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Interpretative Opinion 06-02: Appointment of "Honorary Co-chairman"

June 01, 2006

Timothy L. Jenkins
15 Logan Circle, NW
Washington, DC 20006

Re: Appointment of “Honorary Co-chairman”

Dear Mr. Jenkins:

This responds to your request for an opinion concerning whether you may demonstrate the breadth of your support from distinguished Washingtonians by seeking the use of their names and endorsements as “Honorary Co-chairmen” in your campaign.

Specifically, you stated that the persons you intend to designate as “Honorary Co-chairmen” would not bear any responsibility for fulfilling the Office of Campaign Finance’s (OCF) reporting requirements or record-keeping duties and would serve with no operating responsibilities in the campaign.

D.C. Official Code § 1-1102.04 (2001 Edition) states in pertinent part that “each political committee shall file with the Director a statement of organization within 10 days after its organization. It further provides that the statement of organization shall include:

(1) The name and address of the political committee;
(2) The names, addresses, and relationships of affiliated or connected organizations;
(3) The area, scope, or jurisdiction of the political committee;
(4) The name, address, and position of the custodian of books and accounts;
(5) The name, address, and position of principal officers, including officers and members of the finance committee.

The regulations state at 3 DCMR § 3000.14 (1998, as amended) that “a chairperson shall be required to file the following:

(a) A statement of acceptance, on a form prescribed by the Director, within forty-eighty (48) hours of assuming the office; and

(b) A statement of withdrawal, on a form prescribed by the director, and a copy of written notification sent to the address of record of the treasurer and candidate, if an authorized committee, within five (5) days of vacating the office.”

The above referenced provisions address the requirements of functioning, responsible officers of a campaign committee. Based upon your representations, the “Honorary Co-chairmen” will not be expected or required to perform any of the duties of an actual chairman, or his or her designee; and, will essentially serve in a ceremonial capacity without responsibilities. Thus, there does not appear to be any instance under which one who accepts such a position would be subject to the jurisdiction of OCF.

Therefore, based upon the information you have provided, it is the opinion of the Office of Campaign Finance that your appointment of “Honorary Co-chairmen” is not within the purview of our statutory authority.

The foregoing is an Interpretative Opinion of the Director of the Office of Campaign Finance. Pursuant to D.C. Official Code §1-1103.05, you are entitled to request an Advisory Opinion from the Board of Elections and Ethics on this transaction or activity.