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Craig Varoga tackles unsolicited PAC services, faux campaign logos and political comebacks.


Q: We just got an unsolicited letter from a bank offering “record keeping and reporting services” for our federal PAC.  They claim to be a “cost-effective outsourcing solution.” How is that possible?

A: Hey, it might be better than relying on the candidate’s Uncle Bill, who works as a bookkeeper in a small business two towns over, to run the checkbook, reconcile the bank statements, file the reports and otherwise try to remain in compliance with all laws and regulatory deadlines. The problem is that campaign finance reports require more than financial and legal rigor. They also demand sensitivity to appearances and an awareness of how the opposition will distort and exploit the information. So, while I’m loathe to issue an unconditional “no” without some more info, I definitely think the burden of proof is on the bank. The bank would need to prove its proficiency, trustworthiness and availability if and when something goes wrong.

Q: Should we try for an official looking logo and backdrop in an attempt to add some credibility and gravity to our campaign?

A: I’ve got a three-letter reflex reaction: Ugh. I’ve also got a two-word answer: Hell, no. Fake seals, faux logos and pretend trappings of office are silly at best and pretentious and self-important at worst. In some instances, they may even be unlawful if a jurisdiction prohibits the distribution of official-looking materials designed to mislead citizens.

If you’ve already gone this route, be prepared to call it a “silly mistake” or a “one-time thing for a one-time event.” Going forward, seek credibility through serious venues—private meetings with opinion leaders, solid performances in debates, speeches, policy rollouts and editorial board meetings.Q: How can we pull our opponent’s media buy at local TV stations?

A: All stations maintain public files of media buys by political candidates. This information must be open for anyone to view during the station’s normal business hours. According to Jon Hutchens of MSR Strategies, all you need to do is walk into the station and tell the receptionist which campaign you’d like to see the public political broadcast files for. Media buys are typically arranged by flight dates and are around four to six pages in length. Most stations will actually let you use their copy machines, so make sure you copy everything for the most current buy. And some stations do charge per copy, so don’t forget to bring some change.Q: In a recent column, you wrote about reporting requirements for bundling federal contributions. What is the reporting threshold?

A: According to the FEC, the reporting threshold for 2011 is $16,200. The commission will index the reporting threshold annually for inflation—so it could (probably will) be a little bit higher next year.Q: I’m talking to a potential client who used to be an elected official  but left office more than 15 years ago. Now he wants to make a comeback. Is this a good idea?

A: For every Jerry Brown or Terry Branstad—both governors who have now returned to the helm of their respective states after years out of office—who prove they can stage strong comebacks, there are dozens of ex-officials who have simply lost their mojo. They’re less likely to be equipped to understand the opportunities and risks of social media, 24-hour news cycles and the other trappings of modern campaigns. Think historic, world-class boxers—Joe Louis, Muhammad Ali, Sugar Ray Leonard—who unsuccessfully tried to fight their way back to the top after a long layoff.

So instead of just asking your prospective client why he wants to come back after 15 years, you should ask him why he left in the first place and what makes him think it’s going to be any easier this time around.  Craig Varoga has managed and consulted on local, state and national campaigns for more than 20 years. Send questions using Facebook, LinkedIn or email cvaroga@independentstrategies.com.


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