Most of IPA’s members are firms, not individuals. Most PAC contributions, however, are made by individuals.* In order to raise meaningful funds for IPA PAC, IPA must be able to ask eligible employees of member firms to contribute to the PAC—and we need your prior approval in order to do so. 

It’s easy! Just complete the enclosed form and send it back to us! There are important limitations and conditions of prior approval:

• Prior approval must be granted in writing.
• A firm may grant prior approval to only one trade association PAC, such as IPA PAC, per calendar year. If your firm already has granted prior approval to another trade association PAC for this calendar year, we would be happy to receive your prior approval for next year! (Some firms alternate between two or more PACs, granting one PAC prior approval in even-numbered years and another PAC prior approval in odd-numbered years.) 
• A firm may grant prior approval for multiple years at a time, up to a maximum of five years, so that you do not have to complete a new prior approval form every year.
• You may further restrict, in any manner you deem desirable, your prior approval—such as by limiting the approval to specific identified individuals within your company, by limiting the method by which we may make the solicitation, by limiting the number of times per year we may solicit, and by requiring review and pre-approval of any solicitation before we can send it.

Federal law limits the scope of individuals who IPA may solicit for a contribution to IPA PAC. First, IPA can solicit its individual members. Second, with the prior approval of a member firm, IPA may solicit certain of the member firm’s eligible personnel to contribute to IPA PAC. A member firm’s eligible personnel include its executive and senior administrative personnel, shareholders and their spouses.*

* Generally, a firm’s executive and senior administrative personnel include employees who devote the majority of their work to performing policymaking, managerial or supervisory responsibilities, as opposed to performing administrative or support tasks. In practice, there are several methods of determining who at your firm is eligible. Generally, but not always, employees who are classified as exempt under the Fair Labor Standards Act are eligible. The FEC has posted guidance on its website, and we encourage you to consult your firm’s counsel if you have any questions. Certainly, however, your firm’s C-level employees and VPs should be eligible, as are its shareholders and compensated members of your board of directors—and also their spouses or partners.

IPA can use portions of membership dues and other general purposes donations to defray the overhead and administrative costs of operating IPA PAC, but the PAC generally cannot accept contributions from IPA member firms (except in certain limited situations*). This is why prior approval is so important. It is necessary so that we can raise funds from your firm’s eligible employees to be deposited into the PAC account, and then disbursed out as contributions from the PAC to candidates.

* Federal law prohibits PAC contributions from incorporated entities. In certain limited situations, a member firm that is organized as a partnership of LLC may be able to make a PAC contribution—without prior approval—that then would be attributed to one or more individual partners or members of the firm. Please contact IPA for more information.