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Corporate Facilitation of Contributions

Forbes.com has an article, Federal Election Commission Eyes Corporate Donors, dealing with "corporate facilitation." That's the use of corporate facilities to gather contributions to a political campaign.

Specifically, Aube made a pitch at a bank employee dinner for $50 donations to a political action committee operated by the Oregon Bankers Association during the 2000 election. Aube then made a follow-up solicitation to dinner attendees via e-mail. A total of $1,570 was raised for the PAC. That's exactly the type of stuff prohibited under FEC rules. The bank agreed to pay a civil penalty of $16,500--more than ten times the amount it helped raise for the PAC in the first place.

But much less-blatant behavior can get you in trouble too, particularly when it comes to those rules limiting use of corporate resources. "It's much easier to violate [rule] 114.2(f)," says Brett Kappel, a partner with Powell, Goldstein, Frazer & Murphy in Washington, D.C. "All the executive has to do is send out an e-mail asking employees to send their checks to his secretary."

My post on Kappel's advisory to his clients on the same subject is here.

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