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Ethics commission adopts advisory opinion: transfers through leadership committees may be contributions if coordination is proven
Summary
The commission adopted AO‑2025‑01, concluding that transfers by an independent committee through a leadership committee could constitute contributions to a candidate only where evidence shows coordination; staff emphasized the analysis is fact‑specific and requires strong proof of coordination.
The State Ethics Commission adopted Advisory Opinion AO‑2025‑01 at its Sept. 17 meeting, answering a hypothetical about whether an independent committee’s payment routed through a leadership committee to pay for candidate advertisements could be treated as a contribution subject to statutory limits.
Staff wrote that the question is intensely fact‑specific: merely moving money from an…
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