Minnesota Campaign Finance and Public Disclosure Board
cfb.mn.gov (651) 539-1180 (800) 657-3889

Judicial Candidate Handbook
Last revised 1/28/2024

Welcome ...................................................................................................................................................... 4
Starting a judicial candidate’s campaign committee .................................................................................... 6
Do I need to form a campaign committee? ............................................................................... 6
What does a candidate’s campaign committee do? .................................................................. 6
Who should be the committee chair and treasurer?.................................................................. 7
Does the committee need a bank account? .............................................................................. 9
How do you register with the Board? ........................................................................................ 9
What is the time limit for registering? ...................................................................................... 10
What penalties apply if you don't follow the laws for starting a committee? ............................ 10
Receiving contributions .............................................................................................................................. 11
Where to find the Code of Judicial Conduct ............................................................................ 11
What is a contribution? ............................................................................................................ 11
How often do you need to deposit contributions? ................................................................... 15
A note about independent expenditures.................................................................................. 15
How should you handle loans? ............................................................................................... 15
Who can give you contributions? ............................................................................................ 16
Who can’t give you contributions?........................................................................................... 17
What do you do if you accept a contribution from a prohibited source?.................................. 17
What are the contribution limits? ............................................................................................. 18
What do you do if you accept a contribution that is more than the limits? .............................. 19
How should you handle joint contributions? ............................................................................ 20
What records do you have to keep?........................................................................................ 21
What penalties apply to contributions that don't follow the rules? ........................................... 22
Spending money ........................................................................................................................................ 24
What can a committee do with its money? .............................................................................. 24
What are the disclaimer requirements?................................................................................... 24
What are in-kind expenditures?............................................................................................... 25
What is the difference between campaign expenditures and noncampaign disbursements? . 26
What records must you keep?................................................................................................. 27
This document is available in alternative formats to individuals with disabilities by calling (651) 539-1180; (800) 6573889; or through the Minnesota Relay Service at (800) 627-3529.

What penalties apply to improper spending? .......................................................................... 29
Reporting to the Board ............................................................................................................................... 30
When do you need to file reports with the Board? .................................................................. 30
What are the reporting requirements just before an election (large contribution notices)? ..... 31
How do you report to the Board? ............................................................................................ 33
How do you get an exemption from the electronic filing requirement?.................................... 33
How do you report if you still file a paper form? ...................................................................... 33
How do you find registration numbers for contributors registered with the Board? ................. 34
How do you decide if money received by your committee should be reported as a contribution or as
income? ................................................................................................................................... 34
How to decide if a payment made by your committee should be reported as a contribution to anotherregistered entity. ...................................................................................................................... 35
What do you report to the Board? ........................................................................................... 35
How do you fix mistakes on a report? ..................................................................................... 38
What penalties apply to reporting? .......................................................................................... 38
After the election ........................................................................................................................................ 40
How do you terminate the committee? .................................................................................... 40
What penalties apply to committees after the election? .......................................................... 41
Common questions .................................................................................................................................... 42
Getting on the ballot ................................................................................................................ 42
Economic interest statements ................................................................................................. 43
How to get a federal tax ID number (EIN) for political purposes ............................................. 43
How do you find registration numbers for contributors registered with the Board? ................. 44
How do you decide if money received by your committee should be reported as a contribution or as
income? ................................................................................................................................... 44
How to decide if a payment made by your committee should be reported as an expenditure or as acontribution to another registered entity. ................................................................................. 45
Online contributions................................................................................................................. 45
Fundraiser reporting examples................................................................................................ 46
Joint fundraising events........................................................................................................... 47
Conducting raffles or drawings ................................................................................................ 47
Conducting auctions ................................................................................................................ 47
Having policies to help control your money ............................................................................. 48
Closed captioning resources ................................................................................................... 49
Criminal penalties .................................................................................................................... 492

Getting help ............................................................................................................................................... 50
What is the role of Advisory Opinions? ................................................................................... 50
Complaints .............................................................................................................................. 50
How do you contact the Board? .............................................................................................. 50

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Welcome
This handbook was written for you by the staff of the Campaign Finance and Public Disclosure
Board. The Board was created by the Legislature back in the 1970’s. Its job is to oversee andpublish information about money used to influence state and some local elections in Hennepin
County. This includes elections for state judicial candidates. You can learn more about themission and members of the Board on our website at cfb.mn.gov.
This handbook is for campaign committees run by candidates for state judicial offices. The
state judicial offices are district court judge, court of appeals judge, and supreme court justice.
If you are a candidate for another state office, this handbook is not for you. You need a different
handbook that was written for legislative and constitutional office candidates.
This handbook will tell you about the campaign finance laws that apply to starting and running a
judicial candidate’s campaign committee. The Code of Judicial Conduct has additional rules forjudicial elections. The Code is available on the Board of Judicial Standards website. This
handbook does not discuss the Code of Judicial Conduct because the Campaign Finance andPublic Disclosure Board does not oversee those provisions. Instead, this handbook discusses
only the campaign finance laws that are enforced by the Campaign Finance Board.
If you print this handbook, please check the Board website periodically for updates. Look at the"Last revised" date on the first page of the online handbook to see if you have the latest version.
We have not tried to answer every possible campaign finance question in this handbook. When
you can’t find the answer to a question here, please call or email us. You can find out which
staff member can best help you by looking at the Getting Help section. You also can look at our
website for additional information. All the forms you need also are available on our website.
If a candidate is going to spend only their own money and the only campaign cost will be thecost of filing for office, the candidate does not need to register a campaign committee with theBoard or file any reports with the Board.
If a candidate, however, is going to accept more than $750 in donations, the candidate mustregister a campaign committee with the Board. The candidate’s committee will collect donations
from people who support the candidate and will spend money to help the candidate get elected.
The candidate’s committee must regularly report these contributions and expenditures to theBoard. The information in the report is posted on the Board’s website so the public knows who
is spending money to influence the public’s votes.
Each candidate’s committee has one person in charge of the money. That person is called thetreasurer. The treasurer has an important job, which is making sure that the committee follows
the campaign finance laws. The treasurer also must make sure that the committee follows theelection provisions in the Code of Judicial Conduct. The treasurer’s job takes time and requires
a person who is willing to accept a lot of responsibility.
4The treasurer must receive, keep records on, and report all money coming into the committee.
The treasurer has to approve all spending and make sure that the committee’s money is used inlegally permitted ways. If the committee enters into transactions that violate state laws or fails
to file proper reports on time, the treasurer and the candidate are responsible to the Board. You
should not become a treasurer unless you are willing and able to take on these responsibilities.
If you already are a treasurer, you should be sure that you know what is expected of you andyou should help the committee find another treasurer if you are unwilling or unable to accept thetreasurer's responsibilities.

5Starting a judicial candidate’s campaign committee
Overview
This chapter tells you whether you need a campaign committee, what a candidate’s campaign
committee does, and how to set up a committee.
Topics covered
Do I need to form a campaign committee?
What does a candidate’s campaign committee do?
Who should be the committee chair and treasurer?
Does the committee need a bank account?
How do you register with the Board?
What is the time limit for registering?
What penalties apply if you don't follow the laws for starting a committee?
Do I need to form a campaign committee?
A judicial candidate does not need to form a campaign committee if••

the candidate will spend only the candidate’s own money on the campaign, or
the candidate will not accept contributions totaling more than $750 from other people.

Although a candidate who spends only their own money is not required to form a campaign
committee, the candidate still must file campaign reports with the Board once more than $750
has been spent within a calendar year. The reports must be filed according to the schedule thatapplies to campaign committees. The reports also must comply with the requirements for
campaign committee reports.
If the candidate is going to receive more than $750 from supporters to get elected, thecandidate must form a campaign committee. The rest of this handbook assumes that you needa campaign committee and will help you to understand how to form and operate that committee.
What does a candidate’s campaign committee do?
The candidate is in control of their campaign, but the financial transactions of the campaign
must be made through the committee. The candidate cannot accept or spend money for the
campaign outside of the committee. All contributions, including money from the candidate, must
go to the committee. Campaign expenditures are then made by the committee.
A candidate can have only one campaign committee for each office sought. The candidate’s
campaign committee is known as the principal campaign committee.

6Who should be the committee chair and treasurer?
Every candidate’s campaign committee must have a chair and a treasurer. The candidate
chooses the chair and the treasurer and can replace them at any time. The chair and thetreasurer can be the same person. Although the campaign finance laws allow a candidate to be
the chair and/or the treasurer, having a judicial candidate hold either of these positions probably
would violate the provisions in the Code of Judicial Conduct regarding elections. In any event, acandidate usually will not be a committee’s chair or treasurer because the candidate typicallywill focus on campaigning.
The chair’s duties are not specified in law. It therefore is up to the candidate and the committee
to decide what the chair's duties will be.
The treasurer is the key financial person in the committee. The campaign finance laws specify
many of the treasurer's duties. The committee cannot accept or spend any money when it does
not have a treasurer. The Board will send notifications and bulletins to the treasurer and use
the treasurer as the contact person for the committee. The treasurer’s job has several parts.
Recordkeeping
The treasurer must keep detailed records of all the contributions that the committee receives
and of all the money the committee spends. Some of the things that the treasurer must keep
records of include the following:
•
•
•
•
•

The total amount of money that the committee receives;
The name and address of anyone who gives more than $20 to the committee along withthe date and the amount of the contribution;
Every expenditure made by the committee along with the date and amount of theexpense;Every expenditure made by someone with the committee’s approval along with the date
and amount of the expense; andThe name, address, and Board registration number of any political committee or fund,candidate’s committee, or party unit to which the committee gives money along with thedate and amount of the contribution.

