Many NAIFA Chapters are embracing social media tools such as Facebook, Twitter, and Instagram, and integrating these tools into their chapter activities. IFAPAC related information on social media and websites is subject to both federal and state election laws, and these laws require that the federation
regulate access to IFAPAC related sections of our sites and social media community pages.
Chapters must carefully monitor the content of their sites if they include IFAPAC information that goes beyond simply providing information about PACs and also constitutes a solicitation for IFAPAC contributions.
Only NAIFA’s solicitable class can have access to most IFAPAC information and materials as well as be solicited to contribute to IFAPAC. NAIFA’s solicitable class includes all members (as defined by NAIFA) and their spouses as well as national and chapter, administrative, and management personnel. Anything which could be considered a solicitation for an IFAPAC contribution will need member access only password protection.
For example, posting the names of contributors and amounts contributed, particularly if those having made such contributions are favorably commended is considered a solicitation.
So what exactly constitutes a solicitation?
The FEC says any communication which “encourages… support [of] the PAC’s activities (by making a contribution) [or] facilitates the making of contributions.” Facilitation of the making of contributions would include providing information on how individuals may contribute to the PAC, such as by including an address to which a contribution may be sent in the communication.
What is and is not a solicitation?
Do not try to interpret FEC meaning on your own. If you are unsure, even in the slightest, the best course of action is to always seek approval from the National IFAPAC staff.
What IFAPAC information can be placed on the association's public web pages & social media?
• General information about IFAPAC, such as contact information and staff
• General information about IFAPAC activities, such as a calendar of IFAPAC events
• IFAPAC financial information, such as how much had been contributed or the number of contributors to IFAPAC in a given period
• Information about contributions IFAPAC has made to candidates
• A description of the restrictions under which IFAPAC operates, such as that only NAIFA members may contribute to IFAPAC or who determines which candidates will receive IFAPAC support
• Copies of the campaign finance reports filed with regulators, such as the Federal Election Commission or its state counterpart, setting forth the contributions received or disbursements made by IFAPAC
• Contributors may post information about themselves for the recognition they have received for their investments, such as being a Diplomat, but cannot write posts encouraging others to make similar IFAPAC contributions
How can a chapter promote IFAPAC fundraising events on its public pages?
A chapter could list IFAPAC fundraising events on its public pages and calendars but must be careful that the name of the event itself does not constitute a solicitation, nor can there be specific information about the event beyond the location, date, and time of the event. For example, the chapter can list “IFAPAC Casino Night” on its public website calendar with a link to a password-protected area of the site that would contain more detailed information. However, events named “Give to IFAPAC” or “IFAPAC Needs Your Contribution” could not be publicly displayed, because those names would constitute solicitations.
Moreover, information that expressly encourages attendance and/or PAC contributions at such an event, or information about where to send PAC contributions, constitutes a solicitation. In other words, a chapter can only list the innocuous name, location, date, time, and say nothing else.
What else must chapters do when using websites and social media for IFAPAC?
• Include FEC Disclaimer Language on every solicitation: Contributions to IFAPAC are voluntary and contributed to candidates for elective office. If you have directed NAIFA to do so, your contributions will be divided between your state IFAPAC chapter and IFAPAC National. Club types listed above are merely suggestions. You can contribute more or less than the suggested amount. The amount contributed will not benefit or disadvantage you in any way. You have the right to refuse to contribute without reprisal. Corporate contributions to IFAPAC’s political fund are prohibited. Contributions to IFAPAC are not deductible for federal income tax purposes. For NAIFA-Massachusetts members, the division of funds will be 50%/50% up to the state limit of $500 per calendar year.
• The chapter must, as noted, employ member access only password protection feature for areas of their site which may include an IFAPAC solicitation. The site administrator should also implement a process that terminates an individual’s ability to access the protected portion of the site or social media community when membership terminates.
• If people other than the site administrator are permitted to post messages to chapter public social media accounts, the chapter must police those social media accounts and immediately delete any posts which may contain solicitations for IFAPAC. The original posters may be contacted and requested to repost with edits.
• If a chapter allows anyone other than the site’s administrator to post on its social media, it may also want to include a disclaimer on the public page reminding members that
o “IFAPAC-related messages may only contain general information, and may not solicit IFAPAC contributions or provide information about making or encouraging contributions to the PAC.”
Social Media Tag Suggestions
@NAIFA, #NAIFAProud, #GrassrootsArmy, #IFAPAC, #NAIFAAdvocacy, #financialsecurity, #financialwellness, #MainStreetUSA,#ProudIFAPACSupporter
#CitizenAdvocates
Tips for Tagging Legislators
• Never post a photo with an IFAPAC check in the picture.
• Do not use #IFAPAC
• Do not seek to antagonize or cause arguments with legislators these communications are part of NAIFA’s grassroots interactions
• Always seek permission from the legislator before taking a picture during a meeting to use on social media.
• For additional tips check out the Post Like Pro graphic.
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Questions?
If you have any questions regarding social media practices, you may contact the IFAPAC staff at ifapac@naifa.org.
The IFAPAC Administration Fair Share Contribution is the amount each chapter pays to fund a portion of the costs necessary to operate IFAPAC. The 2021 contribution will be $7.00 per member annually and will be paid by drafts from monthly chapter dues disbursements. (A chapter’s contribution will be $3.50 per member annually for those members who belong to a state and local chapter.)
