Topic: Lobbying Regulations
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Can an Illinois political action committee (PAC) use its state-issued committee ID in lieu of an employer identification number (EIN) when opening a new account? A PAC told us that it is not obligated to get an EIN or file a tax return. The State Board of Elections Guide to Campaign Disclosure provides that a financial institution may require an EIN rather than using an individual’s SSN. It also provides that if interest is earned on invested campaign funds, the committee must also file an IRS report and an IDR report. We don’t want to violate either BSA or tax reporting requirements.
No, we do not believe an Illinois political action committee (PAC) can use its state-issued committee ID in lieu of an employer identification number (EIN) to open a bank account. PACs are political organizations subject to taxation under the Internal Revenue Code, though they may be entitled to certain exemptions. The IRS requires political organizations…
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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?
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…
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Can a state-chartered bank make a political contribution to a candidate for local office?
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 contributing to federal candidates. The FECA also prohibits national banks from making contributions to state and local candidates. However,…
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One of our affiliates is considering hiring a state lobbyist. Are there any compliance issues involved in hiring a lobbyist?
We do not see any problems with the company hiring a lobbyist, given that the lobbyist is in compliance with Illinois and federal election ethics laws; such activities are political speech and are protected by the First Amendment. However, there are three areas of law to keep in mind, particularly municipal securities’ lobbyist rules. Having…