This list of recordkeeping tasks is just a sample of what the treasurer must do. The different
sections of this handbook provide more details about the records that must be kept for eachkind of transaction.
Good records are important because candidates must tell the public who has given them money
and what they did with those contributions. Also, there are limits on the amount of money andhelp that a candidate’s committee can receive. Many of these limits apply to contributions given
over the course of a two-year period. Without good records, the committee cannot know if thetotal amount received from someone over the two-year period is more than the allowed amount.
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The committee also will not have the information needed to prepare its reports. The treasurer orthe candidate must save the records for four years.
Knowing general campaign finance laws
The treasurer does not need to know all the campaign finance laws. But a treasurer should
know enough about these laws to spot potential problems. The treasurer also should know
where to find campaign finance information and how to get additional help when needed. For
example, if a treasurer generally knows that there are contribution limits on the total amount thatan individual can give the committee, the treasurer will understand how important it is to checkthose limits whenever the committee receives an initial contribution or a second contribution
from the same person. The treasurer should know that the specific contribution limits and otherimportant information are available in this handbook and on the Board’s website. The treasurer
also should know that Board staff members are available to answer campaign financequestions.
Reconciliation
The committee’s records are like bank statements. The treasurer regularly must compare thecommittee’s actual cash on hand with its receipts and spending records. If the committee's
records do not reconcile with the bank's records, the treasurer must find and fix the problem.
Reporting
The treasurer must report all receipts and spending to the Board. There is only one reportrequired during a non-election year. The number of reports due during an election year
depends on the office for which the candidate is running and whether the candidate wins any
primary election. The reporting section of this handbook has more details about the number ofreports required and their due dates.
In addition, just before the election, the treasurer must report large contributions as they
happen. The treasurer signs each report to confirm that the information is complete, true, andcorrect. Because the treasurer is responsible for the report, all of the committee’srecordkeeping and reconciliation should be done by the treasurer or under the treasurer’s close
supervision. If the candidate is the treasurer, the candidate must file the committee’s reports.
The Board has a free online application called Campaign Finance Reporter Online (CFRO).
You may use CFRO to keep the committee’s records. CFRO incorporates the campaign
finance laws. As you enter transactions, it will alert you to possible problems. If you entertransactions regularly, you should have time to fix most problems before a violation occurs. You
may use CFRO to file campaign finance reports, which must be filed electronically unless you
have been granted a waiver from the electronic filing requirement.

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The Board periodically offers training sessions for CFRO. CFRO tutorial videos also areavailable on the Board’s website. Finally, you can always call the Board if you need additional
support.
Does the committee need a bank account?
Yes. Money given to a candidate’s campaign committee cannot be mixed with any othermoney. You must open a separate bank account for the campaign committee. The bankaccount must be called the “Campaign Fund of (name of candidate).” The name on the checks,
however, can be the name of the committee. The treasurer must have signing authority for theaccount. The Board strongly suggests that the chair or the candidate also have signingauthority for the account in case the treasurer resigns or is unable to carry out the job’s duties.
This is also a good tool for financial control because it ensures that at least two people haveaccess to the official bank records.
To open a bank account, you need an identification number from the Internal Revenue Service(IRS). The IRS has two types of identification numbers: an individual number (TIN) and an
employer number (EIN). The IRS gives EINs to political organizations, even those that are notactually employers. The IRS has EIN information on its website and an EIN online application.
You also can call the IRS at (800) 829-4933 or send the IRS an SS-4 Application for an
Employer Identification Number. For more detailed help, see the step-by-step instructions in the
Common Questions section of this handbook.
Some candidates decide to open their campaign checking account as a personal account. Yourbank will let you know if this is an option. If it is, you will use your social security number as
your identification number.
All money received by the campaign committee must be deposited into the committee’s bankaccount.
How do you register with the Board?
After you have opened the campaign committee’s bank account, you may register thecommittee with the Board. If you are unable to open a bank account before registering with theBoard, you may register with the Board and open a bank account immediately thereafter. You
must use the Board’s registration form to register the committee.
On the registration form, you must report basic information such as the names and addresses of
the candidate, the committee, the committee’s officers, and the committee’s bank account. You
can deliver the form to the Board in person or by mail, fax, or email. At this time, a committee
cannot register online. The actual name of the committee is left to the candidate’s discretion,
but it typically includes the name of the candidate and either a reference to the office sought or
the judicial district in which the candidate is running. The registration form must be signed by
the treasurer or the candidate.
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If something that you list on the registration form changes, you must tell the Board within 10
days of the change. It is very important to promptly notify the Board of changes in thecommittee contact information because this is the information that the Board uses when it needs
to contact the committee. Changes must be in writing. You may use the same form to reportchanges or send an email or letter with the updated information.
If the candidate, or a committee officer, has personal contact information in addition to theinformation provided on the registration form, that information can be provided to the Board on
the alternate contact information form. The Board will not make the information on the alternate
contact form public and will only use this alternate information to contact the filer about
campaign finance matters. The contact information provided on the alternate contact form must
be different from the contact information provided on the registration form.

Remember to open mail from the Board promptly. Much of the information isdate sensitive.

What is the time limit for registering?
You generally must register the candidate’s campaign committee with the Board within 14 days
after receiving more than $750 from supporters or spending more than $750 to help thecandidate get nominated or elected.
If a candidate for district court judge receives more than $400 from any one source during the
14 days before the election, you must register a campaign committee for the candidate by theend of the next business day after receiving the contribution.
A supreme court or court of appeals judicial candidate must register a campaign committee by
the end of the next business day after receiving more than $2,000 from any one source during
the 14 days before the election.
What penalties apply if you don't follow the laws for starting a committee?
If you do not register the committee on time, the Board may charge a late fee of $25 per day, up
to $1,000. The Board may charge an additional penalty of up to $1,000 for not filing a
registration after the Board has sent notice that your registration is overdue.

10

Receiving contributions
Overview
This chapter tells you what things the committee can receive from people who want to help thecandidate get elected. It also tells you what records to keep for those contributions. You will
use the records to make reports to the Board.
Topics covered
Where to find the Code of Judicial Conduct
What is a contribution?
How often do you need to deposit contributions?
A note about independent expenditures
How should you handle loans?
Who can give you contributions?
Who can’t give you contributions?
What do you do if you accept a contribution from a prohibited source?
What are the contribution limits?
What do you do if you accept a contribution that is more than the limits?
How should you handle joint contributions?
What records do you have to keep?
What penalties apply to contributions that don’t follow the rules?
Where to find the Code of Judicial Conduct
The Code of Judicial Conduct has additional rules about contributions and judicial elections.
The Code of Judicial Conduct is available on the Board of Judicial Standards website. This
handbook does not discuss the Code of Judicial Conduct because the Campaign Finance Board
does not oversee those rules. Instead, this handbook discusses only the campaign financelaws that are enforced by the Campaign Finance Board.
What is a contribution?
A contribution is anything given to the committee, as well as approved expenditures. The
contribution can be money. A contribution also can be a thing or a service. Contributions ofanything other than money are called in-kind contributions. There are some exceptions to thegeneral rule that everything given to the committee is a contribution. A committee volunteer’stime is not a contribution. This volunteer time can include professional or technical services aslong as the service does not require the use of equipment or other resources from a business.
A committee cannot accept any contributions when it does not have a treasurer. All money thatthe committee receives must be deposited in the committee’s bank account. The committee’s
money cannot be mixed with anyone else’s funds. If possible, you should make a copy of any
checks before you deposit them. This will make it easier to reconcile the committee’s records.
11

The money that your committee uses to open its bank account is either acontribution or a loan from the person who provided the funds.

When the committee receives a contribution through an online contribution processor, the entire
amount given by the contributor is the amount of the contribution. The committee should not
subtract any processing fees when recording the amount of the contribution. The committee willreport the processing fees as a noncampaign disbursement to the contribution processor.
Sometimes a contributor will increase the size of a contribution to cover the processing fees forthe contributed amount. In this case, the committee should look at the total amount transferredto the committee by the processor to determine the amount of the contribution. If the processor
transferred the base contribution plus the amount given to cover the processing fees, theamount of the contribution would be the total of those two amounts. The committee then would
report the processing fees as an expenditure to the contribution processor. If the processor
transferred only the base contribution and kept the amount given to cover the processing fees,
the amount of the contribution would be the base contribution only. In this situation, thecommittee would not have any processing fees to report as an expenditure to the contribution
processor.
The Code of Judicial Conduct has additional rules about contributions in judicial elections. The
Code is available on the Board of Judicial on Judicial Standards website.
Vehicle use
The use of a personal car for campaign purposes by a volunteer or by the candidate is not acontribution.
A committee can choose to reimburse a volunteer or the candidate for the vehicle use. To
reimburse someone, you must use the IRS business mileage rate applicable to the year of
travel. The 2024 rate and the 2023 rate are available on the Board’s website. If you do
reimburse someone for vehicle use, you must report it as a campaign expenditure or anoncampaign disbursement, depending on what the person was doing while using the vehicle.
In-kind contributions
An in-kind contribution is always valued at fair market value. For example, if someone gives thecommittee a used computer, the value of the contribution would be the price for which the donor
could have sold the computer in the open market. The donor and the committee should agree
on the value of the in-kind contribution. There is an exception for things that are given to the12committee that have little value. You do not have to keep track of or report donations of goods
that have a market value of $20 or less.

Remember that every in-kind contribution is also an in-kind expenditure on thedate that it was accepted by the committee. The handbook section on
spending money tells you how to report in-kind expenditures.

Approved expenditures
Sometimes, an individual or a group will spend money on the candidate’s behalf. If thecandidate or the committee approves, or is in any way involved with the spending, the amountspent is a contribution to the committee. This type of campaign spending is called an approved
expenditure.
If someone wants to make an approved expenditure on the candidate’s behalf, the treasurer
must approve the expense in advance and in writing. The written approval must state theamount that can be spent and the reason for the spending. The Board has a form on its website
for approving an expenditure. A letter also is acceptable proof of approval. You should keep a
copy of the letter or the form for the committee’s records.
Approved expenditures are always in-kind contributions. The amount of the contribution is theamount spent on the candidate’s behalf. The date of the contribution is the date that thecontribution was accepted.
Notice required when selling items
Many times, a committee will try to raise money by selling t-shirts, hats, or other items.
Committees also sell tickets to fundraisers. The money that the committee receives from thesale of an item or a ticket to an event is a contribution to the committee. The entire amount paid
for the item is the amount of the contribution. The committee should not deduct the value of theitem purchased to determine the amount of the contribution.
When a committee sells goods or services to raise money, it must give notice to the purchasersthat the proceeds from the sale are a contribution to the committee. This notice must be given
verbally at the time of the sale or through a prominent sign displayed within three feet of thepoint of sale, if the sale is made in person. The notice must be prominently displayed on thepage used to make the purchase, if the sale is made through electronic means, such as a
webpage. If the committee is selling items at a location with more than one cashier, a noticemust be posted at each location where a purchase may be made.

13

The notice requirement does not apply to events where the main purpose is to conduct
fundraising or to goods or services sold at a fundraising event that requires the purchase of aticket to attend.

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Miscellaneous Income
A committee also could earn income such as interest on the committee’s bank account orproceeds from selling property that was used in the regular operation of the committee. Income
is not a contribution to the committee. Income is reported on a different schedule thancontributions and is not subject to the same restrictions as contributions.

