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Interpretative Opinion 98-05: Use of Campaign Funds

December 3, 1998
 

Marie Drissel, Treasurer
Williams for Mayor
1634 I Street, NW
Washington, DC  20068

Re: Use of Campaign Funds

Dear Ms. Drissel:

This responds to your request for clarification of the rules governing expenditures that may be appropriately charged to a principal campaign committee. Specifically, you inquire whether it is permissible to use funds from the Williams for Mayor committee to defray expenses incurred due to cancellation and rescheduling of personal travel.  You state that Mr. Williams and his wife canceled a vacation to participate in a Fourth of July campaign event and rescheduled the trip for September 19, 1998.  You further state that Mr. Williams was invited to attend a political event on September 19, 1998, thereby necessitating a second cancellation of the planned vacation.

Because the foregoing factual scenario is one of first impression for this Office, we sought guidance from the Federal Election Commission (FEC) concerning the application of their regulations, which substantially mirror OCF’s, to this specific set of facts.  We enclose for your review a copy of the FEC’s response.

Pursuant to DC Code § 1-1401(7)(A)(1992 Repl. Vol.), an expenditure is defined as “[a] . . . payment, . . .made for the purpose of financing, directly or indirectly, the election campaign of a candidate or any operations of a political committee or election campaign . . . “.  OCF Regulations state “[c]ampaign funds shall be used solely for the purpose of financing, directly or indirectly, the election campaign of a candidate” (45 DCR 3161, 3175)(May 22, 1998).  The activity you describe, i.e., a vacation, was a personal matter, which was not related to the campaign.  At no time did it, or the cancellation fees associated with it, take on the character of an activity that reasonably could be construed as “directly or indirectly related to financing an election campaign or its operations.”  Consequently, it is the opinion of this Office that Williams for Mayor campaign funds may not be used to defray these cancellation fees.