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Commission adopts advisory opinion saying candidate loans to leadership committees/PACs are candidate funds and repayable

State Ethics Commission · December 4, 2025
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Summary

The commission adopted AO2025-02 clarifying that a candidate’s personal loan to a leadership committee or PAC remains the candidate’s funds and repayment to the candidate does not, by itself, create excess contributions under the facts posed.

The State Ethics Commission adopted Advisory Opinion AO2025-02 at its Dec. 4 meeting, answering four related questions about whether candidates may loan personal funds to leadership committees or PACs and whether repayments or subsequent transfers raise contribution‑limit issues.

Staff summarized the request from counsel and concluded that…

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