ILLINOIS CAMPAIGN DISCLOSURE REQUIREMENTS As of 9302011 WHAT






































































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ILLINOIS CAMPAIGN DISCLOSURE REQUIREMENTS As of 9/30/2011
WHAT IS IPACE? � IEA Political Action Committee (PAC) � Funded By $20 Annual Contributions From All IEA Members � Governed Leaders � Purposes by Committee Composed of IEA ◦ Elect Pro-Education State Candidates ◦ Help Locals With Political Activity
ASSISTANCE TO LOCALS � Grassroots Political Activist Program � Educational Resources � Support from Lobbyists � IPACE Rebate Funds
IPACE REBATE PROGRAM � Level I Rebate: $4. 00 Per Contributing Member � Level II Rebate: $10. 00 Per Contributing Member � Level III Rebate: Additional Funds as Justified by Written Request to IPACE � Levels I and II May be Requested Annually
ACCESS TO FUNDS � Level I: Written Request to IEA Government Relations � Level II: Written Request with Explanation of Special Circumstances � Level III: Written Request With Detailed Budget
YOUR COMMITMENT WHEN YOU REQUEST IPACE FUNDS � Deposit Funds in a Separate Bank Account � Use Funds Only for LOCAL Political Purposes ◦ Elect Local Political Candidates (Your Area, NOT State-Level, e. g. School Board) ◦ Pass Local Ballot Initiatives (e. g. School Referendum) ◦ Educate Your Members ◦ Activate Your Members � Comply With State Disclosure Requirements
REGISTRATION CRITERIA � Until You Meet the Criteria for Registration, NONE OF THE OTHER REQUIREMENTS APPLY � Criteria: Spend More Than $3, 000 in ANY Consecutive 12 -Month Period for Any of The Following…….
DIRECT CONTRIBUTIONS � Support or Oppose: ◦ Candidates for Public Office ◦ Question of Public Policy on Ballot
ELECTIONEERING COMMUNICATION � Broadcast, Cable or Satellite Communication or Advertising � Appeals for Vote For/Against a Candidate, Political Party, or Public Policy Question � Made Within: ◦ 60 Days Before General Election ◦ 30 Days Before Primary Election � Does Not Apply to Exclusive Communication To Members
INDEPENDENT EXPENDITURES � Payments or PAC: Not Coordinated With a Candidate ◦ Electioneering Communications ◦ Advocating For/Against a Candidate
OTHER PAYMENTS DON’T “COUNT” � Political Education for Members � “Meet the Candidates” Events � Subs for Lobby Day
WHAT IS A “CONTRIBUTION”? � Cash � Loans � Anything Else of Value (In-Kind Contributions)
HOW DO WE KNOW IF WE MEET THE $3, 000 THRESHOLD? � Keep Current Records of Expenditures ◦ Date ◦ Amount ◦ Type (Do They “Count”)? � Maintain Current 12 -Month Total of Expenses That “Count”
DISCLOSURE REQUIREMENTS � Once You Meet the Criteria for Registration, These Requirements Apply: � One-Time Registration (D-1) � Quarterly Reporting (D-2) � Receipt of Individual Contributions $1, 000 or More (A-1) � “Independent Expenditures” $1, 000 or More (B-1)
OTHER REQUIREMENTS � Electronic Filing of Reports � Reports to Recipients of In-Kind Contributions � Disclosure in Political Communications � Fundraising Solicitation Disclosure � Raffles
WHO ADMINISTERS THE DISCLOSURE REPORTING SYSTEM? � Illinois State Board of Elections ◦ Springfield ◦ Chicago � No Longer any Filing Requirement with County Clerks
ENFORCEMENT � The Board is Happy to Help with Questions Before the Fact � After the Fact, There are Statutory Penalties for not Following the Rules � The Board has become More Thorough and Aggressive in Enforcement
EXAMPLE 1
EXAMPLE 2
PLEASE NOTE � Pretty Much Everything You File is Available to the World Online on the ISBE Website � You Can Use the System to Monitor Other PACs’ Activity � This Presentation Only Covers the Basic Requirements Currently in Place, so… � Read the Disclosure Guide and Monitor the ISBE Website Regularly for Updates
OK, WE HAVE TO REGISTER… � D-1 Must be Filed Within 10 Business Days � 2 Business Days if Within 30 Days of Next Election � Must File Amended D-1 to Report Any Subsequent Changes to Information Within 10 Days
D-1 (TOP)
WHAT INFO MUST BE REPORTED? � DATE COMMITTEE CREATED: Date the $3, 000 Threshold is Reached � FUNDS ON HAND WHEN COMMITTEE CREATED: If not $3, 000 or Less, Will Need Explanation � NEW COMMITTEE OR AMENDMENT � DESIGNATION (You Are a PAC)
INFO TO REPORT (Cont’d) � AREA OF ACTIVITY: Counties You Operate In � PARTY AFFILIATION: None � SPONSORING ENTITY: N/A � PURPOSE: “Support Pro-Education Candidates and Issues” � CANDIDATES SUPPORTED: N/A
INFO TO REPORT (Cont’d) � OFFICERS: Name/Address of Chairman and Treasurer � CUSTODIAN OF BOOKS (If Other than Treasurer) � FINANCIAL INSTITUTIONS: All Banks Used � DISPOSITION OF RESIDUAL FUNDS: Transfer to IPACE
QUARTERLY REPORTS (D-2) � Due on the 15 th of the Month Following the End of the Quarter (March/June/September/December) � All Contributions and Expenditures That Exceed $150 Cumulatively for the Quarter Must be Itemized � Other Transactions are “Nonitemized” � DON’T FORGET TO FILE!