The money that a committee gets from selling tickets to fundraisers is notincome. These funds are contributions from the people who bought tickets. The
Common Questions section of the handbook talks about specific issues related
to different types of fundraisers.

Because income is an exception to the general rule, contact Board staff if you have any
questions about reporting a receipt as miscellaneous income rather than as a contribution.
How often do you need to deposit contributions?
In general, you must deposit contributions within 10 business days of receiving the money. For
contributions received through electronic means, the committee receives the money on the datethat it has access to the funds under the terms of the agreement with the contribution processor.
For all other contributions, the committee receives the money on the date when it physicallyreceives the contribution. If possible, you may want to make copies of any checks before you
deposit them. This may make it easier to reconcile the committee’s financial records.
A note about independent expenditures
Sometimes individuals or groups will make expenditures on the candidate’s behalf without
consulting with or involving the candidate or the candidate's committee in any way. If theexpenditure meets the requirements of the law for independence, it is called an "independent
expenditure." An independent expenditure is not a contribution to the candidate and is notincluded on the committee's report. If you know about an independent expenditure in advanceor have had discussions about an independent expenditure, you should be very careful thatyour involvement has not converted the independent expenditure to a contribution. If in doubt,
ask for guidance from Board staff.
How should you handle loans?
All loans require a written agreement between the lender and the committee, even if the lenderis the candidate. The written agreement must include the date and amount of the loan and thename, address, occupation, and principal place of business of the lender and any co-signer orguarantor. All loans must eventually be either repaid or forgiven.

15

A loan or a loan guarantee is not a contribution until the loan is forgiven or it is paid by someone
other than the committee. If the loan is forgiven, the lender that forgave the loan is the donor of
the contribution. If the loan was repaid by someone other than the committee, the entity that
repaid the loan is the donor of the contribution. The amount of the contribution is the amount of
the loan that was forgiven or repaid.
Because a loan could turn into a contribution at some point in the future, loans from anyone
other than a financial institution are subject to the same contribution limits that would apply to acontribution from the lender. The amount of the loan must be added to the cash and in-kind
contributions from the same lender when checking to see if the lender’s contribution limit has
been reached. These contribution limits are discussed later in this section.
Financial institutions rarely give unsecured loans to candidate’s committees. In practice, a bankwill not loan money to a candidate’s committee unless someone guarantees or co-signs theloan. When someone guarantees or co-signs a loan for the committee, this promise could
become an actual contribution to the committee at some point in the future if the co-signer is
eventually required to pay off the loan. Because of this, the amount of a loan that an individual
may co-sign cannot exceed the contribution limit of the individual and counts against thecontribution limit from that individual.
Who can give you contributions?
You can take contributions from the following types of people:
•
•
•
•
•
•

Individuals who are not lobbyists;
Individuals who are lobbyists;
General purpose political committees and political funds that are registered with theBoard;
Political party units that are registered with the Board;
Another state candidate’s committee only if that candidate is closing down thecommittee within the 12 months; andGroups that are not registered with the Board if 1) the contribution is $200 or less or 2)
the group also gives you a disclosure form, or the address of a government website
where the form can be viewed, showing who gave the group money and how the groupspent that money.

The disclosure form from the unregistered group must list information that is required by the
campaign finance laws. The Board recommends that you not accept more than $200 from anygroup not registered with the Board. If you do want to take more than $200 from an
unregistered group, be sure to consult with Board staff so that you and the donor understandthe requirements before you accept the contribution.
If a group is registered with the Board, it must give you its registration number with its
contribution. Because some groups forget to include their registration numbers with their16contributions, you should always use the lists on the Board’s website to see if the group that
contributed is registered with the Board.

Remember, if a group gives you more than $200, the group also must give you
its registration number or a disclosure form. In lieu of a written form, the group
may give you the address of a government website where the form may beviewed.

Who can’t give you contributions?
Some people and groups cannot give anything to a candidate’s committee. You cannot takemoney, things, or any other contribution from the following people or groups:
•
•
•
•
•
•
•

Corporations;
Limited liability companies (LLCs);
Anonymous contributors unless the contribution is $20 or less;State candidate campaign committees, unless the committee is terminating within thenext twelve months;
Federal or local candidate committees;
Independent expenditure and ballot question political committees and funds; andAnyone who gives you money on the condition that you will give it, or any portion of it, toanother candidate.

Federal law also prohibits contributions from foreign nationals to candidate committees for any
level of office. More information on this prohibition is available at www.fec.gov/updates/foreignnationals/.

Your committee will not be able to accept contributions from most businesses
because most businesses are organized as some type of corporation or LLC or
are associations not registered with the Board.

What do you do if you accept a contribution from a prohibited source?
If the committee deposits a contribution from a prohibited source by mistake, it must give thecontribution back. If the committee returns a contribution from a prohibited source within 90
days of deposit, it does not have to include the contribution or the check returning thecontribution on the committee’s report and any violation associated with the contribution iscleared. If the prohibited contribution is returned more than 90 days after it was deposited, thecommittee still must return the contribution, but the full amount of the original contribution must
be included on the committee’s report. The report must also include a noncampaign
17disbursement recording the return of the contribution. The violation that resulted from theprohibited contribution is not cured by returning the contribution more than 90 days after it was
deposited and, as a result, will be dealt with by the Board. If a committee returns the actual
check from a donor without depositing it, nothing is reported to the Board.
If the committee receives an anonymous contribution that is more than $20, you must send it to
the Board within 14 days. The Board will add the money to the Public Subsidy Programaccount. You must send the entire amount of the anonymous contribution to the Board, not justthe amount over $20.
Sometimes the committee will know the name of a donor but will not have a piece of required
information, such as the donor’s address or employer/occupation. For example, the committee
may receive a contribution through an electronic processor that includes only the donor’s nameand email address. The committee must try to get the missing information for that contribution.
If the committee cannot get the missing information, it must treat the entire contribution as ananonymous one and forward it to the Board.
A committee also can refuse or return any contribution, or any part of a contribution, for its own
reasons.
What are the contribution limits?
Limits on contributions from individuals and political committee and funds
There are limits on the amount that one person or one political committee or fund can give to a
judicial candidate’s committee during a two-year period. A two-year period that ends on
December 31 of a year when the judicial seat sought is on the ballot is called an election
segment. Any other two-year period is called a non-election segment.
Because judicial offices have six-year terms, the election segment plus two non-election
segments make up the election cycle for those offices.
For most offices, the contribution limits are higher in an election segment than they are in a nonelection segment. For judicial offices, however, the contribution limit of $2,500 is the same forelection segments and for non-election segments. The $2,500 limit applies both to one-time
contributions and to the total amount given by one person over the course of the two-year
segment. Although the limits apply to contributions from individuals and from politicalcommittees and funds, the limits are commonly referred to as the individual contribution limits.
Limits on contributions from individuals and political committees and funds to judicial
candidates
Type of segment
Contribution limit
Election segment$2,500Non-election segment$2,50018

There is no limit on the amount that a judicial candidate may give the candidate’s own
committee.

The individual contribution limit also applies to members of the candidate’s
family.

Bundled contributions are contributions delivered to the committee by someone other than theoriginal contributor. A candidate's committee may not accept contributions delivered by aperson if the total of contributions made and delivered by that person exceeds the applicable
individual contribution limit.
Each individual contribution in the bundle is also treated as a contribution from the originalcontributor and counts against the contribution limit applicable to that contributor as well. The
bundling restrictions do not apply to contributions delivered by one spouse on behalf of anotheror to contributions collected by a member of the candidate’s campaign committee. It is up to thecandidate to determine the process for making people members of the committee. However, toavoid bundling violations, a written record of committee members should be kept.

Loans and loan guarantees from sources other than financial institutions are
subject to the contribution limits.

Aggregate political party unit and terminating candidate committee limits
Although many judicial candidates do not accept contributions from political party units, there
also is a limit on the total amount that can be given to a judicial candidate’s committee by all
party units and terminating state candidate committees combined. This limit is ten times theindividual contribution limit for the office sought.
Aggregate party unit and candidate committee contribution limits
Type of segment
Election segment
Non-election segment

Contribution Limit$25,000$25,000

What do you do if you accept a contribution that is more than the limits?
A single contribution that is more than the contribution limits is called a facially excessive
contribution. A committee cannot accept a facially excessive contribution unless, at the sametime that the committee deposits the contribution, it also writes a check to the contributor for theexcess amount of the contribution. The committee would report to the Board only the amount19

kept as a contribution. But the committee should record both the contribution and the refund in
its own records so that they match the committee’s bank statements.
If the total amount of all contributions from a donor is more than the contribution limits, thecommittee still must return the excess amount but it has 90 days to do so. If the committee
returns the excess contribution within 90 days of deposit, it does not have to include thecontribution or the check returning the contribution on the committee’s report and any violation
associated with the contribution is cleared. Again, the committee should still record the receipt
and the return of the contribution in its own records so that they will match the committee’s bankstatements. If the excess contribution is returned more than 90 days after it was deposited, thecommittee still must return the excess amount, but the full amount of the original contribution
must be included on the committee’s report. The report must also include a noncampaign
disbursement recording the return of the excess amount of the contribution. The violation that
resulted from the excess contribution is not cured by returning the excess more than 90 days
after it was deposited and, as a result, will be dealt with by the Board.
How should you handle joint contributions?
Many times, people contribute to a candidate using a check written on a joint account.
However, campaign finance rules do not recognize joint contributions. Every contribution must
be reported as coming from one donor. This means that the treasurer must decide how toreport a contribution that is received in the form of a check drawn on an account with two names
on it.
When you receive a check written on a joint account, you can report the full amount of thecontribution as coming from the person who signed the check. If the amount of the check puts
the signer over the individual contribution limit, however, you will need to determine whether thecontribution can be split between the two people named on the account.
A person may deliver a contribution on behalf of the person’s spouse. If you receive a checkfrom a joint checking account, you must first determine whether the people named on theaccount are a married couple. If they are, you may split the contribution between the two
people if one of the following conditions is met: 1) you personally know that the check was
intended to be from both spouses; or 2) you contact the person who did not sign the check to
confirm that the check was intended to be from both spouses. You should make a note in yourrecords that explains how you treated the contribution and why.
Couples who are not married may not deliver each other's contributions. If a check from two
unmarried people is more than the limit that the signer could donate, it results in a contribution
limits violation. In that case, you must return to the donor the amount that exceeds theindividual contribution limit.

