Fundraising | In The Know

What is a PAC Solicitation?

Monday, August 30th, 2010

Corporations and trade associations may solicit funds for their PACs only from a restricted class of employees or members.

So just what is a “solicitation”? (I’ll address “restricted class” in a subsequent post.)

Federal Election Commission (FEC) rules and court decisions construing what constitutes a solicitation for the PAC are surprisingly broad. An e-mail or letter asking employees or members to write a check or sign up for payroll deduction is clearly a solicitation. But many other activities such as routine government relations or grassroots web sites or newsletters and conference or meeting invitations can easily include inadvertent PAC solicitations. FEC4

Among the examples the FEC has concluded are solicitations are:

• A simple announcement of the time, location, and featured guest for a PAC fundraiser (AO 1976-27);
• Disclosure of the fact that the PAC may accept unsolicited contributions;
• Mentioning a PAC fundraiser in a convention mailing (AO 1976-27);
• Setting up a PAC Booth at a convention (unless contributions from non-restricted class members are declined)(AO 1976-96 and TK);
• Praising employees who have contributed to the PAC (AO 1979-13).

The FEC recently summed up its PAC solicitation rule by saying that communications that “encourage” or “facilitate” contributions to a PAC are solicitations.

In a somewhat surprising development a U.S. District Court recently concluded the “encourage or facilitate” test may not go far enough. The court ordered the FEC to explain why it did not also prohibit communications merely “informing” persons of fundraising activity as solicitations. (Utility Workers v. FEC, DDC 2010)

These rules can be particularly problematic for trade associations due to the “prior approval” requirement for soliciting employees of member corporations. Many announcements that association managers might consider routine (and even necessary) communications with members (such as publicly thanking members who contributed to the PAC) can run afoul of the very broad solicitation standard.

Aristotle’s professional services professionals can assist PACs in navigating the solicitation rules in their fundraising campaigns, web sites, newsletters, and other communications, helping craft effective and fully compliant PAC campaigns. Please contact Jeff Ashe (803-524-2198), Katie Anderson (202-758-9218) or Dave Mason (202-543-8345, x 242) on the professional services team for a review of your PAC communications and advice about making your PAC more effective while keeping it compliant.

David M. Mason, J.D.,
Senior Vice President, Compliance Services

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Digital Politics

Tuesday, June 1st, 2010

Our CEO, John Aristotle Phillips, will be a guest on the Digital Politics internet radio show and podcast this afternoon discussing fundraising, voter targeting, and GOTV efforts. Go here to listen live at 12pm PST/4pm EST: http://wsradio.com/. You can also hear the podcast here.

John will be joined on the show by Stephen Hershkowitz, partner of the law firm Sandler, Reiff and Young and former assistant general counsel at the Federal Elections Commission; and Peter Pasi (Executive Vice President) and Ben Olson (eCampaign Director) from emotive.

________

Update

The podcast is now live – check it out! http://wsradio.com/internet-talk-radio.cfm/shows/Digital-Politics-Radio.html

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Post-Conference Blues

Tuesday, March 2nd, 2010

In the past, when I would get home from the annual PAC Conference or Innovate to Motivate, I would go through a series of withdrawal emotions – first, exhaustion.

Sessions all day and “networking” all night, I always needed to catch up on sleep. Once I was back at work, I would feel overwhelmed. There on my desk would be the large binder with notes, session information, legal questions and contacts I didn’t want to forget. Anxiety would set in, then reality – I had a job to do and I needed to catch up on emails, so I would push that large pile over to the corner until I had time.

We never have time. Our jobs, especially in light of the last year, have increasingly become more hectic and multidimensional. After almost 10 years of attending the winter conferences, I have some advice to pass along that I was given while I was managing the U.S. Chamber’s PAC.

