Coordinated expenditures are expenditures made in cooperation, consultation or concert with, or at the request or suggestion of, a candidate, a campaign, or a political party committee.
A group will be considered coordinated if they have been exposed to nonpublic strategic info about a campaign or political party’s efforts in a given race, and any money the group spends on that election based on that info will be considered a coordinated expenditure. A coordinated expenditure is treated as an in-kind contribution for reporting purposes.
Whether a group is coordinated ultimately depends on the extent of the group’s interactions with the candidate, campaign, or political party, and how those interactions have affected the group’s strategic decision-making in that election.
Examples of coordination:
- A campaign working directly with a local group on the best messaging to use while canvassing.
- A group reaching out to a campaign to figure out which voters the group should target for Get Out The Vote (GOTV).
- A campaign asks a group to use their connections with a local reporter to arrange news coverage of the candidate’s upcoming speech.
The question at the heart of the coordination analysis–whether a group has been exposed to nonpublic strategic info–also reveals the types of info that can be shared without giving rise to coordination: info that is publicly-available and/or non-strategic.
Comparison: Independent vs Coordinated Expenditures
Restrictions
- Independent Expenditures: can’t share nonpublic strategic info about electoral plans and activities with the campaign or political party.
- Coordinated Expenditures: can work directly with, and share nonpublic strategic info with, the campaign or political party.
Limits
- Independent Expenditures: spending is generally unlimited.
- Coordinated Expenditures: spending is subject to contribution limits.
Who Reports
Independent Expenditure: the person or group paying for the Independent Expenditure is responsible for reporting. For more info on how to report independent expenditures, click here.
Coordinated expenditures: are treated as contributions for reporting purposes and, in general, it is the campaign or political party’s responsibility to report any contributions received. However, two major exceptions include in-kind contributions made by any person and any contributions made by PACs. For more info on how to report contributions and coordinated expenditures, click here.