20

What records do you have to keep?
You must keep a record of everything given to the committee. You must keep the records forfour years. The four-year period starts on the date that the report containing the information is
filed with the Board. If an amendment to that report is filed, the four-year period starts on thedate of the amendment. The campaign finance laws require larger contributions to be itemizedon the report. Specifically, for contributions over $200, you must list the name, address, andemployer of the donor, or occupation if self-employed, the date and amount of the contribution;and the donor’s board registration number if the donor is registered with the Board. If one donor
has given multiple contributions that total more than $200, you must itemize them all, listingeach contribution separately on the report under the donor’s name. Contributions from donors
who have given $200 or less, in total, should be added together and listed as a lump sum on thecommittee report to the Board. However, you still have to keep an internal record of each ofthese contributions.
Many times, an initial contribution will be too small to report as an itemized contribution. The
campaign finance itemization laws, however, apply to all contributions given over the course of
the year. If you do not keep good records, you will not be able to tell when a donor’s total
contributions reach the itemization level. The contribution limits also apply to the total of allcontributions received from the same donor during a two-year period. You will need toaccurately track contributions to avoid exceeding the contribution limits.
Although you should keep records of everything given to the committee, the detail of eachrecord depends on the amount given. The specific rules are described in the sections below.
There also are examples of how to record and report transactions related to some typicalfundraisers in the Common Questions section of the handbook.

If you use an electronic reporting system like CFRO, regularly add donation
information to take advantage of the compliance checks within the system.

Contributions of $20 or less – Cash
For a cash contribution of $20 or less, the only thing you must record is the amount and the datethe contribution was received. You may choose to record the name of the contributor for thecommittee’s own use. But the law does not require you to record more than the amount anddate of the contribution.
If you collect money through small donations put in a jar or box, you should tell donors that if
they want to donate more than $20, they should see the treasurer so you can get their donation
information. Donations of $20 or less collected through a donation jar are reported with othernonitemized contributions regardless of the total amount put in the jar.

21

Contributions of $20 or less – In–kind
You do not have to record or report anything for an in-kind contribution that is $20 or less.
Contributions over $20 but not more than $200 – Cash and In-kind
For all contributions over $20 but not more than $200, you must record the name and addressof the donor, the date the contribution was received, the amount of the contribution, and, for inkind contributions, a description of what was donated. If the donor is registered with the Board,
you must record the donor’s Board registration number. Registered donors must put thisregistration number on the contribution. If the donor does not put the registration number on thecontribution, you must get the number yourself. You can contact the donor or use theregistration lists on the Board’s website.
Contributions over $200 – Cash and In-kind
For contributions that are more than $200, you must record the same information required forcontributions over $20 but not more than $200. In addition, you must record the donor’s
employer or, if self-employed, the donor’s occupation.
Each reporting period includes all contributions received during the year, not just thecontributions received since the last report. If you use CFRO, it will automatically keep track ofyour donors by type and in alphabetical order. In addition, CFRO will allow you to easily comply
with the requirement that reports be filed in electronic form.

Remember that the contribution limits apply to contributions given over thecourse of the two-year segment while the itemization requirements apply tocontributions given over the course of the calendar year.

What penalties apply to contributions that don't follow the rules?
The Board may impose a penalty of up to $1,000 for the following things:
•
•
•
•
•

Accepting a contribution when the committee does not have a treasurer;
Not keeping records of contributions;
Mixing committee funds with other money;
Not depositing contributions promptly; andAccepting an anonymous contribution over $20.

If the committee takes a contribution from a group that is not registered with the Board and thecontribution is more than $200, the Board may impose a penalty of up to four times the amount22

of the contribution that is over $200 if the required disclosure statement is not obtained and filedwith the Board.
If the committee takes a contribution that is more than the limit for that type of contribution, theBoard may impose a civil penalty that is up to four times the amount by which the contribution
exceeded the limits.
The Board may impose a penalty of up to $3,000 for the following things:
•
•
•
•
•

Trying to get around the contribution limits by making contributions through anotherperson or on behalf of another person;
Knowingly failing to keep records of contributions or being a candidate affiliated with atreasurer who fails to keep records of contributions;
Accepting a prohibited contribution from a corporation;
Willfully failing to promptly amend a report or statement when instructed to do so by the
Board; andFiling a report or statement knowing that it is false or omits required information or being
a candidate affiliated with a treasurer knowingly filed a false or incomplete report.

One of the most common contribution mistakes is taking a donation that is overthe contribution limits.

23

Spending money
Overview
This chapter tells you what the committee can do with its money. It also covers what records tokeep of your spending. You will use those records to make reports to the Board.
Topics covered
What can a committee do with its money?
What are the disclaimer requirements?
What are in-kind expenditures?
What is the difference between campaign expenditures and noncampaign
disbursements?
What records must you keep?
What penalties apply to improper spending?
What can a committee do with its money?
Campaign committees make campaign expenditures, noncampaign disbursements, andcontributions. Campaign expenditures are payments made to help a candidate get elected.
There are limits on campaign spending for candidates for legislative and constitutional offices
who have signed public subsidy agreements. Some things that these committees spend theirmoney on do not count towards their spending limits. These things are called noncampaign
disbursements. There is a list of noncampaign disbursements near the end of this chapter.
There are no spending limits for judicial candidates. Judicial candidates, however, still reporttheir committee spending as campaign expenditures and noncampaign disbursements.
Consequently, treasurers for judicial candidate committees still must know the difference
between these two types of spending.
A judicial candidate’s campaign committee also may make contributions to political parties,
political committees, and political funds, if permitted by the Code of Judicial Conduct. A
committee may make contributions to 501(c)(3) charities of $100 per charity per year.
Money collected for political purposes cannot be used by or loaned to anyone for personalreasons. A committee also cannot make contributions to federal or local candidates.
What are the disclaimer requirements?
All campaign material must include a disclaimer, which is a statement of attribution that tells
who is responsible for producing and distributing the material. The campaign finance laws arevery specific about the words that must be used in the disclaimer. When a candidate’s

24committee is involved with producing or distributing the campaign material, the following
disclaimers must be used.
For campaign material that is distributed through broadcast media, the disclaimer must state“Paid for by the ………..committee.” If the material is produced and broadcast without cost, thedisclaimer must state, “The ……….committee is responsible for the content of this message.”
For all other campaign material prepared and paid for by the candidate’s committee, thedisclaimer must state “Prepared and paid for by the ……….. committee, ……………(address).”
If the material is produced and distributed without cost, the words “paid for” may be omitted fromthe disclaimer. The address in the disclaimer must be either the committee’s mailing address or
the committee’s website address if the website includes the committee’s mailing address.
For written communications other than outdoor signs, websites, or social media pages, thedisclaimer must be printed in 8-point font or larger. The disclaimer requirement is satisfied foran entire website or social media page when the full disclaimer appears once on the homepageof the site. On a Facebook page, the full disclaimer should be in the banner picture for the siteor in the About section.
The disclaimer requirement does not apply to the following items:••••

Fundraising tickets, business cards, personal letters, or similar items that are clearly
being distributed by the candidate:Bumper sticker, pins, buttons, pens, or similar small items on which the disclaimer
cannot be conveniently printed;
Skywriting, wearing apparel, or similar items where it would be impracticable to include a
disclaimer; andOnline banner ads and similar electronic communications that link directly to another
online page that includes the full disclaimer.

What are in-kind expenditures?
In-kind expenditures result ONLY from the committee’s receipt of in-kind contributions. They
are equal and complementary. Every in-kind contribution received by your committee results in
an in-kind expenditure on the date that the in-kind contribution was accepted by your committee.
Approved expenditures are a type of in-kind expenditure.

Remember that the committee’s in-kind expenditures must match its in-kind
contributions. For every in-kind contribution coming in, there will be acorresponding in-kind expenditure going out.

25

What is the difference between campaign expenditures and noncampaign
disbursements?
As discussed above, candidates for legislative and constitutional office can be bound by
spending limits. The things that do not count toward the spending limits are called
noncampaign disbursements. Although judicial candidates are not subject to spending limits,
judicial candidates still must report spending as campaign expenditures or noncampaign
disbursements. If you have questions about how to categorize an expense, contact Board staff
or consult the Guide to Noncampaign Disbursements on the Board’s website.
The following is the current list of noncampaign disbursements applicable to judicial candidates:
•

•
•
•

•
•
•

•
•
•
•
•
•
•
•
•

•

Payment for accounting and legal services related to operating the candidate's campaign
committee, serving in office, or security for the candidate or the candidate's immediatefamily, including but not limited to seeking and obtaining a harassment restraining order;
Return of a contribution to the source;
Repayment of a loan made to the principal campaign committee by that committee;
Payment for food, beverages, necessary utensils and supplies, facility rental, andentertainment for a fundraising event (note that payment for advertising or invitations toa fundraising event is not a noncampaign disbursement);
Payment for food and beverages consumed by a candidate or volunteers while engaged
in campaign activities;
Payment of candidate’s expenses for serving in public office, other than for personal
expenses;
Payment of up to $3,000 during a two-year election cycle segment for detection-related
security monitoring expenses for the candidate, including home security hardware,
maintenance of home security hardware, identity theft monitoring services, and credit
monitoring services;
Costs of child care for candidate’s children when campaigning;Fees, transportation, meals, and lodging paid to attend a campaign school;
Costs of a post-election party during the election year when a candidate’s name will nolonger appear on a ballot or after the general election;
Interest on loans;
Filing fees;
Post-general election holiday or seasonal cards, thank you notes, or advertisements inthe news media mailed or published before the end of the election cycle;
Costs of campaign material bought to replace defective campaign material, if thedefective material is destroyed without being used;
Contributions to a party unit;
Costs of campaigning incurred by a person with a disability, as defined in Minnesota
Statutes, section 363A.03, subdivision 12, and which are made necessary by thedisability;
Payments for funeral gifts or memorials;
26

•
•
•
•
•
•
•
•
•
•

Costs of the candidate attending a state or national political party convention held in
Minnesota;
Costs to an incumbent or a winning candidate of providing services to residents in the
district after the general election in an election year for the office held;
Payment of advances of credit in a year after the year in which the advance wasreported as an expenditure;
Payment of fines assessed by the Board;
Costs paid to a third party for processing contributions made by a credit card, debit card,or electronic check;
Costs paid to support the candidate's participation in a recount of ballots affecting thecandidate's election;
Funds donated by a terminating candidate committee to the state general fund or to a
county obligated to incur special election expenses due to that candidate’s resignation
Costs for a party given in honor of the candidate’s retirement from public office after thefiling period for affidavits of candidacy for that office has closed;
Costs paid to repair or replace campaign property that was lost, stolen, or damaged or
defaced to such a degree that it no longer serves its intended purpose; andContributions to a fund used to pay for recount costs of the candidate.

