC.”
4. When soliciting funds for the Super PAC, the individual must be clear that he or she is doing so on behalf of the Super PAC and not the campaign. If the Super PAC has bestowed a fundraising title on the individual, he or she must use that title when soliciting for the Super PAC. Likewise, if letters are sent to prospective Super PAC donors, they must be on Super PAC letterhead (or the donor’s personal letterhead); if emails are sent to prospective Super PAC donors, they must be from a Super PAC e-mail address (or a personal email address).
5. The individual may not solicit funds for the campaign and the Super PAC at the same time (e.g. in the same letter, phone call, e-mail, meeting, or event).
6. The individual may not explicitly earmark funds specifically for use in the candidate’s race, though it is permissible for the individual to discuss the PAC’s support for the candidate as part of the solicitation.
More charges for the Trump Administration to follow up in 2017.
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