A leaked 2015 memo appears to give Hillary Clinton staffers advice on how to solicit large-sum donations for super PACs without breaking campaign finance laws restricting that behavior.
According to the Intercept, the memo in question was uncovered in Guccifer 2.0’s recent hack of the DNC and was written by Marc Elias, who now serves as general counsel to Clinton’s campaign. (RELATED: Hacker Leaks ‘Big Donor’ Information From Alleged DNC Breach)
Though Citizens United guarantees super PACs the ability to raise unlimited funds for candidates, the rules still prohibit official campaign staffers from soliciting donations larger than $5,000 on their behalf.
However, Elias’ memo explicitly states 10 guidelines for “how fundraisers may discuss Super PACs with campaign donors,” without breaking said laws.
- All conversations that refer to a Preferred Super PAC should include a hard ask for $5,000.
- As long as a hard money solicitation is made, you may speak freely about the campaign’s support for that Super PAC’s work.
- If a donor provides you with an amount of money that s/he wants to give and asks where it should go, you should reply with a hard money ask.
- If a donor tells you that s/he plans to give a certain amount of money to a Super PAC, you should reply with a hard money ask.
- If a donor asks you to identify the Super PACs that the campaign is supporting, you may identify them as long as you couple it with a hard money ask.
- If a donor asks whether the campaign is supporting the efforts of a particular Super PAC and it is not, you may tell the donor this.
- You may also ask donors to solicit funds from other individuals in $5,000 chunks for the Super PAC.
- Mere guidance about the law is permissible, in response to direct questions from donors.
- Do not specifically earmark the funds for the Secretary’s election.
- You may provide contact information of Super PAC personnel, but you may not lean on the donor to take a call or meeting from Super PAC personnel.
You can read the entire memo here.