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PAC DISCLOSURE REQUIREMENTS

 

1.  Any organization or entity that accepts contributions, makes expenditures, or incurs debts in excess of $750 to advocate for or against candidate or for or against the passage of a ballot issue is defined as a PAC. 

2.  An entity that meets the financial filing threshold of $750 must organize and register as a PAC by filing a Statement of Organization with the Ethics Board within 10 days of crossing the threshold.  Any subsequent changes in the information disclosed on a Statement of Organization must be disclosed by filing an amended Statement within 30 days of the date of the change.    

3.  A PAC that uses an abbreviation or acronym as part of its committee name shall provide a written explanation of the full word or words that are abbreviated or form the acronym.  The PAC name may not substantially duplicate the name of an already registered committee. 

4.  PACs must appoint both a chair and treasurer, each of who shall be at least 18 years of age. 

5. A PAC must either have an Iowa resident as the treasurer or maintain all of the PAC's funds in bank accounts in a financial institution located in Iowa. 

6.  PAC expenditures must be remitted to the designated recipient within 15 days of the date of the issuance of the payment. 

7.  Contributions to a PAC must be submitted to the PAC within 15 days of the date of the check.  This includes contributions from other PACs.     

8.  The PAC treasurer must deposit all contributions within 7 days of receipt. 

            9.  All PAC funds must be segregated from any other funds of the committee or any officers of the committee.  However, a permanent organization that temporarily engages in activities that qualifies it as a PAC under 68A.6 that only makes expenditures from its existing general operating funds is not required to open a separate account. No funds or property of a PAC may be used for the personal benefit of any officer or member of the PAC. 

            10.  PAC treasurers must keep a detailed and exact account of the following: 

1.  All contributions and expenditures. 

2.  The name and mailing address of every person making contributions to the PAC in excess of $10 (including the date and amount of the contribution). 

3.  The name and mailing address of every person to whom expenditures are made (including the purpose of the expenditure and the date and amount). 

11.  PAC treasurers must preserve all campaign records for a period of 5 years.  However, a committee is not required to keep records for more than 3 years from the certified date of the dissolution of the committee (68A.203(4)). 

12.  Once a PAC has been organized and registered, it must file campaign disclosure reports.  PACs file their reports with the Board.   

13.  Even if a PAC has not made expenditures or taken in contributions during a reporting period, the PAC must at least file a DR-2 campaign disclosure summary page on or before the required due date. 

14.  State PACs file their reports as follows:

Election year (Even numbered years)

Report Due    Period Covered
May 19   January 1 through May 14
July 19    May 15 through July 14
October 19   July 15 through October 14
January 19   October 15 through December 31

Non-Election year (Odd numbered years)

July 19   January 1 through June 30
January 19   July 1 through December 31

15.  If the reporting due date falls on a weekend or holiday that the Ethics Board is closed, the reporting due date is extended to the next working day following. 

16.  It is crucial that disclosure reports are filed on or before the due date as automatic civil penalties are imposed for late-filed reports.  If a report is not filed after a delinquency notice is sent by the Ethics Board, a contested case will be set and more severe sanctions may be imposed.  Under the law, PAC chairs are responsible for filing reports and are subject to liability for failing to do so. 

17.  PACs must disclose all PAC campaign activities. Effective July 1, 2005, PACs hiring a consultant must file Schedule G. PACs do not have to account for campaign property (thus do not file Schedule H).  

18.  PACs must disclose the name and address of all contributors who give in excess of $25 in a calendar year.  PACs that receive dues payments from payroll deductions must be very careful in making sure that proper disclosures are made and should contact the Ethics Board for assistance. 

19.  PACs must disclose candidate ID numbers and the PAC check number on the disclosure report when making contributions to statewide and general assembly candidates.  A list of candidate ID numbers is available from the Ethics Board or on the Board's Web site by clicking on the Candidate/PAC/Lobbyist/Address List. 

20.  A PAC that is no longer accepting contributions or making expenditures may dissolve by expending all PAC funds, transferring or paying all debts, and filing a DR-3 Notice of Dissolution.  Until a Notice of Dissolution is filed, the PAC must continue filing disclosure reports on or before the appropriate due date. 

21.  PAC political mailings and advertisements must contain the words "paid for by" along with the name of the PAC.  If the mailing contains numerous pages, the attribution only needs to appear on one page.  Both the statute and the rules exempt small items or items where printing the statement would be impracticable (pencils, political business cards, clothing).  Also, yard signs (16 square feet or smaller) are not subject to the requirement (see rule 351-4.39 for additional information concerning yard signs versus outdoor advertising). 

           22.  Remember that PAC expenses are not the same as lobbying expenses.  PAC expenses are reported under Iowa Code chapter 68A and lobbying expenses are reported under Iowa Code chapter 68B.  Unless lobbying expenses come out of PAC funds, lobbying expenses are not disclosed by the PAC.  Also, a lobbyist does not need to report any campaign contributions made by a PAC.  Rather, the lobbyist reports contributions made to candidates for state office by the lobbyist.