What records must you keep?
You must keep records of all the committee expenditures, including unpaid expenditures, in-kind
expenditures, and approved expenditures (which are a form of in-kind expenditure). Your
records must include the date and amount of each expenditure. You must keep the records forfour years. The four-year period starts on the date that the report containing the information is
filed with the Board. If an amendment to that report is filed, the four-year period starts on thedate of the amendment. The treasurer must approve all spending done by the committee. You
can use CFRO to keep track of your spending. You should regularly enter your spending into
CFRO.
There is one exception to the requirement that you record every expenditure. The exception isfor very small items that you purchase out of a petty cash fund. The treasurer or deputy
treasurer can take up to $100 per week from the committee's checking account and use thatmoney to pay cash for small incidental purchases. The committee must keep a record of each
withdrawal for the petty cash fund. As a best practice, the committee should get a receipt foreach reimbursement or payment made from petty cash, but does not report these individualtransactions to the Board.
For both cash and in-kind expenditures, you must record the following information:••

the date and amount of the expenditure, including in-kind expenditures;
the name and address of the vendor and the vendor’s Board registration number if thevendor is registered with the Board; and27

•a description of the item or service purchased, including how the item or service wasused.

If you are reimbursing someone for an expense that was more than $200 or paying a credit cardbill for an expense that was more than $200, you must keep some additional information. You
must keep the information listed above for 1) the person or company that you are paying for the
expense and 2) the vendor who actually sold the item or performed the service. For example, if
you reimburse a volunteer who paid more than $200 for a brochure, you must keep the following
information in your records:••••

the date and amount of the reimbursement expenditure;
the fact that the payment was reimbursement for a brochure;
the name and address of the person being reimbursed; andthe name and address of the vendor who produced the brochure.

If you reimburse someone for vehicle use, you must report it as a campaign
expenditure or a noncampaign disbursement, depending on what the person
was doing while using the vehicle.

You must have an invoice or a receipt for any payment over $100. If the committee spends
more than $200 with a vendor at one time or over the course of the year, you must itemize thepayments to that vendor. If you use CFRO, it will automatically group payments to a vendor andsort vendors alphabetically.
You also should keep separate records for campaign spending and for non-campaign spending.
You must report these two types of spending separately to the Board. CFRO tracks campaign
expenditures and noncampaign disbursements separately based on how you classify eachtransaction and includes those expenses on different report schedules.
The date that a campaign expenditure or noncampaign disbursement is reportable is the datewhen the committee made the commitment to spend the money, not when the bill was actually
paid. An expenditure that has not been paid at the reporting date must be listed as an unpaid
bill. For example, if the committee runs advertisements on Facebook, Meta will not charge thecommittee for the ads until they all have finished running or the cost has reached a maximum
amount set by the committee. The committee should record the Facebook advertisements as
an unpaid bill using the date that the committee entered into the advertising agreement with
Meta. The committee can estimate the cost of the ads and then enter the actual amount when it
pays the bill.
The date that an in-kind expenditure was made is the date that the committee accepted the inkind contribution of goods or the date that in-kind services were actually provided. The vendor
for the in-kind expenditure is the donor of the corresponding in-kind contribution.
28

Approved expenditures made on the candidate’s behalf are both in-kind contributions and inkind expenditures. For example, if an entity provided phone banks for the candidate, thecommittee would report this contribution as an in-kind contribution and an in-kind expenditure on
the date that the services were provided. Also, before an entity goes ahead with an approved
expenditure, the treasurer or the candidate must approve the expense in writing. The written
permission should describe what the donor is going to do for the committee, when it will happen,and how much the donor can spend. This writing should be kept with the committee’s otherrecords.

Remember that approved expenditures must be approved in advance and inwriting by the treasurer or the candidate and that the writing must state theamount that can be spent and the reason for the spending.

What penalties apply to improper spending?
The Board may impose a penalty of up to $1,000 for the following things:•••

Spending money when the committee does not have a treasurer;
Not keeping records of spending; andMixing committee funds with other money.

The Board also may impose a penalty of up to $3,000 if a person knowingly fails to keep
records of expenditures. The Board may impose an additional $3,000 civil penalty on thecandidate or committee that is affiliated with the person who knowingly failed to keep the
expenditure records.
The Board may impose a penalty of up to $3,000 if someone converts committee funds topersonal use and may bring a legal action to recover the converted funds. The Board also may
impose a penalty of up to $3,000 for violations of the disclaimer requirement.

29

Reporting to the Board
Overview
This chapter tells you how to use your records to file reports with the Board. It also tells you
when those reports are due. You can use CFRO to keep your records and file your reports. If
you use CFRO, it automatically fills out all of the report schedules for you.
Topics covered
When do you need to file reports with the Board?
What are the special reporting requirements just before an election (large contribution
notices)?
How do you report to the Board?
How do you get an exemption from the electronic filing requirement?
How do you report if you still file a paper form?
How do you find registration numbers for contributors registered with the Board?
How do you decide if money received by your committee should be reported as acontribution or as income?
How do you decide if a payment made by your committee should be reported as an
expenditure or a contribution?
What do you report to the Board?
How do you fix mistakes on a report?
What penalties apply to reporting?
When do you need to file reports with the Board?
The reports that you file with the Board are like bank statements. They show the amount ofmoney that the committee started with at the beginning of the year, the receipts and spendingthat have come in and gone out of the committee during the year, and the amount of money thatthe committee has left at the end of the year.
For a non-election year, you must file one report for the entire year. This report is due on
January 31 of the following year. The 2023 year-end report is due on January 31, 2024.
For an election year, a candidate for district court judicial office must file three reports with theBoard. In 2024: those reports are due according to the following schedule:
Pre-primary-election report:
Pre-general-election report:
Year-end report:

July 29, 2024 (15 days before the primary)
October 28, 2024 (first business day after 10 days before
the general election)
January 31, 2025

30

The committee of a candidate for district court judicial office who did not file for office does nothave to file the pre-primary report. A candidate for a district court judicial office whose name will
not appear on the general election ballot does not have to file the pre-general report.
For an election year, a candidate for an appellate court judicial office must file six reports with
the Board. In 2024, these reports are due according to the following schedule:
April report:
June report:
Pre-primary-election report:
September report:
Pre-general-election report:
Year-end report:

April 15, 2024
June 14, 2024
July 29, 2024 (15 days before the primary)
September 24, 2024
October 28, 2024
January 31, 2025

The committee of a candidate for appellate court judicial office who did not file for office does
not have to file the June report or the pre-primary report. A candidate for an appellate court
judicial office whose name will not appear on the general election ballot does not have to file theSeptember report or the pre-general report.

A calendar with all the reporting dates is available on the Board’s website.
Remember that late fees begin without notice on the day after a report is due.

Each report filed with the Board covers the time period from the beginning of the year to the cutoff date for the report. The cut-off date for the pre-primary and pre-general reports is sevendays before the report is due, and the cut-off date for the year-end report is December 31. The
beginning balance on every report should be the ending balance from the previous year’s
report. Because each report covers the entire year up to the date of the report, you will repeat
some of the committee’s earlier receipt and spending entries on its later reports.
You must file reports every year until the committee closes and files a termination report, even if
the committee does not collect or spend any money during the year.
What are the reporting requirements just before an election (large contribution notices)?
During election years, there is a gap between the last date for transactions included on the preprimary report and the date of the primary election. There is another gap between the last date
for transactions included on the pre-general report and the general election. During these twotime periods, you must report to the Board any large contributions or loans that you receive.
The size of the contribution or loan that triggers the notice requirement is different for each
office.

31

Office
District Court
Appellate Court

Large contribution notice triggers
Amount that triggers notice requirement
More than $400
More than $2,000

The notice is due by the end of the next business day after you receive the large contribution or
loan. The triggering amount is the total of all contributions and loans received from the same
source during the large contribution notice period. You don't count contributions and loans
received before the beginning of the period because they will be included in your pre-election
report.
There are two exceptions to the large contribution notice requirement. A candidate who is
unopposed in the primary election or whose name will not appear on the primary election ballot
does not need to file a notice for a large contribution received during the pre-primary notice
period. A candidate whose name will not be on the general election ballot does not need to filea notice for a large contribution received during the pre-general notice period.
If you enter an applicable contribution immediately upon receipt, CFRO will notify you if you
have a large contribution notice due and will guide you through the filing of the notice. The
Board also has an online reporting system separate from CFRO for these large contributions.
You can use this system to report large contributions even if you do not use CFRO. The Board
gives all registered committees a username and password and a link to access the system.
For 2024, the large contribution notice requirement is in effect during the following periods:
Election
Primary
GeneralFirst day in effectJuly 23
October 22

Last day in effectAugust 12
November 5

The large contribution notice period is based on the date that the committee receives thecontribution. If a contribution is given to the candidate or to a committee member, it is received
on that date. That means that it is important for everyone who receives contributions on behalfof the committee to notify the treasurer of every contribution during the large contribution notice
period. If they do not, a reporting violation may occur because the treasurer did not know about
the contribution.
A large contribution notice is a report filed with the Board, just like your regular reports. For thatreason, it is subject to the same penalty for late filing, which is $50 per day. If a treasurer does
not manage the large contribution notice requirement carefully, late fees of $1,000 per unfiled
large contribution notice can easily result.

