[Lnc-business] Prohibition on raising soft money

Richard Longstreth richard.longstreth at lp.org
Wed Aug 22 04:39:26 EDT 2018


My thanks Tim. This is extremely clarifying.

Richard

On Tue, Aug 21, 2018, 23:03 Tim Hagan via Lnc-business <
lnc-business at hq.lp.org> wrote:

>    Please do. Thanks!
>
>    ---
>    Tim Hagan
>    Treasurer, Libertarian National Committee
>
>    On 2018-08-21 16:11, Caryn Ann Harlos wrote:
>
>    I am going to add this to my new member tip sheets
>
>    On Tue, Aug 21, 2018 at 4:57 PM Caryn Ann Harlos
>    <[1]caryn.ann.harlos at lp.org> wrote:
>
>    Good to know!
>
>    On Tue, Aug 21, 2018 at 4:22 PM Tim Hagan via Lnc-business
>    <[2]lnc-business at hq.lp.org> wrote:
>
>         The Federal Election Campaign Act and FEC regulations in Title 11
>      has a
>         restriction that LNC members, as officers of a national political
>      party
>         committee, need to be aware of. We cannot solicit nonfederal
>      funds,
>         such as contributions to state or local candidates or to
>      affiliates
>         that don't file with the FEC, when acting on behalf of the LNC.
>         From the FEC Campaign Guide: "National parties may not solicit,
>      raise,
>         direct or spend funds, or anything of value, that are not subject
>      to
>         the prohibitions, limitations and reporting requirements of the
>      [FECA]
>         Act. This prohibition of nonfederal and Levin funds also applies
>      to any
>         agent or officer acting on behalf of the national party committee
>      or
>         any entity that is directly or indirectly established, financed,
>         maintained or controlled by a national party committee."
>         What does this mean for us? It does not mean that LNC members can
>      never
>         solicit nonfederal funds, such as for Riverside County Supervisor
>      or
>         Phoenix mayor. However, do not use your LNC title when soliciting
>      for
>         nonfederal funds, because then you can be perceived as acting on
>      behalf
>         of the LNC. Do not use LNC resources to ask people to donate to
>         nonfederal funds. There are some gray areas, and for those you
>      can ask
>         me and I will check with Paula Edwards, our FEC consultant.
>         Thanks,
>         Tim Hagan
>         This is the regulation in Title 11, for your reference:
>         §300.10   General prohibitions on raising and spending
>      non-Federal
>         funds (52 U.S.C. 30125(a) and (c)).
>         (a) Prohibitions. A national committee of a political party,
>      including
>         a national congressional campaign committee, must not:
>           (1) Solicit, receive, or direct to another person a
>      contribution,
>         donation, or transfer of funds, or any other thing of value that
>      is not
>         subject to the prohibitions, limitations and reporting
>      requirements of
>         the Act;
>           (2) Spend any funds that are not subject to the prohibitions,
>         limitations, and reporting requirements of the Act; or
>           (3) Solicit, receive, direct, or transfer to another person, or
>         spend, Levin funds.
>         (b) Fundraising costs. A national committee of a political party,
>         including a national congressional campaign committee, must use
>      only
>         Federal funds to raise funds that are used, in whole or in part,
>      for
>         expenditures and disbursements for Federal election activity.
>         (c) Application. This section also applies to:
>           (1) An officer or agent acting on behalf of a national party
>         committee or a national congressional campaign committee; and
>           (2) An entity that is directly or indirectly established,
>      financed,
>         maintained, or controlled by a national party committee or a
>      national
>         congressional campaign committee.
>         --
>         Tim Hagan
>         Treasurer, Libertarian National Committee
>
>      --
>
>    --
>    In Liberty,
>    Caryn Ann Harlos
>    Libertarian Party and Libertarian National Committee Secretary
>    - [3]Caryn.Ann. Harlos at LP.org or Secretary at LP.org.
>    Chair, LP Historical Preservation Committee - LPedia at LP.org
>
>    A haiku to the Statement of Principles:
>    We defend your rights
>    And oppose the use of force
>    Taxation is theft
>
>      --
>
>    --
>    In Liberty,
>    Caryn Ann Harlos
>    Libertarian Party and Libertarian National Committee Secretary
>    - [4]Caryn.Ann. Harlos at LP.org or Secretary at LP.org.
>    Chair, LP Historical Preservation Committee - LPedia at LP.org
>
>    A haiku to the Statement of Principles:
>    We defend your rights
>    And oppose the use of force
>    Taxation is theft
>
> References
>
>    1. mailto:caryn.ann.harlos at lp.org
>    2. mailto:lnc-business at hq.lp.org
>    3. mailto:Caryn.Ann.Harlos at LP.org
>    4. mailto:Caryn.Ann.Harlos at LP.org
>
-- 
Richard Longstreth
Region 1 Representative (AK, AZ, CO, KS, MT, NM, OR, HI, UT, WA, WY)
Libertarian National Committee
richard.longstreth at lp.org
931.538.9300
-------------- next part --------------
   My thanks Tim. This is extremely clarifying.

