July 2, 2008
James J. Bailey, Chairman, Corrective Legislative Action PAC
E. Graham Thompson, Chairman, FuturePAC
P. O. Box 3217
Baton Rouge, LA 70821
Re: Ethics Board Docket No. 2008-488
Dear Mr. Thompson and Mr. Bailey:
The Louisiana Board of Ethics, in its capacity as the Supervisory Committee on Campaign Disclosure, at its June 26, 2008 meeting, considered your request for an advisory opinion concerning the propriety of the Corrective Legislative Action PAC (CLA) merging with Future PAC. You state that the goals of Future PAC are closely aligned with those of the CLA and that both organizations promote economic development in the Baton Rouge region. You further state that Future PAC has achieved Big PAC status while CLA’s membership is 49 and that CLA currently has approximately $31,000 in funds and would like to transfer these monies to Future PAC.
The Board concluded, and instructed me to inform you, that based on the facts presented it is the opinion of the Board that the merger, as described, is not prohibited by the provisions of the Campaign Finance Disclosure Act. However, the statutory limits as to contributions received by the political committees and contributions to candidates made by the political committees should be aggregated. Section 1505.2K of the Campaign Finance Disclosure Act provides that no person shall contribute more than $100,000 to a political committee for a set four year cycle - the current cycle runs from January 1, 2007 to December 31, 2010. Therefore, if an individual has contributed more than $100,000 during that four year period to either political committee, no more contributions may be received Future PAC from that individual. Section 1505.2H sets forth those contribution limits applicable to candidates. If the political committees in the aggregate have made contribution(s) to a candidate up to the maximum statutory limits, no further contributions may be received by that candidate from Future PAC for that election.
The Board issues no opinions as to laws other than the Campaign Finance Disclosure Act. If you have any questions, please contact me at 763-8777.
LOUISIANA BOARD OF ETHICS
Alesia M. Ardoin
For the Board