as of 9/30/2011. iea political action committee (pac) funded by $20 annual contributions from all...

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ILLINOIS CAMPAIGN DISCLOSURE REQUIREMENTS As of 9/30/2011

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ILLINOIS CAMPAIGN DISCLOSURE

REQUIREMENTSAs of 9/30/2011

IEA Political Action Committee (PAC) Funded By $20 Annual Contributions From

All IEA Members Governed by Committee Composed of IEA

Leaders Purposes

◦ Elect Pro-Education State Candidates◦ Help Locals With Political Activity

WHAT IS IPACE?

Grassroots Political Activist Program Educational Resources Support from Lobbyists IPACE Rebate Funds

ASSISTANCE TO LOCALS

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

IPACE REBATE PROGRAM

Level I: Written Request to IEA Government Relations

Level II: Written Request with Explanation of Special Circumstances

Level III: Written Request With Detailed Budget

ACCESS TO 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

YOUR COMMITMENT WHEN YOU REQUEST IPACE FUNDS

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…….

REGISTRATION CRITERIA

Support or Oppose:◦ Candidates for Public Office◦ Question of Public Policy on Ballot

DIRECT CONTRIBUTIONS

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

ELECTIONEERING COMMUNICATION

Payments Not Coordinated With a Candidate or PAC:◦ Electioneering Communications◦ Advocating For/Against a Candidate

INDEPENDENT EXPENDITURES

Political Education for Members “Meet the Candidates” Events Subs for Lobby Day

OTHER PAYMENTS DON’T “COUNT”

Cash Loans Anything Else of Value (In-Kind

Contributions)

WHAT IS A “CONTRIBUTION”?

Keep Current Records of Expenditures◦ Date◦ Amount◦ Type (Do They “Count”)?

Maintain Current 12-Month Total of Expenses That “Count”

HOW DO WE KNOW IF WE MEET THE $3,000 THRESHOLD?

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)

DISCLOSURE REQUIREMENTS

Electronic Filing of Reports Reports to Recipients of In-Kind

Contributions Disclosure in Political Communications Fundraising Solicitation Disclosure Raffles

OTHER REQUIREMENTS

Illinois State Board of Elections◦ Springfield◦ Chicago

No Longer any Filing Requirement with County Clerks

WHO ADMINISTERS THE DISCLOSURE REPORTING SYSTEM?

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

ENFORCEMENT

EXAMPLE 1

EXAMPLE 2

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

PLEASE NOTE

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

OK, WE HAVE TO REGISTER…

D-1 (TOP)

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)

WHAT INFO MUST BE REPORTED?

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

INFO TO REPORT (Cont’d)

Due on the 15th 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!

QUARTERLY REPORTS (D-2)

D-2

D-2 (TOP)

Individual Contributions Transfers from Other PACs Loans In-Kind Contributions Other

Section A: RECEIPTS

D-2 SECTION A

Transfers to Other PACs Loans Expenditures Independent Expenditures

SECTION B: EXPENDITURES

D-2 SECTION B-C-D

Listing of Loans Payable◦ Original Amount◦ Cumulative Payments◦ Balance at end of Quarter

SECTION C: DEBTS

Cash at Beginning of Quarter + Receipts (Section A) - Expenditures (Section B) = Cash at End of Quarter

Investments

SECTION D: CASH BALANCE

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

CONTRIBUTIONS OF $1,000 OR MORE (SCHEDULE A-1)

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”

SCHEDULE A-1/IPACE REBATES

A-1

Payments Not Coordinated With a Candidate or PAC:◦ 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

INDEPENDENT EXPENDITURES (SCHEDULE B-1)

B-1

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 Issues◦ Hardware◦ Software◦ Passwords

CONSIDER USING ISBE SOFTWARE (IDIS)

ELECTRONIC FILING

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

IN-KIND CONTRIBUTION REPORTS TO RECIPIENTS

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

REPORT TO RECIPIENT

IN-KIND CONTRIBUTIONS

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

DISCLOSURE ON POLITICAL COMMUNICATIONS

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)

FUNDRAISING SOLICITATION DISCLOSURE

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

RAFFLES

RAFFLE REPORT

YOUR BEST FRIEND IS…

TOOLS WITHIN THE WEBSITE

ONE-STOP SHOPPING

TOPICAL PUBLICATIONS

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TOPICAL PUBLICATIONS

TOPICAL PUBLICATIONS

TOPICAL PUBLICATIONS

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

KNOW WHAT TO DO WITH IPACE FUNDS◦ SEGREGATE◦ ACCEPTABLE USES

KNOW THE DISCLOSURE RULES◦ DO YOU HAVE TO FILE?◦ IF SO, STAY UP TO DATE ON THE RULES

KEEP GOOD RECORDS

CONCLUDING THOUGHTS