Purpose of Summary

Many NAIFA members volunteer their time and money in order to further NAIFA’s advocacy and political programs. However, some companies and broker/dealers have created policies for their producers that restrict their ability to engage in political activities. NAIFA created this form to assist our members with defining the nature and scope of their volunteer political activities in order to assist their compliance department(s) in determining if a NAIFA member’s activities are covered by their policies.

After completing this form, NAIFA members should send it to the compliance department(s) of their insurance company and/or broker/dealer and ask the chief compliance officer 1) if their activities are covered by the company’s and/or broker/dealer’s compliance policies and, if so, 2) what activities are restricted.

About IFAPAC

The National Association of Insurance & Financial Advisors (NAIFA) is the national component of a federation of state and local chapter’s. NAIFA sponsors a federal political action committee (NAIFAPAC), which contributes only to candidates for federal office and national political parties. NAIFA’s federal PAC is a political action committee (separate segregated fund) registered only with the Federal Election Commission. NAIFAPAC is not registered with any state or local government entities and does not contribute to candidates for state or local office or state and local political parties or other state and local political funds. In addition, NAIFAPAC does not contribute to state or local officials who are candidates for federal office.

Each NAIFA state chapter has its own, separate political action committee, which is eligible to contribute to candidates for state or local office or state political parties and other similar political entities.

NAIFA’s federal PAC is not maintained or controlled by any NAIFA state chapter. NAIFA’s state chapter PACs are not maintained or controlled by NAIFA.

NAIFA’s federal PAC and state PACs cooperate and coordinate in raising funds from individual NAIFA members to the federal and state PACs.

IFAPAC contributions from individual NAIFA members are either 1) retained entirely by NAIFA’s federal PAC or 2) split between NAIFA’s federal PAC and the NAIFA member’s state chapter PAC. In order to be split between NAIFA’s federal PAC and the NAIFA member’s state chapter PAC, the NAIFA member must have previously notified NAIFA that he/she is permitted to contribute to a state PAC. NAIFA has advised all of its members to consult with their company and broker/dealer compliance department(s) to determine if their IFAPAC contribution(s) can be shared with their state chapter PAC.

My Involvement with IFAPAC (check all that apply)

I am a NAIFA member and would like to know the company’s or broker/dealer’s opinion on whether my ability to contribute to and participate in the fundraising and candidate selection activities of NAIFA’s federal and state PACs is affected by the company’s or broker/dealer’s interpretation of the SEC’s “Pay-to-Play” Rule. The following provides information about IFAPAC and my level of participation in NAIFA’s federal and/or my state chapter PAC:

• I solicit advisory business from state or local government entities on behalf of the company and/or broker/dealer.
• I supervise an employee of the company or broker/dealer who solicits advisory business from state or local government entities on behalf of the company and/or broker/dealer.

Personal Contributions

I am an IFAPAC contributor.

• I give $150 or less annually to IFAPAC – 50% (or more) of which is retained by NAIFA’s federal PAC and 50% (or less) of which is returned to my state chapter PAC.
• give $300 or less annually to IFAPAC – 50% (or more) of which is retained by NAIFA’s federal PAC and 50% (or less) of which is returned to my state chapter PAC.
• I give more than $300 annually to IFAPAC – 50% (or more) of which is retained by NAIFA’s federal PAC and 50% (or less) of which is returned to my state chapter PAC.

Local PAC Involvement

• I volunteer my time to assist IFAPAC fundraising by serving on a Local PAC committee. The committee’s purpose is to act solely to raise money for the federal and my state chapter’s PAC, not for individual state or local candidate campaigns, party committees or other similar entities. In this position, I have no involvement in determining which candidate campaigns receive PAC disbursements or the amount of any such disbursements to individual candidates, party committees or other similar entities.
• I volunteer my time to assist IFAPAC fundraising by chairing a Local PAC committee. I act solely to raise money for the federal and my state chapter’s PAC, not for individual state or local candidate campaigns, party committees or other similar entities. In this position, I have no involvement in determining which candidates receive PAC disbursements or the amount of any such disbursements to individual candidates, party committees or other similar entities.

State PAC Involvement

• I volunteer my time to assist IFAPAC by serving on the State PAC Board. I raise money from individual NAIFA members within my state for the federal and my state chapter’s PAC. In this position, I have no involvement in determining which candidate campaigns receive disbursements or the amount of any such disbursements to candidates.
• I volunteer my time to assist IFAPAC fundraising by chairing the State PAC Board. I raise money from individual NAIFA members within my state for the federal and my state chapter’s PAC. In this position, I have no involvement in determining which candidate campaigns or party committees receive disbursements or the amount of any such disbursements. 
• I volunteer my time by serving on the Candidate Selection Committee for our State PAC. Our committee is responsible for selecting which candidate campaigns, party committees and other similar entities receive my state chapter’s PAC disbursements and the amounts of such PAC disbursements. Campaigns and party committees that receive my chapter’s PAC disbursements are for state elections only.

National PAC Involvement

• I volunteer my time to assist IFAPAC by serving on the federal PAC Board. I focus on fundraising for the federal and all state chapter’s PACs from individual NAIFA members within our entire federation (nationwide). In this position, I have no involvement in determining which candidate campaigns, party committees or other similar entities receive disbursements from our federal PAC or the amount of any such disbursements.
• I volunteer my time by serving on the Candidate Selection Committee for NAIFA’s Federal PAC. The Committee is responsible for selecting which federal candidate campaigns and national party committees receive NAIFA’s federal PAC disbursements and the amount of such disbursements.

I request a timely response (within 15 days of the date below) from this compliance department regarding whether or not my individual NAIFA political activities are permitted based on company or broker/dealer policy. Please do not hesitate to contact me if you need additional information.

Download form