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Interpretative Opinion 99-15: Appropriate Name for Bank Account

November 5, 1999

The Honorable Florence H. Pendleton
U.S. Senator for the District of Columbia
441-4th Street, NW
Suite 10S12
Washington, DC  20001

Dear Senator Pendleton:

This responds to your request, by letter dated October 29, 1999, for an interpretative opinion concerning the appropriate name for a bank account.  Specifically, you inquire whether “ DC Senatorial Committee” is an appropriate name for a bank account if it is specified for just one senator, as a campaign finance fund.

First, DC Code, Section 1-113(5)(g)(1) (1999 Repl. Vol.) authorizes a Representative or Senator to “solicit and receive contributions to support the purposes and operations of the Representative’s or Senator’s public office”.  Further, a Senator or Representative “shall establish a District of Columbia statehood fund in 1 or more financial institutions in the District of Columbia”.  In our view, to avoid confusing the electorate in terms of the entity and the individual to whom a contribution is made, the name designation of an official Statehood Fund should identify the fund, and include the office and officeholder’s name, e.g., District of Columbia Statehood Fund for U.S. Senator Florence H. Pendleton.

Finally, if you inquire concerning any restrictions that may apply to the name(s) given to a candidate’s campaign finance fund, DC Code, Section 1-1413(a), as well as 3 DCMR Sections 3000.6 and 3005.5 guide us.  Section 3000.6 requires that any political committee designated by a candidate to receive contributions and make expenditures on their behalf as an authorized committee include the name of the candidate for elective office in the District of Columbia in its name.  Section 3005.5 prohibits a candidate from commingling contributions with their personal funds or accounts.  Further, DC Code, Section 1-1413(a), referencing DC Code, Sections 1-1414(b)(9) and 1-1415(b), requires that each political committee and candidate accepting contributions and making expenditures designate in their registration statement the location and title of the campaign depositories of that political committee or candidate.  In light of these provisions, which must be read in tandem, it is our considered opinion that the names of campaign depositories should include both the names of the candidate and the authorized political committee.  As stated previously, the recommended designation will clearly inform the electorate of the entity and the individual to whom a contribution is made.