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Interpretative Opinion 01-09: Contribution Limits

June 14, 2001
 

David Wilmot
HMO Health Political Action Committee
  & Charitable Fund
1010 Vermont Avenue, NW
Suite 810
Washington, DC  20005

Dear Mr. Wilmot:

This responds to your request for an opinion concerning whether the HMO Health Political Action Committee & Charitable Fund (HMO Health PAC) may donate $1,000 to the “5th Annual Ward 8 Health Festival (Health Festival)” to be held on Saturday, June 16, 2001, at Staton Elementary School, located at 2701 Naylor Road, SE, Washington, DC, from 11:00 a.m. until 4:00 p.m.  You state that the Health Festival will be hosted by Councilmember Sandy Allen; and, that the contribution, which will be listed in the Health Festival brochure, is not related to any political or constituent service funds associated with Councilmember Allen.

You are correct.  The Office of Campaign Finance (OCF) General Counsel, Kathy S. Williams, contacted Ron Dennis, Executive Assistant to Councilmember Allen, and queried as to the sponsorship of the Health Festival.  According to Mr. Dennis, the Health Festival is under the auspices of, among other organizations, Staton Elementary School, Capital Community Health Plan, District of Columbia Lottery Board, Health Right, UPO, and Greater Southeastern Community Hospital.  Moreover, Mr. Dennis confirmed that there are not any political or constituent service funds associated with Councilmember Allen supporting this event.  Accordingly, the Health Festival does not fall within the parameters of an activity regulated by OCF.

Therefore, it is the opinion of OCF that the Health Festival does not trigger the reporting requirements under the jurisdiction of OCF, subject to its financial limitations on political committees and constituent service funds.