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      FEC Record: Advisory opinions
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      AO 2015-07: Payment for food, beverages and valet parking at campaign events

FEC Record: Advisory opinionsAO 2015-07: Payment for food, beverages and valet parking at campaign eventsOctober 9, 2015 Attendees at a campaign event may pay for their own food,  beverages and valet parking without making in-kind contributions to the  committee. **Background** Hillary for America (the “committee”) is the principal  campaign committee for presidential candidate Hillary Clinton. The committee  would like to hold campaign events at restaurants, hotels and other venues  where food and beverages may be offered to attendees, and at museums, private  homes, and other locations where valet parking services may be offered. Any such  services would be offered independent of the campaign--the committee will not request  or pay for any of the services--but the committee expects event attendees may  choose to pay for them on their own. Hillary for America asks if attendees may pay for their own  food, beverages and valet parking services at these events without the payments  resulting in in-kind contributions to the committee. **Analysis** Under the Federal Election Campaign Act and Commission  regulations, a contribution includes any gift, subscription, loan, advance, or  deposit of money or anything of value made by any person for the purpose of  influencing any election for Federal office. 52 U.S.C. § 30101(8)(A)(i); 11 CFR  100.52(a). “Anything of value” includes all in-kind contributions as well as the  entire amount paid to attend a fundraiser or other political event. 52 U.S.C. §  30101(8)(A)(i); 11 CFR 100.52(a), (d); 11 CFR 100.53. In previous advisory opinions, the Commission concluded that  payments for food and beverage expenses for a committee’s event by anyone other  than the committee would result in an in-kind contribution. See AOs 1980-63 (Wirth); 1980-89 (Coelho). Similarly,  if a committee provides food and beverages at an event, and an attendee  reimburses or defrays the committee’s costs for the food and beverages, the  attendee would make an in-kind contribution to the committee. See AO 2007-22 (Hurysz). If costs  for food and beverages are included in the charge to attend an event, any  payment of that charge would result in a contribution. See 11 CFR 100.53. Hillary for America’s request differs from those precedents  because the committee does not plan to provide food or beverages at its planned  events. Therefore, attendees would not be reimbursing or defraying any costs that  the committee would otherwise incur. Also, these costs would not be included in  the charge to attend the event, so an attendee’s payment for his or her own  food and beverage would not result in a contribution to the committee. However,  the Commission pointed out that its conclusion assumes that the attendees’  choice to purchase food and beverages at the event will not affect the  committee’s costs for the event. That is, the committee will not receive any  discounts based on attendees’ purchases, nor will it be obligated to pay a  minimum charge if attendees do not make a purchase. The Commission also approved an attendee’s payment for valet  parking services under the same analysis.  Date issued: 10/1/2015; 5 pages **Resources:** Advisory opinion 2015-07 [PDF]            Commission discussion of advisory opinion 2015-07 [mp3]
 Author
          Zainab  SmithCommunications Specialist


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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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