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Interpretative Opinion 00-04: Solicitation of Funds

August 22, 2000

Linda O’Brien, Campaign Manager
1322 C Street, NE
Washington, DC  20002

Re: Fundraiser – Sale of Raffle Tickets

Dear Ms. O’Brien:

This responds to your request for an opinion concerning a proposed fundraiser involving the sale of raffle tickets to support the candidacy of Tommy Wells for School Board of the District of Columbia.  Specifically, you state that you plan to raffle two (2) Redskins tickets for a home opener game, whose face value is $75.00 each, at a cost of $10.00 per ticket.

DC Code § 1-1441.1(a)(5) provides, in pertinent part, “[n]o person shall make any contribution which, and no person shall receive any contribution from any person which, when aggregated with all other contributions received from that person, relating to a campaign for nomination as a candidate or election to public office, . . . exceeds:  in the case of a contribution in support of a candidate for member of the Board of Education . . ., $200.”

DC Code § 1-1441.1( c) states, “[i]n no case shall any person receive or make any contribution in legal tender in an amount of $25 or more.”

DC Code § 1-1416(b)(2) requires the disclosure of “[t]he full name and mailing address . . . of each person who has made 1 or more contributions to or for . . . such candidate (including the purchase of tickets for events such as dinners, luncheons, rallies, and similar fundraising events) . . . in an aggregate amount or value in excess of $50 or more, together with the amount and date of such contributions.”  Further, DC Code § 1-1416(b)(6)(A) requires the reporting of the net amount of proceeds from the sale of tickets to fundraising events organized by a committee.

The fundraising event you propose is certainly a permissible mechanism to raise funds  in support of a candidate.  However, it will be necessary that you carefully monitor
ticket sales to ensure that purchases by a single contributor do not exceed 20 tickets (@ $10.00 each)  to  avoid  the  making  and  receipt of an excessive contribution.  Moreover,
committee records should be reviewed for prior contributions to the candidate by raffle ticket purchasers to avoid excessive contributions to the candidate’s campaign.

Finally, payment of ticket purchases valued in excess of $25 may not be made or accepted in the form of cash (legal tender).