32

How do you report to the Board?
You must file your reports electronically. The Board may make an exception for your committee
if you do not intend to raise or spend more than $5,000 within a calendar year, or otherwise
show that you have a good reason for not filing electronically.
If you are using CFRO, you can use it to generate the required reports and send themelectronically to the Board. CFRO incorporates the campaign finance requirements. As you
enter your records, it will alert you to possible mistakes. If you enter records regularly, you
should have time to fix your mistakes before a violation occurs. The Board holds periodic
training classes on the use of CFRO. The Board’s website has a current list of training
opportunities and online tutorials. The training offered by the Board and online tutorials on the
Board's website explain the step-by-step process for creating and filing a report using CFRO.
You can use other campaign finance software to keep your records and report to the Board aslong as the software meets the Board’s requirements.
How do you get an exemption from the electronic filing requirement?
If you think you have a good reason for not filing electronically, you may request a waiver fromthe requirement. You may ask for a waiver by filling out the waiver request that is available on
the Board's website. The Board will tell you if the waiver is granted. If it is, you may continue tofile paper reports.
How do you report if you still file a paper form?
If the committee has a waiver to report using a paper form, you may send your report to theBoard by fax, by U.S. mail, or as an attachment to an email. If you fax the report, you should
keep a copy of the transmittal confirmation to show that you sent the report on time. Even homefaxes usually have a way to print a transmission report. If the Board does not receive the fax by
the filing deadline and the committee does not have a transmittal confirmation, the committee’sreport will be considered to be late.
Paper reports must comply with all the legal requirements for committee reports. You should
read the instructions for completing each schedule before you start to fill them in. You should
complete the schedules before you fill out the summary page. On the schedules, contributions
and expenditures must be grouped by source or vendor. Donors and vendors must be reported
alphabetically when itemization is required. The report must include all transactions fromJanuary 1 through the cutoff date of the reporting period.
Paper reports also must be clearly legible even in a scanned image. If the report is not legible,
the treasurer will be required to re-do the report and to resubmit it. The Board has also
developed an information sheet that tells treasurers about the most common problems withpaper filings. This information sheet is available on the Board’s website.
33

How do you find registration numbers for contributors registered with the Board?
If a lobbyist, party unit, political committee, or political fund that is registered with the Board
gives your committee money and the contribution is greater than the itemization threshold, youmust report the contributor’s Board registration number with the contribution. The lobbyist, party
unit, political committee, or political fund is required to include its registration number with its
contribution. Use the registration number provided by the contributor for your records.
If no registration number was provided with the contribution, it can be difficult to determine
which lobbyist, party unit, committee, or fund was the actual source of contribution. For
example, multiple local affiliates of the same labor union may have political funds with similarnames. Political committees and funds also may use different names on their checks than thenames that are on the Board’s registration list.

If you use CFRO, enter the contribution using the registration number provided
and the system will fill in the contributor’s name.

Finding the correct registration number is important because if you don’t use the correct number
on your report, Board staff may not be able to match contributions on the reports filed by thedonor and the recipient. This may result in your being required to amend your report to correct
the error.
If there is no registration number with a contribution from a group, check the lists of registeredentities on the Board’s website or contact Board staff for help. You also can contact the entitythat made the contribution to ask for its registration number.
If your committee makes a contribution to another group registered with the Board, you must
give that entity your committee’s registration number. On your report, you must include thecorrect registration number for the party unit or the committee or fund to which your committee
gave money.
How do you decide if money received by your committee should be reported as acontribution or as income?
Money received by your committee is reported either as a contribution to the committee or as
miscellaneous income. Almost all of the money received by a principal campaign committee
should be reported as contributions but there are a few exceptions to this general rule. Here aresome common receipts and how they should be reported.
Transaction
Money received for tickets to a fundraiser
Money received for a table sponsorship at a fundraiser
34

How to report transaction
Contribution
Contribution

Transaction
Money given to reimburse your committee for anothercandidate’s share of the cost of a good or service, such as a
mailing or a fundraiser
Money received as a refund because the committee paid fora good or service that it never received
Interest paid on the committee’s bank accountProceeds from selling something at a silent or live auction
Item given to your committee to sell at an auction
Refund of a security deposit

How to report transaction
Miscellaneous income
Miscellaneous income
Miscellaneous income
Contribution
Contribution
Miscellaneous income

How to decide if a payment made by your committee should be reported as acontribution to another registered entity.
Money paid out by your committee is reported either as a campaign expenditure, noncampaign
disbursement, or contribution made. Money paid to other entities registered with the Board is
the only type of payment that is reported as a contribution made. All other payments , including
charitable contributions, are reported as expenditures or noncampaign disbursements. If you
use CFRO, whether a payment is classified as a contribution made is dependent on the
expense type selected when the transaction is entered. Here are some common payments andhow they should be reported.
Transaction
Money paid to a committee or fund registered with theBoard for tickets to a convention or dinner
Payment to a committee registered with the Board for atable sponsorship at an event
Payment to a group not registered with the Board forsponsorship of an event
Money given to a 501(3)(c) charity
Money used to pay for the candidate’s attendance at a civicorganization dinner
Money you returned to a contributor more than 90 days
after deposit of the contribution

How to report transaction
Contribution
Contribution
Expenditure
Expenditure
Expenditure
Noncampaign disbursement

What do you report to the Board?
You report the committee’s receipts and spending to the Board. Each report has a summary
section where you show•••

the total amount given to the committee by each type of donor;
the total amount spent by the committee on campaign expenditures, noncampaign
disbursements, and contributions made; andthe total amount loaned to the committee outright or in the form of unpaid bills.

The report also has a section where you list more details about contributions that the committee
received from each type of donor. For example, contributions from lobbyists are listed on
35Schedule A1 - LOB – Contributions from Lobbyists. There are other schedules for contributions
from individuals, party units, and political committees and funds. Schedules B1 – CE and B1 NCD are used to list the committee’s campaign expenditures and noncampaign disbursements.
There are additional schedules used to report contributions made and to report the details ofloans and unpaid bills.
The amount of detail that you report on each schedule depends on the amount of thecontribution or the spending.
If you use CFRO you don't need to worry about the schedules or the summary. CFRO fills themout automatically based on the receipts and expenses you entered. Before you file your reportwith the Board, you can look at it on your computer or print it out so that you can see exactly
what your filed report will contain.
Paper filers will need to review the instructions included with the paper forms and theinformation sheet about common paper filing problems before filing reports. This review will
help paper filers to correctly fill out each schedule and the summary and make sure that thereport meets the requirements for a paper filing.
The Common Questions section of the handbook describes how to report transactions that arise
during a typical fundraiser.
Contributions
In this section, when we talk about the contribution amount, we mean the total of allcontributions received from the same donor. For example, if a donor buys a fundraiser ticket for$75 and later makes a cash contribution of $150 within the same year, the total contribution
amount is $225 and the contributions will be itemized. Do not subtract processing fees or thevalue of anything received by the donor at the fundraiser to determine the amount of thecontribution. Any processing fees and fundraiser expenses will be reported as noncampaign
disbursements or expenditures. Apply the rules below to the total amount contributed by adonor, not to each individual contribution from the same donor.
You do not have to report anything for in-kind contributions from one donor that are $20 or less.
You also should exclude in-kind contributions of $20 or less when calculating the total amountgiven by a donor.
Contributions from donors who each gave $200 or less – Cash and in-kind total:•••

Add the in-kind contributions together.
Add the cash contributions together.
Report the total amount of the in-kind contributions in the in-kind column on thenonitemized line on the bottom of the schedule.

36

•
•
•

Report the total amount of the cash contributions in the cash column on thenonitemized line on the bottom of the schedule.
Do not list the donors separately.
Do not list these small contributions as miscellaneous income.

Contributions from one donor of more than $200 – Cash and in-kind total:
•
•
•
•
•
•

Report each contribution individually.
Report the date received and the donor’s name, address, and employer, or occupation if
self-employed.
Report in-kind contributions in the in-kind column and cash contributions in the cash
column.
List the donors in alphabetical order.
If a donor made more than one contribution, list each contribution separately under thedonor's first entry on your report
Include the registration number of any donor registered with the Board.

Don’t report receipts from fundraisers as “miscellaneous income.” They arecontributions from the people who came to the fundraiser.

Expenses
For this section, the expense amount is the total of all payments made or owed to the same
vendor. For example, if you bought office supplies for $60 and later bought more supplies fromthe same vendor for $150 within the same year, the total expense amount for that vendor is$210 and the expenditures will be itemized. Unpaid bills count toward the itemization threshold.
Apply the rules below to the vendor totals, not to each individual payment made to the same
vendor.
Vendors or suppliers to whom you have made expenditures or noncampaign disbursements of$200 or less:•••

Add the campaign expenditures together and report the total amount on thenonitemized line on the campaign expenditure schedule.
Add the noncampaign disbursements together and report the total amount on thenonitemized line on the noncampaign disbursement schedule.
Do not list the payments individually.

Vendors or suppliers to whom you have made expenditures or noncampaign disbursements ofmore than $200:

37

•
•
•
•

•
•

List the vendor name, address, and Board registration number if the vendor is registeredwith the Board with the first expense to that vendor reported on the schedule.
Report each additional payment individually on the schedule below the vendor’s entry.
Report the date and either the amount of the payment or the amount that is unpaid.
Describe the item or service bought and how the item or service was used. The
description must be specific enough so that people looking at the report can tell what
was bought with the payment.
List the vendors in alphabetical order on the report.
If the payment was made to reimburse someone or to pay a credit card bill, you must
report using either of the following two methods. (1) You can report the expense as if itwere paid directly to the vendor who sold the goods or services; listing the vendor as the
payee instead of the person you reimbursed. Under this option, you will keep your own
records showing that this payment was actually a reimbursement and to whom it waspaid. (2) Under the second method, you can report the name and address of the person
you are reimbursing as the payee and describe the item originally purchased. Under thisoption, if you are reimbursing someone for an item that cost more than $200, you mustalso include the name and address of the vendor from whom the person being
reimbursed bought the item. If you are reimbursing an individual for more than one
expense, list the underlying vendors in alphabetical order under the name of the person
being reimbursed.

If you have questions about how to report a contribution or a payment, you can contact theBoard for help.

The other disbursements schedule is used only for the payment of security
deposits and payments to charities. If you have something else recorded on
this schedule, you might have made a data entry error or recorded something
incorrectly. Call the Board for help.

How do you fix mistakes on a report?
After you have filed a report with the Board, you might discover that the report is incorrect or
missing some information. After you discover the error, you have 10 days to file an amended
report with the Board. If you feel that you will need more than 10 days to research a problem orgather bank records, contact the Board. The Board will provide limited extensions to theamendment period for good cause.
What penalties apply to reporting?
The Board will impose a fee for late reports. The late fee is $25 per day for year-end reports, up
to a maximum of $1,000. The late fee is generally $50 per day for all other reports, up to a
maximum of $1,000 per report, but if total receipts during the reporting period exceed $25,000,
38

the Board may impose a late fee equal to up to two percent of the amount required to bereported, per day, up to a maximum of the amount required to be reported. Late fees begin the
day after the report is due, without notice. Please be sure to keep the reporting deadlines on
your calendar. The late fee also applies to large contribution notices that must be filed during
each pre-election notice period.
The Board may impose a penalty of up to $1,000 for the following things:••••

Not sending in a report after the Board has told the committee that it is overdue;
Not sending in an amended report after the Board has told you to do so;
Not sending in information requested by the Board to reconcile discrepancies between
reported by the donor and the recipient; andFailing to keep records of contributions and spending

The Board may impose a penalty of up to $3,000 for the following things:
•
•
•
•
•

Signing and certifying a report to be true when the person knows that it contains false
information or omits required information;
Knowingly providing false or incomplete information to a treasurer with the intent that thetreasurer rely on that information to certify the report;
Knowingly failing to keep records of contributions and expenditures;
Willfully failing to file an amended report; andWillfully failing to cooperate with the Board to reconcile a report discrepancy.