Make the effort to stay in touch with new contacts. Even something as simple as friending new contacts on Facebook helps. You never know if you will need something, or more importantly, can help someone else. Or who will become your friends outside of the industry. In 2002, I was six months on the job, just out of college and arrived to my first conference early. I had lunch with Sheree Anne Kelly with the Public Affairs Council to learn more about the conference. Eight years later, I am still grateful for that lunch and the natural friendship that followed. PS. Congrats to SA for her recent promotion!!
Read your notes again. This may seem weird but I would take the notes from sessions and open up a document and type. What this did was allow me to see what I thought was important to remember and to look at that piece of information, after the conference, to see if it really was still relevant to what my PAC could do and what it was already doing. There are so many great ideas but you can’t incorporate them all. Take the top few and think about how to make them work for your PAC.
Audit. There are more audits than just financial. Have an outsider look at what you do – communicating with PAC members, how you raise money, which events work, who you write checks to and the effect it has for your organization. I would ask someone from the outside to look in – either a recent contact or, if you really want to jumpstart your PACs potential, an organization with experience, such as Aristotle. Our PAC staff has actively managed some of the most successful PACs in the country and the knowledge pooled together has had amazing results for our clients.

Lastly, I still have my notes from the last nine years of conferences and all the binders and session handouts that seemed relevant to my career. Yes, I’m a proud nerd. My last suggestion is to keep what matters and what you can see yourself using over the years. Although I was sad to miss my first conference season in my career, I am thoroughly enjoying my newest challenge, motherhood. And I can’t wait to bring the little man along next year to meet all of the amazing friends I have made over the years.

Theresa Brown

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Using the Carrot Instead of the Stick

Tuesday, February 23rd, 2010

thank-you One of the blogs that I follow — TechPresident – recently posted an interesting piece on the use of positive reinforcement in the grassroots campaign to include a public option in the health care bill.

The blog sums up the situation on the Hill far more eloquently than I can, so I’ll let you read what they say about what’s going on with the campaign’s strategy. But the article brought several questions to my mind that many of our clients deal with on a regular basis – how effective are thank-you-letter campaigns at garnering goodwill on the Hill, and are they a good use of our grassroots organization’s time? With limited time and resources, is it worthwhile to engage advocates in a thank-you-letter campaign? Or is it better to wait until action is needed to positively influence legislation in order to prevent going to the well too many times?

I tend to think that you can’t say thank you enough – both with your advocate base and with your legislative targets. We’ve had many clients who have increased response rates among their advocate bases simply by implementing a consistent and meaningful recognition program.

Experience also has shown our team that keeping constituents engaged on issues, even when there isn’t a pressing issue going on, is important to the long-term health of grassroots programs.

I’m interested in hearing about other experiences from the field. Have any of you experienced an enhanced relationship with a legislator because of a concerted effort to use the carrot instead of the stick? It certainly appears to be getting some traction with the public option effort, although whether it’s enough to get the bill passed remains to be seen.

Amy Meli
Director, Grassroots Services

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Prep Your “PAC Talk” with the CEO

Thursday, July 30th, 2009

You’re the PAC manager.
Your job is to grow the PAC.
You need real buy-in from the CEO and his/her direct reports to do your job.
Your boss says it’s your responsibility to present the case.

How can you be effective?

Here are a few simple suggestions, learned over the years, that might be helpful.

