IBA Compliance Connection

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We are a state-chartered bank, and we have been asked to be a sponsor for a fundraiser for a candidate for a local office. Is this permissible?

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Yes, state banks may contribute to political candidates for state and local office, subject to the dollar amount limitations in the Illinois Election Code.

The Federal Election Campaign Act (“FECA”) prohibits corporations, including all banks, from directly contributing to federal candidates. The FECA also prohibits national banks from making contributions to state and local candidates. However, there are no federal or Illinois laws that prohibit a state bank from contributing to a state or local candidate, provided the contribution adheres to the dollar amount limitations in the Illinois Election Code (which are updated by the Illinois State Board of Elections on January 1 of every odd year to keep pace with inflation).

For resources related to our guidance, please see:

  • Illinois Election Code, 10 ILCS 5/9-8.5 (Establishes dollar amount limitations on contributions)
  • Illinois Election Code, 10 ILCS 5/9-8.5(g) (“On January 1 of each odd-numbered year, the State Board of Elections shall adjust the amounts of the contribution limitations established in this Section for inflation as determined by the Consumer Price Index for All Urban Consumers as issued by the United States Department of Labor and rounded to the nearest $100. The State Board shall publish this information on its official website.”)