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      FEC Record: Advisory opinions
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      AO 2019-04: LLC’s contribution-processing service permissible

FEC Record: Advisory opinionsAO 2019-04: LLC’s contribution-processing service permissibleApril 17, 2019 Prytany LLC may provide contribution-processing services through its platform without making any contributions or incurring any reporting obligations. Background Prytany, a non-partisan, for-profit LLC, has developed an online platform that enables individuals to make contributions to participating candidates’ principal campaign committees and national party committees. To make contributions, contributors must enroll with the platform. Similarly, principal campaign committees and national party committees must also enroll if they wish to receive contributions through the platform. Access to the platform is not restricted based on a committee’s political affiliation. Enrolled committees pay an annual membership fee of $250 and a 3% per-contribution transaction fee. Individual contributors will not pay any fees to enroll with the platform, but will incur a processing fee of 2.9% of the amount contributed plus $0.30 if they make contributions using a credit or debit card. Additionally, enrolled users can use the platform’s social networking functions to engage in group messaging, information sharing, and solicitations for contributions. Analysis In previous advisory opinions (cited within the opinion), the Commission has determined that the provision of contribution-processing services to a political committee by a commercial vendor does not constitute a contribution to the political committee if the commercial vendors meet the following criteria: The vendor renders services in the ordinary course of business and at the usual and normal charge;The vendor forwards contributions through a segregated account to candidates and political committees, and;The vendor employs adequate screening procedures to ensure that they are not forwarding illegal contributions. The Commission concluded that Prytany’s business model satisfies all three criteria. The Commission also concluded that committees enrolled with Prytany’s platform may utilize the social networking features of the platform to communicate with users and send solicitations without such use resulting in a contribution to those committees by Prytany, since the services are provided to all enrolled committees at a commercially reasonable rate, regardless of whether a committee receives contributions through the platform. Additionally, the Commission concluded that, while these activities do not subject Prytany to any reporting requirements, Prytany is subject to requirements for the timely forwarding of contributions and contributor information to political committees. Date issued: April 11, 2019; Length: 8 pages Citations Regulations 11 CFR 100.52Gift, subscription, loan, advance or deposit of money 11 CFR 102.8Receipt of contributions 11 CFR 110.6Earmarked contributions Resources Advisory opinion 2019-04Commission consideration of advisory opinion 2019-04
 Author
          Paul StoetzerSr. Communications Specialist


Read next: AOR 2019-06: Leigh Brown
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This information is not intended to replace the law or to change its meaning, nor does this information create or confer any rights for or on any person or bind the Federal Election Commission or the public. The reader is encouraged also to consult the Federal Election Campaign Act of 1971, as amended (52 U.S.C. 30101 et seq.), Commission regulations (Title 11 of the Code of Federal Regulations), Commission advisory opinions and applicable court decisions.


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