The Iowa Ethics and Campaign Disclosure Board issues this Advisory Opinion sua sponte pursuant to Iowa Code section 68B.32A(12) and Iowa Administrative Code rule 351-1.2(1).
We note at the outset that the Board’s jurisdiction is limited to the application of Iowa Code chapters 68A, 68B, and rules in Iowa Administrative Code chapter 351. Advice in a Board advisory opinion, if followed, constitutes a defense of a subsequent complaint based on the same facts and circumstances.
QUESTION POSED
Can a candidate utilize campaign funds for sponsorship of an organization’s event without limitation to “enhance the candidacy” of the candidate?
OPINION
In Advisory Opinion 2008-18, the Board advised that a candidate could permissibly pay for a sponsorship to an event they did not attend so long as there was some correlation to the event enhancing the candidacy of the candidate. The Board now modifies and clarifies the limits of campaigns contributing sponsorship monies to organizations for campaign purposes.
Iowa Code section 68A.302(1) permits the expenditure of campaign funds for “campaign purposes, educational and other expenses associated with office, or constituency services” and prohibits the use of campaign funds for “personal expenses or personal benefit.”
Iowa Code section 68A.302(2)(i) prohibits the use of campaign funds for meals or food “except for tickets to meals that the candidate attends solely for the purpose of enhancing the candidacy or the candidacy of another person” or “payment for food and drink purchased for campaign related purposes and for entertainment of campaign volunteers.” Prior guidance has allowed candidates to contribute to an organization in order to attend a dinner because attendance at the dinner was to enhance the candidacy of the candidate. See Advisory Opinion 2003-12.
Since that time, Advisory Opinion 2024-02 clarified that 501(c)(4) organizations are not “charitable organizations” for purposes of the allowable transfer of candidate committee funds as sanctioned by 68A.303(1)(a) and donations to 501(c)(4) organizations by candidate committees are not permitted.
Recently, candidate committee reports show candidates have been making “sponsorship” payments to politically-affiliated 501(c)(4) and other organizations. These “sponsorships” are in significant amounts and do not appear to be tied to attendance at a dinner, event, or exhibit space to promote the candidate. Little, if any, information is provided showing how the sponsorship payment, which far exceeds the cost of attending a dinner or regular attendance at the event, benefits the candidacy of the candidate. Instead, it appears to be a transfer of candidate committee funds to an organization not permitted under Iowa law. These transactions are more akin to donations to politically-aligned organizations by the candidate rather than bona fide campaign expenses.
Merely providing a financial donation to an organization does not rise to the level of enhancing the candidacy of the candidate, regardless of the organization's political affiliation or its advertising of the candidate’s name as a donor. Therefore, Advisory Opinion 2008-18 is rescinded insofar as it allows candidates to provide sponsorship dollars to an organization without the candidate attending the event.
Candidates may continue to use campaign funds to pay for a sponsorship of an event in an amount that is equivalent to two dinner tickets to the event and/or a base-level exhibit booth if provided as a general benefit of sponsorship to all other sponsors. Any contribution over and above the base-level sponsorship of an event, such as purchasing an entire dinner table or paying an unadvertised and excessive sponsorship amount is not allowed under Iowa law. In addition, the candidate must actually attend the event for it to benefit the candidacy of the candidate. Any previous guidance contrary to this opinion is rescinded insofar as it conflicts with this opinion.
BY DIRECTION AND VOTE OF THE BOARD:
James Albert, Chair
Elaine Olson, Vice Chair
Jonathan Roos
Daniel Jessop
Leah Rodenberg
SUBMITTED BY:
Erika Eckley, Executive Director and Legal Counsel
ISSUED ON:
May 20, 2026
Pursuant to Iowa Administrative rule 351-1.3(3), a person who has received a board opinion may, within 30 days after the issuance of the opinion, request modification or reconsideration of the opinion. A request for modification or reconsideration shall be deemed denied unless the board acts upon the request within 60 days of receipt of the request. Pursuant to Iowa Administrative rule 351-1.3(6), a person who has received a board opinion or advice may petition for a declaratory order pursuant to Iowa Code section 17A.9. The Board will refuse to issue a declaratory order to a person who has previously received a board opinion on the same question, unless the requestor demonstrates a significant change in circumstances from those in the board opinion.