FAQ:  Using Local IMPAC Funds for Media Expenditures

Many local AORs make use of their local IMPAC funds to support media campaigns on  local issues during elections.  These types of expenditures are a legitimate use of local IMPAC funds, and are encouraged.  However, the Fair Political Practices commission (FPPC) requires local AORs to follow certain procedures to ensure that any expense they make conforms to all standards of disclosure and accuracy. To help you process such a request, C.A.R. provides the following Frequently Asked Questions.  These are intended to provide you with as much information as you may need to process your request smoothly and in a timely manner. As a precaution, please always consult with C.A.R. staff before embarking on, or committing to, any use oflocal IMPAC funds for a media campaign.  Please contact Rick Laezman in C.A.R.’s Local Governmental Relations Division at (213) 739-8273 or richardl@car.org.

FREQUENTLY ASKED QUESTIONS

Q:  Can my local Association use local IMPAC to pay for a media campaign, and if so, what does this include?

A:  Yes, local IMPAC may be used for a media campaign to support local issues advocacy.  This includes direct mail pieces to property owners or voters, newspaper advertisements and radio ads.

Q:  Is there any special language that we have to include in our media material?

A:  Any media advertising for issues advocacy should clearly state that the source of funding is the California Association of REALTORS® Issues Mobilization Political Action Committee.  This language is required during a ballot measure campaign.  It is not required, but is suggested, for all other issues advocacy.

Q:  Are there requirements for the size or location of the disclosure?

A:  No, the disclosure can be in a smallfont located at the bottom of your mailer, as long as it is clearly visible and legible.   You may use abbreviations to economize space.

Q:  Why do we have to disclose C.A.R. IMPAC as the funding source when our local Association is the one paying for the ad?

A:  Your Association’s Local IMPAC dollars are deposited into,and withdrawn from, a statewide political action committee (PAC) that is controlled by C.A.R. 

Q:  If we disclose C.A.R. IMPAC as the funding source, our opponents might use that against us in the campaign.  Is there any way we can avoid the disclosure?

A:  In local ballot campaigns, the disclosure is mandatory.  However, if you donate your local IMPAC money to another PAC instead, any media that it prints will disclose that PAC as the source of funding.  Keep in mind that local IMPAC will still be disclosed as a donor to that PAC, and those records are public.

Q:  Can we mention our local Association anywhere in the ad? 

A:  It’s ok to mention the local Association as an advocate for or against the issue.  However, you maynot use the language “Paid for by (Local Association).”  You also may not use your local Association name in such a way as to give the impression that it is paying for the ad.

Q:  Are there any other language requirements for media campaigns?

A:  Other than the disclosure requirements, there are no specific requirements for the language of your ad.  However, C.A.R. also checks for accuracy of information, supportable assertions, proper language usage and general professionalism of your media campaign.

Q:  We are in a real time crunch.  How long does it take for C.A.R. staff and the IMPAC counsel to review our funding requests, and is there any way to speed up the process?

A:  Normally, the review process takes approximately two (2) weeks.  However, in cases where time is a consideration, upon request, your paperwork can be expedited in as little as two days.

Please remember to contact C.A.R. staff before you initiate any media buys that you intend to expense with local IMPAC funds.  C.A.R. will review your draft language and let you know if any changes are needed to avoid any complications with the funding of your request.  For more information, please contact Rick Laezman in C.A.R.’s Local Governmental Relations Division at (213) 739-8273 or richardl@car.org.