IAA-PAC Fact Sheet
In order to strengthen the IAA’s government relations efforts, the Board of Governors determined that the IAA should support political campaigns of federal candidates who play influential roles in setting the statutory framework governing our membership. Accordingly, the Board approved the creation of the Investment Adviser Association Political Action Committee (IAA-PAC). IAA-PAC is registered with the Federal Elections Commission and operates in strict conformity with federal law.
Political Action Committee (PAC) Defined
Under federal election law, no corporation – including a non-profit association such as the IAA – is permitted to contribute money directly to candidates, but may only do so through a separate segregated fund called a political action committee (or PAC) set up for the purpose of making political contributions to candidates for elective office. All contributions to a PAC are made voluntarily by individuals, not corporations.
IAA-PAC supports candidates to the US Senate and House of Representatives who influence decisions regarding policies affecting the investment advisory profession. In a highly competitive legislative arena with many different interests vying for Congress’ attention, PAC contributions can strengthen relationships with key policy makers.
Who can the PAC solicit for contributions?
As a trade association, the IAA’s PAC is only permitted to solicit voluntary contributions from the executives and administrative personnel of its member companies (defined as salaried personnel who have policymaking, managerial, professional, or supervisory responsibilities) after receiving written permission to do so. Accordingly, either an appropriate corporate officer or the corporate representative authorized by the firm to serve as the IAA’s principal contact must sign and return the Solicitation Authorization Form authorizing IAA-PAC to solicit its executive and administrative personnel.
Please note that in no event will IAA-PAC solicitations be sent to persons at your firm other than those with whom IAA regularly communicates and those executives who are either designated by you or disclosed in your firm's Form ADV, Part 1.
Solicitation Authorization Form
Signing the IAA-PAC Solicitation Authorization Form does not obligate you or others at your firm to contribute to the PAC. Contributing to IAA-PAC is a voluntary decision and no advantage or disadvantage will be given based on an individual’s decision to contribute or not. Additionally, corporate approval of a trade association PAC does not limit the corporation’s right to solicit contributions for its own PAC, or an individual’s right to contribute to multiple federal PACs, or any state or local PACs. A corporation, however, may not authorize more than one trade association to solicit its employees in a calendar year.
Are contributions to IAA-PAC tax deductible?
Personal contributions to IAA-PAC are not deductible as charitable contributions for federal income tax purposes.
To which candidates will IAA-PAC contribute?
In accordance with the authority conferred by the Board of Governors (BOG) to the IAAPAC Board of Directors (comprised of three BOG members, IAA Executive Vice President, and IAA Vice President for Government Relations), IAA-PAC will make contributions on a non-partisan basis to candidates for the US House of Representatives and the US Senate who may influence decisions regarding those issues of concern to investment advisers and/or serve on the House and Senate Committees with legislative jurisdiction over these issues.
How much may individuals contribute to IAA-PAC?
An individual may not contribute more than $5,000 a year to one PAC. However, a husband and wife each have a separate $5,000 limit, even if only one spouse has income. Federal law requires that IAA-PAC report the full name, mailing address, occupation and name of employer of each individual whose contributions aggregate more than $200 in a calendar year. All contributions must be personal, not corporate.
Would a Contribution to IAA-PAC Violate the SEC’s “Pay to Play” Restrictions?
No. Under its bylaws, IAA-PAC is authorized to make contributions only to candidates for the US House of Representatives and the US Senate; further, IAA-PAC is not authorized to contribute to any “official” of a state or local “government entity,” as defined in Rule 206(4)-5 (generally, state and local incumbents, candidates, or successful candidates with certain influence or authority over advisory contracts with government pension plans) even if such state or local official is a candidate for the US House of Representatives or the US Senate. Effective March 14, 2011, however, an investment adviser that provides advisory services to a state or local government entity as a client (or as an investor in a pooled vehicle) must maintain records of any payments made by the adviser or certain of its employees to PACs, including contributions to IAA-PAC.
If you have any questions about IAA-PAC, please contact IAA Vice President for Government Relations Neil Simon at email@example.com or (202) 293-4222.