The Board also may impose an additional $3,000 civil penalty on the candidate orcommittee affiliated with a person who:•••

Falsely certified a report;
Provided false information to the treasurer; orKnowingly failed to keep records of contributions and spending.

39

After the election
Overview
This chapter tells you what happens to the committee and its money after the election. It also
tells you how to terminate the committee.
Topics covered
How do you terminate the committee?
What penalties apply to committees after the election?
How do you terminate the committee?
A committee cannot stop operating until 1) it has $100 or less in cash and property; and 2) it has
submitted a termination report to the Board. A committee can terminate its registration with theBoard even if it has unpaid debts. The committee’s termination, however, does not affect theliability of the committee, the candidate, or the committee’s officers for the unpaid debts.
The committee cannot give its assets away to anyone for personal use. The committee can sell
its assets to anyone at fair market value, including the candidate. If the candidate is running foranother state-level office, the committee’s debts can be transferred to the candidate’s newcommittee. Assets can be transferred to the new state-level committee subject to the limits ontransfers from party units and terminating candidate committees.
To reduce its assets, the committee also can make contributions to political parties, politicalcommittees, and political funds. A committee that is terminating within the next 12 months canmake contributions to other state-level candidates but can never give money to federal or local
candidates. A committee that is terminating within 12 months also can make unlimited
contributions to charities organized under section 501(c)(3) of the Internal Revenue Code.
When the committee donates money to other state candidates, you must tell the recipient inwriting that the committee is terminating.

If you contribute to a candidate committee, make sure you use that committee’s
correct registration number on your report.

When the committee has $100 or less, you can terminate its registration by sending atermination report to the Board. The termination report is just like a regular report except that itcovers from January 1 of the termination year through the date the committee stopped
operating. Terminating the committee’s registration with the Board means that no further
reports will be required.

40

The treasurer or candidate must keep the committee’s records for four years after it terminates.
It is not unusual for candidate committees to be inactive for an election cycle while a candidate
decides whether to run again. But there is a limit on how long the committee may stayregistered without activity. A committee must stop operating and terminate its registration when
1) it has been six years since the last election that the candidate ran in; or 2) it has been six
years since the day that the candidate left office.
The Board will notify a committee if it must terminate. The committee then has 60 days todispose of its assets and send in the termination report. If the candidate is planning to run again
for the same office, you can ask the Board for permission to keep the committee active beyond
the six-year limit.
What penalties apply to committees after the election?
The Board may impose a penalty of up to $1,000 for not keeping records for four years
If the committee does not terminate within 12 months after giving money to another statecandidate’s committee, the Board may impose a penalty of up to four times the amount of eachcontribution made to another candidate's committee. If the committee does not terminate within
12 months after giving money in excess of $100 to a 501(c)(3) charity, the Board may impose apenalty of up to $3,000.

41

Common questions
Overview
This chapter describes some important things that are not covered in detail in the previous
sections. It also tells you how to report some common transactions that occur during
fundraisers.
Topics covered
Getting on the ballot
Economic interest statements
Getting a federal tax ID number for political purposes
How do you find registration numbers for contributors registered with the Board?
How do you decide if money received by your committee should be reported as acontribution or as income?
How do you decide if a payment made by your committee should be reported as an
expenditure or as a contribution to another registered entity?
Online contributions
Fundraiser reporting examples
Joint fundraising events
Conducting raffles or drawings
Conducting auctions
Having policies to help control your money
Criminal penalties
Getting on the ballot
Nothing that you do with the Board actually gets the candidate’s name on the ballot. That is
because the Office of the Secretary of State and county election officials handle the election
process. The Board only handles financial and disclosure matters. Candidates typically get on
the ballot by filing an affidavit of candidacy to run for office during a specified filing period. The
requirements are technical and you have to follow them correctly. The candidate should review
materials produced by the Secretary of State and contact that office or their county if there arequestions. The Secretary’s website has more information about what a candidate must do to
get the candidate’s name on the ballot.
When the candidate files with the Secretary of State or a county filing officer to get on the ballot,
the filing officer will give the candidate a packet of materials from the Board. It is very importantthat the candidate reads everything in this packet.

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Economic interest statements
An economic interest statement (EIS) shows a judge’s name, address, principal place ofbusiness, and associated business names; where the judge or the judge’s spouse owns
property in Minnesota, either directly or through membership in a partnership, excluding directlyheld homestead property; business categories applicable to compensation earned by the judge
or the judge’s spouse as an employee or independent contractor; investments in securities
valued at more than $10,000 owned partially or fully by the judge or the judge’s spouse; certain
contracts and professional licenses held by the judge or the judge’s spouse; and whether thejudge or an immediate family member has any financial interests in horseracing. Judges mustfile a completed EIS with the Board within 60 days of assuming their duties. The Board puts
information from the completed EIS on its website to make it easier for people to know when an
elected official could have a conflict of interest.
If the judge does not timely file the EIS, the Board will charge a fee of $5 for each day that the
EIS is late, up to a maximum of $100. If the judge does not file the EIS after the Board has
given notice that it is due, the Board may impose an additional civil penalty of up to $1,000.
How to get a federal tax ID number (EIN) for political purposes.
1. Go to this link and select Begin Application:
https://sa2.www4.irs.gov/modiein/individual/index.jsp
2. When asked for the type of organization, select the bottom option for additional types oforganizations, then select Continue.
3. On the next page, select Political Organization, then select Continue twice.
4. When asked for the reason for the EIN, select Banking purposes, then select Continue.
5. The responsible party is an individual who should probably be the candidate for a candidate
committee so that you don’t have to change it every time the treasurer changes. For a party
unit or political committee or fund, it should be the treasurer and should be changed if thetreasurer changes. Complete the Responsible Party form, then select Continue.
6. Enter the contact information of the organization, then select Continue.
7. For the legal name, use “Campaign fund of (name of candidate, or entity if not a candidate)”.
Then the name attached to the EIN will match the name on the bank account. Aside fromthe text “Campaign fund of” the name provided to the IRS should match the name used
when registering with the Board.
8. a. Candidate committees and party units: Check the button that says you will NOT be filing
Form 8871. This form is not filed by state candidate committees or state party units.
b. Political committees and funds: If you expect that the annual gross receipts of yourcommittee or fund will NEVER exceed $25,000, check the button that says you will NOT be
43

filing Form 8871. If you expect that your annual gross receipts will exceed $25,000, checkthe button that says you will be filing Form 8871.
9. When asked if you will have W-2 employees, select No unless you will have paid
employees. If you will have W-2 employees, seek legal assistance.
10. When asked how you wish to receive your number, select Receive letter online. Otherwise
you may wait weeks to get the number.
11. Review your application information. If it is all correct, click the Submit button.
How do you find registration numbers for contributors registered with the Board?
If a lobbyist, party unit, political committee, or political fund that is registered with the Board
gives your committee money you must include the contributor’s Board registration number whenentering the contribution. The lobbyist, party unit, political committee, or political fund isrequired to include its registration number with its contribution. Use the registration number
provided by the contributor for your records.
If no registration number was provided with the contribution, it can be difficult to determine
which lobbyist, party unit, committee, or fund was the actual source of contribution. For
example, multiple local affiliates of the same labor union may have political funds with similarnames. Political committees and funds also may use different names on their checks than thenames that are on the Board’s registration list.
Finding the correct registration number is important because if you don’t use the correct number
on your report, the Board may not be able to match contributions on the reports filed by thedonor and recipient. This may result in being required to amend your report to correct the error.
If there is no registration number with a contribution from a group, check the lists of registeredentities on the Board’s website or contact Board staff for help. You also can contact the entitythat made the contribution to ask for its registration number.
If your committee makes a contribution to another group registered with the Board, you must
give that entity your committee’s registration number. On your report, you also must include thecorrect registration number for the party unit or the committee or fund to which your committee
gave money.
How do you decide if money received by your committee should be reported as acontribution or as income?
Money received by your committee is reported either as a contribution to the committee or as
miscellaneous income. Almost all of the money received by a principal campaign committee
should be reported as contributions but there are a few exceptions to this general rule. Here aresome common receipts and how they should be reported.

44

Transaction
Money received for tickets to a fundraiser
Money received for a table sponsorship at a fundraiser
Money given to reimburse your committee for anothercandidate’s share of the cost of a good or service, such as a
mailing or a fundraiser
Money received as a refund because the committee paid fora good or service that it never received
Interest paid on the committee’s bank accountProceeds from selling something at a silent or live auction
Refund of a security deposit
Item given to your committee to sell at an auction

How to report transaction
Contribution
Contribution
Miscellaneous income
Miscellaneous income
Miscellaneous income
Contribution
Miscellaneous income
Contribution

How to decide if a payment made by your committee should be reported as an
expenditure or as a contribution to another registered entity.
Money paid out by your committee is reported either as a campaign expenditure. noncampaign
disbursement, or contribution made. Money paid to other entities registered with the Board is
the only type of payment that is ever reported as a contribution. All other payments, including
charitable contributions, are reported as campaign expenditures or noncampaign
disbursements. If you use CFRO, whether a payment is classified as a contribution made isdependent on the expense type selected when the transaction is entered.. Here are somecommon payments and how they should be reported.
Transaction
Money paid to a committee registered with the Board fortickets to a convention or dinner
Payment to a committee or fund registered with the Board
for a table sponsorship at an event
Payment to a group not registered with the Board forsponsorship of an event
Money given to a 501(3)(c) charity
Money used to pay for the candidate’s attendance at a
civic organization dinner
Money you returned to a contributor more than 90 days
after deposit of the contribution

How to report transaction
Contribution
Contribution
Expenditure
Expenditure
Expenditure
Noncampaign disbursement

Online contributions
When the committee receives a contribution through an online contribution processor, thecommittee must record the entire amount given by the donor as the amount of the contribution.
The committee should not subtract any processing fees to determine the contribution amount.
The committee will report the processing fees as a noncampaign disbursement to thecontribution processor. The committee does not have to report each processing fee as aseparate transaction but instead can report the fees paid to each processor on a monthly basis.