Be prepared! This is the Boy Scout motto and for good reason. When Baden Powell, generally recognized as being the founder of the World Scout movement, was asked, “Be prepared for what?” He replied, “Why, for any old thing.” Make sure you have the information you need to answer any questions that may come up. Engage colleagues beforehand to suggest questions that may be asked in the meeting. Then, get the answers so that you can deliver.
Arrive early for the meeting. Surely your mom told you not to be late. You can’t deliver if you aren’t there. Believe me, there is nothing worse than having the highest paid executives in the organization waiting on you because you are late. Build in plenty of time so you are relaxed and ready to go when it’s your turn.
Plan for 30 — expect 10. I can’t tell you how many times I’ve been told, “Jeff, you will have 30 minutes.” Then, I end up getting ten. Everyone wants to have their day in the sun and if you aren’t first on the agenda, other presentations may run over the amount of time allotted. Don’t expect the PAC to be a topic that falls into the this category. Most likely, this is where an attempt will be made to save time.
Have an objective and an agenda. Make sure this is clearly stated ahead of time with the meeting organizer and state it again first thing in the meeting. My objective today is to garner your support in growing our PAC. Make no mistake about it — everyone in the room will know exactly what you mean. And that you aren’t afraid to ask.
Be concise and stay on point. There will be plenty of opportunities to go off course, to expand too much and to give lengthy examples. Your time is limited. Keep bringing it back to your objective and keep marching forward. You’re on a mission and you’ve got one chance. Make sure you tell them what you need and why you need it.
Get their support and then get out. After you have what you need, there is no reason to stay longer. The truth is that decisions are made in these types of meetings, action usually takes place later. Just because someone nods or says aloud that they will support the PAC doesn’t mean the money is in the PAC bank account yet. There will be plenty of work in following up with everyone afterwards.

– Jeff Ashe

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This Heading Should Be Neither Clever Nor Cute

Wednesday, June 17th, 2009

In yesterday’s teleconference organized by Network for Good, Farra Trompeter , Vice President of the communications agency, Big Duck, gave tips for writing on the web. Going off the premise that the viewer has a very short attention span, straight-forward, eye-catching material was strongly advocated for any successful webpage. Simple content and headings without any humor were advocated, metaphors were rejected, and headings that are neither “clever nor cute” were strongly encouraged. Big words should also be avoided and simple sentences used.

From a marketing standpoint this seems to make sense, but with the internet making more and more technologies obsolete is this a reason for concern? For example, as more and more people go on the web for their daily news updates, the newspaper industry is in steep decline. Many newspapers are no longer in business or are moving to a solely web-based readership, but if the creators of these sites have the primary aim of catching our attention, and not actually the content, is this a problem? What are the implications of online news sources using simplistic sentences and primarily a summary format for their news stories? I can’t decide if as a viewer it should be my job to fight against what appears to be the “dumbing down” of the internet, try to be a more engaged viewer, and reject the different ploys being used to garner my attention, or give in, like the majority of people surfing the web (according to Ms. Trompeter), as I enjoy colorful pictures, big headlines, and bullet point summaries.

- Emily Reynolds

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One-minute Storyteller: Making Emotional Connections with Supporters (and Potential Supporters)

Friday, June 12th, 2009

Big thanks to Network for Good for providing an all access pass to @MJRovner from Sea Change Strategies for The One-minute Storyteller: Making Emotional Connections with Supporters (and Potential Supporters) free teleconference.

Few unexpected tips from the teleconference:

Focus on a single person and tell that story, omit any generalizations to your larger group (i.e.: Spend time developing a character we care about and include high stakes)
Come out and state the reason you’re telling the story near the end (i.e.: Your $100 donation feed three stray dogs for a year)
Don’t include statistics! They kill a story – limit yourself to no more than one number per story.

Tune in to Network for Good every Tuesday this month for additional free teleconferences or keep reading Aristotle’s In The Know for additional reviews.

- Kristi

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Ben Katz, Aristotle’s CTO Interviewed on Digital Politics

Tuesday, March 17th, 2009

Aristotle’s CTO, Ben Katz, was a guest on the political radio show Digital Politics, discussing how the mindset of the “permanent campaign” effects the strategies of new candidates and elected officials. He focuses on the importance of maintaining contact with supporters and donors. You can listen here: http://signonradio.com/programs/digital-politics/

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In The Know

News and Analysis from the Aristotle Team

Archive for the ‘Fundraising’ Category

What is a PAC Solicitation?

Digital Politics

Post-Conference Blues

Using the Carrot Instead of the Stick

Prep Your “PAC Talk” with the CEO

This Heading Should Be Neither Clever Nor Cute

One-minute Storyteller: Making Emotional Connections with Supporters (and Potential Supporters)

Ben Katz, Aristotle’s CTO Interviewed on Digital Politics

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