IFAPAC serves as the collecting agent for both the federal PAC (NAIFAPAC) and every state chapter PAC, all of whom together comprise IFAPAC. IFAPAC operations include national staff to process every transaction and attend to all pay-to-play and compliance requirements for all states regarding all IFAPAC receipts. IFAPAC operations also cover the costs of all bank and credit card processing fees for IFAPAC contributions. Administering IFAPAC – one of the largest political action committees in the insurance industry and the collecting agent for 51 state PACs – has expenses including staffing, donor database management software fees, donor recognition materials, solicitation and other PAC mailings (printing and postage), meetings, marketing and promotional materials, customized election reports, target lists, overhead, and other additional expenditures.
It’s essential that 100% of the political (hard) dollars raised by IFAPAC is used to support candidates for elective office, not for operating expenses.
National dues cover a large portion of IFAPAC administration costs. The costs covered by the national portion of dues include staffing, donor database management software fees, donor recognition materials, mailings, marketing and promotional materials, customized election reports, credit card fees, overhead, and other expenses that benefit both national and every chapter.
All chapters must help fund a portion of the costs to administer IFAPAC because all chapters benefit from the operation of IFAPAC. Since 1968, IFAPAC has requested that chapters help pay for IFAPAC administrative expenses. Not all chapters did so, or they responded in an inconsistent manner. The mandatory per member fee treats all chapters equally and ensures that IFAPAC receives a fair share of its administrative funding from all NAIFA chapters, who each benefit from IFAPAC’s operation.
Each chapter’s full fair share fee is $12.00 per member annually (or $6.00 for those members who belong to a state and local chapter). This amount is 40% of IFAPAC’s annual operating costs, net of the federal PAC’s share of member administrative contributions, divided by the number of members. The 2021 fee has been decreased to $7.00 to give chapters time to allocate funds in their budgets for this expense.
The fair share contribution amount is limited to an amount that should be manageable for chapters while also helping to cover a fair portion of IFAPAC costs. It is estimated that chapter fair share contributions in 2021 will fund only 24% of IFAPAC’s operating costs (net of a portion of individual member administrative account contributions). The remaining 76% of the funding needed to cover the costs to administer IFAPAC will come from contributions from NAIFA’s operating account.
Consideration was given to returning a portion of the IFAPAC Administration Fair Share Contribution to chapters for their state PAC administrative accounts. However, it was decided to limit the contribution to only that amount to be used to administer IFAPAC to make the contribution amount more manageable and so that each state chapter can determine for itself what amount it needs to administer its state PAC by budgeting for these costs in the chapter’s annual budget.
Yes, any member whose contribution to IFAPAC is deemed administrative will still be shared back with the member’s state chapter administrative account if the member’s Pay-to-Play Rule Directive allows for sharing.
January 2021. The NAIFA Board approved this program in 2019 but delayed its implementation until 2021 to allow time for preparation and prioritization.
Beginning in 2021, a chapter’s fair share will be deducted from monthly dues disbursements. If a member pays an annual amount, the full $7.00 is deducted in the month of payment. If a member pays monthly or for a portion of a year, a prorated amount of the $7.00 is deducted based on the number of months the member has paid for. (Remember, a chapter’s contribution will be $3.50 per member for those members who belong to a state and local chapter.)
The chapter per member annual contribution amount will increase by $1.00 per year until the chapter fair share contribution is 40% of IFAPAC’s operating costs. Forty percent of IFAPAC’s operating costs is currently $12.00 per member.
Administrative funds allow for 100% of political dollars to be spent on candidates. In states that allow candidates to accept soft dollars, this is an additional source of funds to support candidates.
Administrative funds help cover the operating costs allowing for creative and interactive fundraising events/campaigns and recognition opportunities.
Chapters can raise administrative dollars by asking members to contribute directly to the administrative fund from their business or personal accounts. All contributions written from business accounts are treated as administrative contributions and are shared with state administrative accounts when such sharing is permitted by member Pay-to-Play Rule Directives.
Chapters can host administrative specific fundraising campaigns, such as a ring toss, silent auction, or other activities with proceeds designated specifically for administrative dollars.
Chapters can also contribute general funds directly to IFAPAC in addition to the payment of their Administration Fair Share Contribution.
Yes, but funds can be transferred in this manner only in states where administrative dollars can be used to support candidates. In such states, chapter general treasury funds can be directed to the chapter’s state PAC to support candidates. Where permitted, such contributions do not count towards the state‘s fair share fundraising goals and the state chapter is required to track any limits that apply to those contributions.
The disbursement report a chapter receives every month will show each member’s dues payment in one column and the fair share contribution amount in another column, with totals for both. Based on this report, a chapter can appropriately record dues payments, and the fair share contribution expense. The amount disbursed will be the net of the dues payments minus the fair share contributions.
No. We would like to accommodate payment requests that differ from withholding the fair share contribution as part of the dues disbursement, but we are unable to administer such exceptions. Each month we process over 10,000 dues payments and our system doesn’t allow us to make exceptions to the general rule.
A Chapter who wishes to cover their fair share contribution from their PAC’s administrative fund, and whose state law allows this, can reimburse their operating account from the PAC administrative account based on the contribution total in the disbursement report.
The best way is to multiply the budgeted number of members for 2021 by $7 for members who do not belong to a local chapter, and by $3.50 for those members who do belong to a local chapter. The calculation is an estimate based on the projected number of members who will pay their dues in 2021.