   Richard
   On Tue, Aug 21, 2018, 23:03 Tim Hagan via Lnc-business
   <[1]lnc-business at hq.lp.org> wrote:

        Please do. Thanks!
        ---
        Tim Hagan
        Treasurer, Libertarian National Committee
        On 2018-08-21 16:11, Caryn Ann Harlos wrote:
        I am going to add this to my new member tip sheets
        On Tue, Aug 21, 2018 at 4:57 PM Caryn Ann Harlos
        <[1][2]caryn.ann.harlos at lp.org> wrote:
        Good to know!
        On Tue, Aug 21, 2018 at 4:22 PM Tim Hagan via Lnc-business
        <[2][3]lnc-business at hq.lp.org> wrote:
             The Federal Election Campaign Act and FEC regulations in
     Title 11
          has a
             restriction that LNC members, as officers of a national
     political
          party
             committee, need to be aware of. We cannot solicit nonfederal
          funds,
             such as contributions to state or local candidates or to
          affiliates
             that don't file with the FEC, when acting on behalf of the
     LNC.
             From the FEC Campaign Guide: "National parties may not
     solicit,
          raise,
             direct or spend funds, or anything of value, that are not
     subject
          to
             the prohibitions, limitations and reporting requirements of
     the
          [FECA]
             Act. This prohibition of nonfederal and Levin funds also
     applies
          to any
             agent or officer acting on behalf of the national party
     committee
          or
             any entity that is directly or indirectly established,
     financed,
             maintained or controlled by a national party committee."
             What does this mean for us? It does not mean that LNC
     members can
          never
             solicit nonfederal funds, such as for Riverside County
     Supervisor
          or
             Phoenix mayor. However, do not use your LNC title when
     soliciting
          for
             nonfederal funds, because then you can be perceived as
     acting on
          behalf
             of the LNC. Do not use LNC resources to ask people to donate
     to
             nonfederal funds. There are some gray areas, and for those
     you
          can ask
             me and I will check with Paula Edwards, our FEC consultant.
             Thanks,
             Tim Hagan
             This is the regulation in Title 11, for your reference:
             §300.10   General prohibitions on raising and spending
          non-Federal
             funds (52 U.S.C. 30125(a) and (c)).
             (a) Prohibitions. A national committee of a political party,
          including
             a national congressional campaign committee, must not:
               (1) Solicit, receive, or direct to another person a
          contribution,
             donation, or transfer of funds, or any other thing of value
     that
          is not
             subject to the prohibitions, limitations and reporting
          requirements of
             the Act;
               (2) Spend any funds that are not subject to the
     prohibitions,
             limitations, and reporting requirements of the Act; or
               (3) Solicit, receive, direct, or transfer to another
     person, or
             spend, Levin funds.
             (b) Fundraising costs. A national committee of a political
     party,
             including a national congressional campaign committee, must
     use
          only
             Federal funds to raise funds that are used, in whole or in
     part,
          for
             expenditures and disbursements for Federal election
     activity.
             (c) Application. This section also applies to:
               (1) An officer or agent acting on behalf of a national
     party
             committee or a national congressional campaign committee;
     and
               (2) An entity that is directly or indirectly established,
          financed,
             maintained, or controlled by a national party committee or a
          national
             congressional campaign committee.
             --
             Tim Hagan
             Treasurer, Libertarian National Committee
          --
        --
        In Liberty,
        Caryn Ann Harlos
        Libertarian Party and Libertarian National Committee Secretary
        - [3]Caryn.Ann. Harlos at LP.org or Secretary at LP.org.
        Chair, LP Historical Preservation Committee - LPedia at LP.org
        A haiku to the Statement of Principles:
        We defend your rights
        And oppose the use of force
        Taxation is theft
          --
        --
        In Liberty,
        Caryn Ann Harlos
        Libertarian Party and Libertarian National Committee Secretary
        - [4]Caryn.Ann. Harlos at LP.org or Secretary at LP.org.
        Chair, LP Historical Preservation Committee - LPedia at LP.org
        A haiku to the Statement of Principles:
        We defend your rights
        And oppose the use of force
        Taxation is theft
     References
        1. mailto:[4]caryn.ann.harlos at lp.org
        2. mailto:[5]lnc-business at hq.lp.org
        3. mailto:[6]Caryn.Ann.Harlos at LP.org
        4. mailto:[7]Caryn.Ann.Harlos at LP.org

   --

   Richard Longstreth
   Region 1 Representative (AK, AZ, CO, KS, MT, NM, OR, HI, UT, WA, WY)
   Libertarian National Committee
   [8]richard.longstreth at lp.org
   931.538.9300

References

   1. mailto:lnc-business at hq.lp.org
   2. mailto:caryn.ann.harlos at lp.org
   3. mailto:lnc-business at hq.lp.org
   4. mailto:caryn.ann.harlos at lp.org
   5. mailto:lnc-business at hq.lp.org
   6. mailto:Caryn.Ann.Harlos at LP.org
   7. mailto:Caryn.Ann.Harlos at LP.org
   8. mailto:richard.longstreth at lp.org


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