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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 by Committee Composed of IEA Leaders Purposes Elect Pro-Education State Candidates
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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 by Committee Composed of IEA Leaders • Purposes • 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 Not Coordinated With a Candidate or PAC: • 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
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
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 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!
Section A: RECEIPTS • Individual Contributions • Transfers from Other PACs • Loans • In-Kind Contributions • Other
SECTION B: EXPENDITURES • Transfers to Other PACs • Loans • Expenditures • Independent Expenditures
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”
INDEPENDENT EXPENDITURES (SCHEDULE B-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
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 Issues • Hardware • Software • Passwords • CONSIDER 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
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