Subject: Re: Hillary Clinton 2016: Campaign wants donors to pay for their own food, parking - Kenneth P. Vogel - POLITICO
From: "Alexander S. Mackler" <[email-masked]>
To: "Eric Schwerin" <[email-masked]>
Cc: "Hunter Biden" <[email-masked]>
Date: Tue, 18 Aug 2015 19:32:16 -0400

Maybe they can pay their do-nothing, hot-air consultants a little less? Just a thought. 

ASM

> On Aug 18, 2015, at 7:11 PM, Eric Schwerin <[email-masked]> wrote:
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> http://www.politico.com/story/2015/08/hillary-clinton-2016-campaign-wants-donors-to-pay-for-their-own-food-parking-121497.html#ixzz3jCnK6zYu
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> Hillary Clinton 2016: Campaign wants donors to pay for their own food, parking
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>  				
> Getty
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> Hillary Clinton’s campaign, which has struggled to keep costs in check, wants donors to pay for their own food and valet parking at fundraising events, according to a request it filed this month with the Federal Election Commission.
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> The request, released publicly by the FEC on Tuesday afternoon, sketches out a novel accounting plan under which the Clinton campaign would shift some fundraising costs to donors, without counting against their contribution limits.
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> According to the request signed by Clinton’s lead campaign lawyer Marc Elias, Clinton’s presidential campaign “plans to organize and host numerous events throughout the election cycle in restaurants, hotels, or similar event spaces,” including some at which it “does not plan to make significant food or beverages available to event attendees.” Instead, the campaign “anticipates that individuals in attendance may want to personally purchase food or beverages at the location of the event,” Elias wrote in the request.
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> Likewise, Elias wrote that the campaign anticipates that supporters who host fundraisers at “private homes, museums, or office conference rooms” will foot bills for their valet parking services, and that donors who “seek to take advantage of the valet service will pay the individual per-car price (e.g. $10) and any accompanying tip.”
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> Catering and parking at fundraisers can be quite costly.
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> The Clinton campaign, which has said it intends to run a tightfisted operation, spent about $125,000 on catering and about $18,000 on valet parking between its mid-April launch and the end of June, according to campaign-finance filings.
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> Campaigns usually either pay such costs directly or, in the case of smaller events in donors’ homes, allow hosts to donate food, drink and parking costs. But, when hosts provide services and the tally exceeds $1,000, the FEC interprets those costs as in-kind campaign contributions because they are considered “necessary expenses incurred to provide an inducement for the making of a contribution.”
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> And those in-kind contributions count against donors’ $2,700 contribution limit for the primary election. For example, if a host paid $3,000 for pastries, juice and coffee for a breakfast fundraiser, that person could write off $1,000 of it if it was in their own home, but they would only be able to donate another $700 in cash to the beneficiary campaign.
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> Under the accounting sketched out in the Clinton request, though, individual attendees — rather than the host — would each pay their own way. But the costs wouldn’t count as an in-kind contributions, and, as such, wouldn’t diminish the amount of cash they could give to the campaign.
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> The campaign’s rationale, according to the request, is that the food and parking services offered at the fundraisers in question aren’t “necessary expenses” related to the fundraising, but rather elective extras that aren’t central to the event.
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> The campaign, Elias wrote, “does not plan to have the food and beverages that individuals may want to purchase available at these events, nor will it imply on the invitations for the events that such food and beverages will be available. Contributions made to (the Clinton campaign) in connection with these events may be motivated by any number of factors, but they simply are not induced by the availability of food or beverages.”
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> Still, at least one campaign finance watchdog warned that the request could open the door for campaigns to offload all manner of other expenses to deep-pocketed supporters, allowing them to provide more assistance to candidates than envisioned by federal contribution limits.
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> “Why stop at food and valet? How about Uber cars for all attendees?” asked Paul Ryan, senior counsel at the Campaign Legal Center. “And would the campaign need to pay for a band that entertains guests at the restaurant ‘after’ the fundraising event, if the campaign says that it didn’t require the band for its fundraising event, but the restaurant wanted to have a band that night?”
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> And, if the FEC issues a broad ruling allowing the Clinton campaign to proceed, Ryan wondered whether corporations, which are barred from donating to campaigns, might be able to use the ruling to pick up expenses accrued by fundraiser attendees.
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> To prevent the Clinton campaign request from being used as “a Trojan horse,” Ryan said, it’s “pretty important” that, if the FEC approves the request, it “make(s) clear that it is only permitting attendees to pay their own expenses and that third parties are not allowed to pay these expenses.”
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> The six-member FEC can take weeks or even months to rule on such requests, and there’s no guarantee that it will issue clear guidance. The commission frequently splits on partisan lines, producing three-three votes.
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> Neither Elias nor a Clinton campaign spokesman responded to requests for comment.
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