Date - Tuesday, October 13
Activity - 21-day pre-general C-4 due (for both statewide and Seattle filing purposes)
Reporting Period - September 1 through October 12
Date - October 13 through November 2
Activity - Special reports due if committee makes or receives contributions of $1,000 or more in the aggregate from one source
On October 13, 2015, which is twenty-one (21) days before the general election on November 3, your Committee’s pre-general election C-4 is due. This C-4 report must cover your total contributions and expenditures for the reporting period running from September 1 through October 12. Remember to report as an in-kind contribution to your Committee the value of the staff time and overhead that the sponsoring union provided to it during the preceding time period.
Furthermore, starting on October 13, your committee must file a special “last minute contributions report” if it makes or receives contributions of $1,000 or more in the aggregate from one source. For PDC purposes, contributors must file this report within 24 hours of (or the first working day after) giving $1000 or more during the twenty-one (21) days before the general election. Recipients must file their report within 48 hours of (or the first working day after) receiving $1000 or more during the twenty-one (21) days before the general election.
For SEEC reporting purposes, the special report must be filed by the committee receiving the contribution. The report must be filed by 4:30 p.m. the day after receipt. This is important to remember, because we are now entering the penalty phase where the SEEC will charge $150 per day per report for late-filed reports.
Importantly, October 13 also marks another campaign finance milestone. Starting on that date, no committee may 1) receive contributions over $5,000 in the aggregate from one source or 2) make aggregate contributions totaling over $5,000 to a candidate or other political committee. This is true for both PDC and SEEC reporting purposes.
This prohibition no longer applies to ballot measure committees, pursuant to the Ninth Circuit’s ruling in Family PAC v. McKenna et al., 9th Circuit Court of Appeals No. 10-35832 (Dec. 29, 2011). This limitation also does not apply if the contribution is from the state committee of a bona fide political party.
Finally, if you are involved in a Seattle campaign, be sure to send notification to the SEEC by October 26 of your committee’s time and location of public inspection of its campaign books. This is different than the PDC’s requirement to have the books available for inspection between October 26 and November 2, between 8:00 a.m. and 8:00 p.m. by appointment, within 24 hours of the time and day requested.
If you need more specific information regarding your PAC’s compliance on this or any other issue, don’t go it alone. Be sure to give us a call so we can get you the answers you need.