D-2
D-2 (TOP)
Section A: RECEIPTS � Individual Contributions � Transfers from Other PACs � Loans � In-Kind Contributions � Other
D-2 SECTION A
SECTION B: EXPENDITURES � Transfers � Loans to Other PACs � Expenditures � Independent Expenditures
D-2 SECTION B-C-D
SECTION C: DEBTS � Listing of Loans Payable ◦ Original Amount ◦ Cumulative Payments ◦ Balance at end of Quarter
SECTION D: CASH BALANCE � Cash at Beginning of Quarter � + Receipts (Section A) � - Expenditures (Section B) � = Cash at End of Quarter � Investments
CONTRIBUTIONS OF $1, 000 OR MORE (SCHEDULE A-1) � Must File When Receiving Single Contributions of $1, 000 or More � Loans, Cash, In-Kind � File Within 5 Business Days of Receipt � 2 Business Days in 30 Days Prior to Election � Postmark Doesn’t Count: Date Actually Received by Board
SCHEDULE A-1/IPACE REBATES � You do not Have to File an A-1 for Receipts from IPACE of $1, 000 or More, IF � You Itemize the Receipt in Section A of the D 2 and Indicate “Rebate of Individual Contributions”
A-1
INDEPENDENT EXPENDITURES (SCHEDULE B-1) � Payments or PAC: Not Coordinated With a Candidate ◦ Electioneering Communications ◦ Advocating For/Against a Candidate � Expenditures of $1, 000 or More in the 30 Days Before an Election: Must File B-1 � Must File Within 5 Business Days � Must File Electronically
B-1
ELECTRONIC FILING � If You Have… ◦ Cash on Hand of $10, 000 or More, or ◦ Receipts of $10, 000 or More in a Quarter, or ◦ Expenditures of $10, 000 or More in a Quarter… � Then You Have to File Reports Electronically Forever � Exception: Amended D-1’s
ELECTRONIC FILING � Security/Transition ◦ Hardware ◦ Software ◦ Passwords � CONSIDER Issues USING ISBE SOFTWARE (IDIS)
IN-KIND CONTRIBUTION REPORTS TO RECIPIENTS � Anything of Value Contributed to a Candidate or PAC (See Disclosure Guide for Limited Exceptions) � Must Report on D-2 � Also Must Report to Recipient (NOT to ISBE) Within 5 Business Days
REPORT TO RECIPIENT � Name/Address of Contributor � Vendor Paid (If Applicable) � Description and Market Value � Date of Expenditure � Use “In Kind Contribution Notification” Form � Do NOT Send to ISBE
IN-KIND CONTRIBUTIONS
DISCLOSURE ON POLITICAL COMMUNICATIONS � If You Expend Funds for Communications Directed at Voters and Mention the Name of a Candidate… � Must Clearly Identify the PAC as Having Paid for It
FUNDRAISING SOLICITATION DISCLOSURE � Applicable Only if You Solicit Funds for your PAC in Addition to the Annual $20 � Solicitation Must Include a Canned Notice (See Guide to Campaign Disclosure)
RAFFLES � PACs Need a Raffle License from the State in Order to Conduct a Raffle � No Charge for License � For Each Raffle, a Separate “Raffle Report” Must be Completed and Filed With the Next D -2 Report � Raffles Not Recommended Unless You Comply with the Above
RAFFLE REPORT
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REFERENCE
REFERENCE
“THE LAW”
CALENDAR
IPACE ON THE WEB
IPACE ON THE WEB
IPACE ON THE WEB
OTHER RELATED INFO
IEA Website CLICK “RESOURCES” 67
IEA Website CLICK “FINANCIAL PROCEDURES” 68
IEA Website CLICK here for the handbooks CLICK here for workshops & webinars 69
CONCLUDING THOUGHTS � KNOW WHAT TO DO WITH IPACE FUNDS � KNOW THE DISCLOSURE RULES ◦ SEGREGATE ◦ ACCEPTABLE USES ◦ DO YOU HAVE TO FILE? ◦ IF SO, STAY UP TO DATE ON THE RULES � KEEP GOOD RECORDS