45

Sometimes a contributor will increase the size of a contribution to cover the processing fees forthe contributed amount. In this case, the committee should look at the total amount transferredto the committee by the processor to determine the amount of the contribution.
Fundraiser reporting examples
All money received from a fundraiser attendee is a contribution, regardless of whether theattendee received food and beverages, entertainment, or benefits such as a golf outing. The
only way that you can exclude fees from the attendee's contribution is if the fees were paid
directly to the provider of the services, such when the attendee paid the greens fees directly to
the golf course.
The examples below explain recordkeeping and reporting for a typical fundraising event and fora golf tournament.
The committee holds a reception and dinner as a fundraiser. Tickets to the reception alone are$20 and tickets to the dinner are $125. Anyone who pays $250 or more can attend a private
reception with the candidate. Food and beverages are provided to the people who attend.
The committee must keep records of all the money collected at the fundraiser as contributions.
The committee also must keep records of any goods or services donated for the fundraiser.
The details recorded will depend on the amount of the contribution.
For contributions of $20 or less, the committee must record only the total amount received. The
committee does not need to record any donor information for these small contributions.
For contributions of more than $20 to $200, the committee must record the name and addressof the donor along with any Board registration number.
For contributions of more than $200, the committee must record the donor’s name, address,
Board registration number, if any, and employer or occupation.
All the costs related to the fundraiser count as spending by the committee holding the event.
The payments for the food, beverages, utensils and supplies, facility rental, and entertainment,or the value of those items if they were donated, are recorded as noncampaign disbursements.
Any other expenses, such as invitations and postage, are recorded as campaign expenditures.
For all cash and in-kind expenditures, you must record the following information:••••

the date and amount of the payment or in-kind expenditure;
the name and address of the vendor;
a description of the item or service purchased; andthe Board registration number of any entity to which you make a payment.

46

If the committee holds a golf tournament fundraiser and charges $200 per person, thecommittee would report the entire $200 as a contribution. The committee would not deduct thecost of greens fees or cart rentals from the $200. Instead, the committee would report these
expenses as noncampaign disbursements. If attendees pay their greens fees directly to the golfcourse and none of those fees go to the committee, those fees do not count as contributions tothe committee. The golf course cannot offer reduced greens fees that are not available to othergroups. If the golf course did offer reduced fees, it would likely be a contribution to thecandidate's committee from a corporation, which is against the law.
Joint fundraising events
If the committee holds a fundraiser with another candidate’s committee, you must be careful notto break the rule against accepting a contribution earmarked for another candidate and the ruleagainst making transfers to another state-level candidate’s committee. You should make it clear
which candidate is getting the contribution by doing things such as setting up separate
contribution tables for each candidate or giving donors a receipt with the candidate’s name. The
costs of the fundraiser have to be split between the candidates according to each candidate’s
share of the fundraiser’s proceeds. For example, if one candidate received 40% of the total
contributions, that candidate’s committee must pay 40% of the event's campaign expendituresand 40% of the event's noncampaign disbursements. The division must be done separately for
campaign expenditures and noncampaign disbursements. If one candidate pays more thantheir share of the expenses, reimbursements may be made after the event as long as clear andcomplete records are kept to explain the finances of the event.
Conducting raffles or drawings
Raffles could be considered charitable gambling and might not be legal for a political fundraiser.
You should read “Frequently Asked Questions about Raffles, Lawful Gambling, and Political
Campaign Financing." This is a flyer put out by the Gambling Control Board, which regulatescharitable gambling. It is available on the Board’s website. You also can call the Gambling
Control Board at (651) 539-1900 if you are considering having a raffle or a drawing as part of afundraiser.
Conducting auctions
When the committee collects goods for an auction, remember the following things:•••

Don’t accept any contributions from corporations, either directly or indirectly;
Don’t accept contributions worth more than $200 from groups that are not registered with
the Board unless the group gives you a financial disclosure form; andBe aware of how a contribution could affect the committee’s contribution limits.

When the committee holds an auction, the items donated for the auction are in-kind
contributions to the committee from the people who give the items. You must record every in47

kind contribution that is more than $20. The items must be valued at fair market value. You
must add the value of all items given by a person to determine the amount of that person’scontribution. You cannot treat each item separately.
If the total value of the item or items donated is less than $20, you do not have to keep a recordof the item(s). You may wish to keep a record for internal committee reasons.
If the value of the donated item is more than $20, you must record the donor’s name andaddress and Board registration number. If the donated item is worth more than $200, you also
must record the donor’s employer, or occupation if self-employed.
A best practice tip is to create a contribution receipt form that has space for all the required
information. On the form, you can tell people to give employment information only if thecontribution is more than $200.
Each item donated to the committee for the auction that is worth more than $20 also must berecorded as an in-kind expenditure. The vendor for the expenditure is the person who donatedthe item. The value is the fair market value of the item, which should be the same as the valueof the corresponding in-kind contribution. You also must describe the item in the committee’srecords. The date of the expenditure is the same date as the date of its receipt.
A best practice tip is to record both the in-kind receipt and the in-kind expenditure at the time theitem is accepted. When an in-kind contribution is entered in CFRO, you will be prompted toenter the corresponding in-kind expenditure at the same time.
Fair market value is the price that someone would pay for the item in the open market. It does
not include a premium that a person might pay for the item to help the seller.
The sale of the auction items is separate from the collection of those items. Everyone who buys
something at the auction has made a cash contribution to the committee holding the auction.
Record these purchases as cash contributions. Do not reduce the amount of the contribution by
the value of the item bought. You do not need to report the item bought to the Board but you
may want to keep these records for internal purposes.
Having policies to help control your money
It can be hard to keep track of contributions collected during fundraisers and for auctions. It isvery important for the treasurer to keep control over these events. If more than one person will
be collecting contributions at a fundraiser, for an auction, or just in the ordinary course of thecommittee's work, the treasurer should make sure that these people get the required
information from the donors. A best practice tip is to create a receipt for every contribution. The
receipt should include the donor’s name, address, employment information, and Board
registration number (if applicable) along with the date and amount of the contribution. The
person collecting the contribution for the committee should keep a copy of the receipt. The
48

treasurer should collect the copies of these receipts as soon as possible. All money andcontributions also should be given to the treasurer right away. The treasurer also should keep
any records related to fundraisers such as the bid sheet for an auction.
A committee should have policies that ensure that the treasurer is the person in control of themoney and that the money in the bank always balances out with the money shown on reports
filed with the Board.
Closed captioning resources
The Minnesota Commission of the Deaf, DeafBlind, and Hard of Hearing makes a free, online
training class about closed captioning available through its website.
Criminal penalties
Some violations of the campaign finance laws can be criminally prosecuted. For these
violations, the Board could refer the matter to a county attorney. The county attorney would
decide whether the matter should be charged as a crime. The Board itself does not charge orprosecute criminal matters.
Some of the violations that carry possible criminal penalties are listed in this handbook. In
addition, the following violations of campaign finance laws may be charged as crimes:
•
•
•
•
•
•

Filing a registration form knowing that it contains false information or omits required
information;
Knowingly providing false or incomplete information to a treasurer with the intent that thetreasurer will use that information in certifying a report;
Trying to get around the contribution limits by making contributions through anotherperson or on behalf of another person;
Participating in the preparation or distribution of campaign materials that do not include
the required disclaimer;
Helping someone to violate the laws prohibiting corporate contributions; andKnowingly failing to keep records.

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Getting help
Overview
This chapter tells you how to get help from the Board.
Topics covered
What is the role of Advisory Opinions?
Complaints
How do you contact the Board?
What is the role of Advisory Opinions?
The Board on occasion issues advisory opinions that provide the Board’s interpretation of astatutory provision. Over the years, the Board has issued over 450 advisory opinions, many ofwhich may be viewed and searched on the Board’s website. If you have a question about anadvisory opinion, or wish to discuss the process for requesting an opinion from the Board,contact Board staff.
Complaints
The Board enforces campaign finance laws by reviewing reports that people file with it. Of
course, not all problems with campaign finances show up on filed reports. If you have reason tobelieve that a committee is not reporting accurately to the Board, or in some other way has
broken the campaign finance laws, you can file a complaint with the Board. If the complaint isabout an activity under the Board’s jurisdiction, and evidence is provided to show that thecomplaint has a reasonable basis, the Board will likely investigate. Information concerning acomplaint may not be made public by Board staff until the Board publishes a final decision.
How do you contact the Board?
At the beginning of this handbook, we told you that we wouldn’t try to answer every possible
question you might have. We encourage you to call or email the Board for help. We want yourexperience running a candidate’s committee to be successful, and Board staff will try their best
to provide you with the information you need for that to happen.
The Board has two email distribution lists that will keep you informed of campaign financeissues and updates to CFR. You may subscribe to these lists here on the Board’s website.

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Staff Members
Jeff Sigurdson
Executive Director(651) 539-1189
jeff.sigurdson@state.mn.us

Megan Engelhardt
Assistant Executive Director(651) 539-1182
megan.engelhardt@state.mn.us

Jon Peterson
Information Technology Specialist(651) 539-1186
jon.c.peterson@state.mn.us

Melissa Stevens
Compliance Officer(651) 539-1188
melissa.stevens@state.mn.us

Gary Bauer
Information Technology Specialist
gary.bauer@state.mn.us

Andrew Olson
Management/Legal Analyst(651) 539-1190
andrew.d.olson@state.mn.us

Erika Ross
Programs Administrator(651) 539-1187
erika.t.ross@state.mn.us

Greta Johnson
Management/Legal Analyst(651) 539-1183
greta.johnson@state.mn.us

Who to Call for HelpCampaign finance reporting/registration
Lobbyists reporting/registration
Economic interest statements
Compliance information
Public subsidy
Advisory opinions
Campaign Finance Reporter Online (CFRO)
Forms, general information
All staff may also be reached at(651) 539-1188(651) 539-1187(651) 539-1187(651) 539-1182(651) 539-1189(651) 539-1189(651) 539-1190(651) 539-1180(800) 657-3889

Email the board
Registration and reports
Economic interest statements
General questions or comments

cfb.reports@state.mn.us
cfb.eis@state.mn.us
cf.board@state.mn.us

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You may also contact the Board as follows:
By telephone at (651) 539-1180 or toll free (800) 657-3889.
By TTY by calling (800) 627-3529 and asking for (651) 539-1180.
By fax to (651) 539-1196 or fax toll free (800) 357-4114.
By United States mail to:Campaign Finance & Public Disclosure Board
190 Centennial Office Building
658 Cedar Street
St. Paul, Minnesota 55155-1603

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