Q: Our association has a PAC but our treasurer is not a lobbyist and our assistant treasurer is a lobbyist. Do we still need to file an LD-203 report for the PAC? And if so, who must file and by when must the filing occur?
A: The individual lobbyist will have to file his or her own individual contributions. On the association’s semi-annual report (LD-203), the association would list the name of the PAC. It does not matter whether your treasurer is or is not a lobbyist for the purposes of the filing by the association.
The association would indicate the name of its PAC and indicate contributions of $200 or more from the PAC to any federal candidate, any leadership PAC or any one of the six national party committees that were made during the six-month reporting period.
On the lobbyist’s separate filing, the lobbyist may have to indicate – if he or she has a controlling say in where PAC contributions are spent – that he or she is the assistant treasurer. If the lobbyist has a responsibility for allocating PAC funds, he or she would have to list contributions from the PAC that he or she was responsible for having made in the individual lobbyist report.
So it’s a fact-specific situation depending on how the PAC is set up, and who its officers are, as well as who controls contributions.
Have a question for Compliance Q&A? Send your questions to ehill@columbiabooks.com.
Tags: associations, compliance, LD-203, PACs
