January 24, 2019
TO ALL INTERESTED PERSONS
Pursuant to Iowa Code section 68B.32A(12) and rule 351ā1.2, the Iowa Ethics and Campaign Disclosure Board issues this opinion on Iowa Code section 68A.301. We note at the outset that the Boardās jurisdiction is limited to the application of Iowa Code chapters 68A and 68B, Iowa Code section 8.7, and rules in Iowa Administrative Code chapter 351. Advice in a Board opinion, if followed, constitutes a defense to a subsequent complaint based on the same facts and circumstances.
QUESTION:
May a candidate committee accept contributions from a federal candidateās committee?
OPINION:
Iowa Code section 68A.301 states:
A candidateās committee shall not accept contributions from, or make contributions to, any other candidateās committee including candidateās committees from other states or for federal office, unless the candidate for whom each committee is established is the same person. For purposes of this section, ācontributionsā includes monetary and in-kind contributions but does not include travel costs incurred by a candidate in attending a campaign event of another candidate and does not include the sharing of information in any format.
Under federal law, it is permissible for a federal candidate to contribute to a non-federal candidate, but āonly in amounts and from sources that are consistent with [federal and] state law.āi Thus, because such a contribution is prohibited under Iowa law, it is impermissible for an Iowa candidateās committee to accept a contribution from a federal candidateās committee.
CONCLUSION:
A candidateās committee registered with the Ethics and Campaign Disclosure Board is prohibited from accepting a campaign contribution from a federal candidateās committee unless both committees are established for the same person.
BY DIRECTION AND VOTE OF THE BOARD
James Albert, Board Chair
John Walsh, Vice Chair
Jonathan Roos
Carole Tillotson
Mary Rueter
Elaine Olson
Submitted by Megan Tooker, Board Legal Counsel
iFEC Non-Federal Elections Rule, 11 C.F.R. Ā§ 300.62.