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Guidance on Reporting Staff Time
To provide full disclosure of its campaign financial activity, a ballot question committee must report the source of funding for all expenditures, including paid staff time, made for the purpose of initiating, promoting, defeating or influencing a ballot question. If the organization that formed the ballot question committee has used or transferred funds from its general treasury for expenditures for paid staff as well as other expenditures, the amount of those funds or transfers should be reported as a contribution on Schedule A of the campaign finance report. Under 21-A M.R.S.A. §1056-B(2-A)(D), a ballot question committee must report “funds or transfers from the general treasury of an organization filing a ballot question report.”
The general treasury funds used or transferred should, at a minimum, equal the total amount of expenditures, less any individual contributions reported during the filing period.
Expenditures for Staff Time to Initiate, Promote, or Oppose a Ballot Question
If an organization has paid employees to initiate, promote, or defeat or influence a ballot question, those expenditures should be reported on Schedule B of the organization’s campaign finance report, listing the individual staff member as the payee. The committee should not report the combined total expenditures for all staff members as a lump sum.
The Commission staff believes it is sufficient to provide a combined total paid to each employee for the entire report period, and it is not necessary to list separately every salary payment made to the employee during the period. Reimbursements for travel or other expenditures should be reported separately and not as part of compensation.
Donating Staff Time to Political Action Committees
If the organization that formed a ballot question committee has donated paid staff time to a political action committee formed by a coalition of organizations to initiate, promote, or defeat a ballot question, the ballot question committee would report the cost of the staff time as a Schedule B expenditure. The recipient PAC would report the receipt of an in-kind contribution on its report. The ballot question committee must report any donation of paid staff time to initiate, promote, or defeat a ballot question as an expenditure on Schedule B regardless of the recipient.
This advice is from the Commission staff and is not binding on the members of the Commission. If you have any questions about this advice or your reporting requirements, please feel contact the Commission staff at (207) 287-4179.
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