Tracking Down Campaign Donor Information & Job History

ElectaFile Short Summary: Common Missing Data in Donor Info; How Much Do I Have to Dig? Magic Language; Self Addressed, Return Envelopes!

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Treasurers might hear from the State Board that it needs info about a campaign donor. That is, with the volume and speed of campaign fundraising, info gets missed—and you might have multiple contributions from Jane Jones or Biff Streebaker where you know the name of the donor, you know the date of the donation, and you know the amount—but that’s it.

For each contribution over $50, the law requires you to disclose:

1. The contributor’s name.

2. The contributor’s mailing address.

3. The contributor’s job title or profession; and

4. The contributor’s employer’s name or employer’s specific field of business activity (these are data points for principal occupation)

These 4 data points can be a bear —especially under time pressure. Here’s what the law says:

What If You Don’t Know All 4 Data Points?

You have to use “best efforts” to get the information.

And you need to document those best efforts. The “best efforts” concept is set out in detail in 08 NCAC 21 0101, but for purposes of this blog post, you need to document that you asked for the missing information in writing at least once. That can be a message sent to the contributor within 30 days of the contribution or a writing “to the file” that documents you orally asked for this missing info within 30 days of the contribution. If the request for add’l info is in writing, you have to include a pre-addressed return post card or envelope for the response material.

Key Point: Your Best Efforts communications (i.e., follow up)—and all written solicitations for that matter—must include magic language set out in 08 NCAC 21 .0101. Take a gander!

Key Point: If you’re about to turn in a report where you don’t know the contributor’s principal occupation, the Rule says to write “Unable to Obtain” but be sure to maintain the records we talk about here. Document those “best efforts”!!!

What Happens if I Get the Info After I Filed the Report? You file an amended report. This can be a doozy, but it’s got to be done. Do not assume that you can just file something later with the next scheduled report. Not a good plan!

That’s All For Now! Have a great week and see you Thursday morning!

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