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Interpretative Opinion 03-08: Solicitation of Funds

April 15, 2003

Thorn Pozen, Esq.
DCDSC Legal Counsel
555 Twelfth Street, NW
Washington, DC 20004-1206

Re: Proposed DC Democratic State Committee Fundraising Plans

Dear Mr. Pozen:

This is in response to your letter dated April 4, 2003, in which you requested that the Office of Campaign Finance inform you whether we foresee ethics or compliance issues related to the two proposed fundraising activities you described.

You indicated that the DC Democratic State Committee intended to establish a subcommittee under the name of the DC Democratic Business Council (DCDBC), which will organize fundraisers for the following purposes:

A.  An Annual National Retreat and Issue Conference;
B.  A Policy Briefing Series; and
C.  A second series of fundraising receptions which would request contributions from the public and feature notable members of the community, including elected officials and members of their staffs.

Based upon your description of the activities your organization intends to engage in, there does not appear to be any indication that the fundraisers will inure any direct benefit or gain to any elected or government official.

Therefore, it is the opinion of this office that the activities that your organization intends to undertake will not be prohibited under our statute or regulations.