I Need Compliance Help

Can we use C3 or C4 matching gifts for a PAC event?

• No. You can only use a PAC matching gift to solicit donations for a PAC event. (We cannot combine dollars of different entities to the same total in a public communication.)

Can I talk about tax-deductible giving options at a PAC event?

• No. We cannot discuss C3 or tax-deductible giving options at a PAC event or within an email related to a PAC event. 
• If someone asks, say: This is a partisan event, so for legal reasons, we can’t talk about that here — can you contact us afterward (or email advisor@movement.vote) to discuss? 
• After the event, you can email them the link to our Donation Methods page: movement.vote/donate.

Can we track C3 gifts made by PAC event attendees?

• Yes. We can apply a refcode internally, so staff and volunteers can see the donation.

Can federal candidates and elected officials participate in our PAC events?

• Yes: Federal candidates, elected officials, and agents acting on their behalf, such as staff, can participate in PAC fundraising events. Important caveats:
• Ultimately, candidates should also be aware of their own legal compliance. MVP is not able to provide legal advice or guidance to candidates or officials. If candidates have any concerns, they should consult with their compliance team.
• We should not hold joint fundraisers with candidates, and candidates cannot solicit donations for their campaign at our events.
• If a volunteer wants to have a federal candidate or official at their PAC event, it is very important to let them know that any speeches, remarks, and/or discussions at the event should only reference public information (no insider strategy). The candidate or official cannot share any non-public information at the event, as this could be viewed as coordination with MVP. It is very important that MVP not be seen as coordinating with any candidates.

Can local or state candidates and elected officials participate in our PAC events?

• This will be dependent upon where/what office. Check with the Donor Organizing Team by emailing volunteer@movement.vote.

Rules and Checklist

Please review this checklist before you send a mass email to MVP supporters on your own email list.

Can I talk about Movement Voter Project (C4) or Fund (C3) in a PAC communication?

• As background: Movement Voter Project, Movement Voter PAC, and Movement Voter Fund are three legally distinct and separate organizations. (Learn more here.)
• PAC communications should only refer to Movement Voter PAC because your solicitations are to benefit the PAC entity.
• You can refer to Movement Voter Project as “the 501(c)(4) sibling to Movement Voter PAC.”
• You cannot mention Movement Voter Fund.
• Our PAC house party slide deck and speaker guide have been vetted and approved by our communications and legal team. You can mention any of the work in those resources freely in your PAC events or communications. You can also draw from any of our blog posts marked “Partisan”. 

OK, do we really have to say ‘Movement Voter PAC’ and not ‘Movement Voter Project’ when inviting people to a PAC fundraising event?

If you are inviting people to a PAC event, you need to refer to it as Movement Voter PAC to comply with entity consistency. Or, you can shorten it to ‘MVP’.

But I really want to mention some of our 501(c)(3) or nonpartisan-funded work!

In partisan communications, we CAN discuss 501(c)(3) organizations as well as specific, publicly-known nonpartisan C3 or C4 activities “at arms’ length” in the third person, as long as we DO NOT say or imply that “we” (e.g., Movement Voter PAC, or Movement Voter Project if we’re communicating in a partisan context) are FUNDING them or those activities.  

To minimize risk for the organizations themselves, we should also not say or imply that those activities have partisan implications.

• E.g., we CAN say, “Look at the great work Org X is doing,” NOT “Look at the great work Org X is doing that we funded through our nonpartisan C3 arm,” or “Look at this great nonpartisan work Org X is doing — it’s going to help us win the midterms!”
• Many 501(c)(3) organizations have 501(c)(4) sibling entities (e.g., Unidos MN Education Fund is C3, while Unidos MN Action is C4; ISAIAH is C3, while Faith in Action is C4). If you know the C4 entity name, please use that name.

Words to use when describing MVP

A few do’s and don’ts:

• Do say “mutual fund.”
• Do not say “clearinghouse.”
• Do not say “intermediary” or “funding intermediary.”

The legal backstory:

• We can say “mutual fund” because by definition, a mutual fund pools funds together and then determines how to use (in actual mutual funds, invest) the larger pot.
• On the other hand, we cannot say "clearinghouse" or “intermediary” because by definition (or implicit understanding), such an entity would only be facilitating transactions and would have no control over the ultimate use of funds. In IRS and accounting terms, that would be effectively the same as an “agency transaction”, which would show up on the organization's books not as revenue, but as simply cash in and cash out on the balance sheet — it would be a passthrough, and not actual MVP revenue or grantmaking activity.