2016 CWA Political Action Fund Administrative Procedures Checklist
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- Kory Whitehead
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1 2016 CWA Plitical Actin Fund Administrative Prcedures Checklist 1. Dates f Prgram The 2016 CWA Plitical Actin Fund (federal plitical actin cmmittee- CWA-COPE PCC) Prgram will be cnducted n a calendar year basis beginning January 1, 2016, thrugh December 31, Payrll Deductins fr Member Cntributins: A member must cmplete the CWA Vluntary Check-ff Authrizatin Card in rder t cntribute t the CWA Plitical Actin Fund by payrll deductin. The card must then be submitted t the member's emplyer with a cpy t the District/Sectr ffice. Federal electin law als regulates hw PAC payrll deductins are slicited, received and recrded, and it is imprtant t make sure that CWA, its affiliates and ur members cmply with that law. In rder t achieve better cmpliance, Lcal Unins and District/Sectrs shuld take the fllwing measures. First, maintain cpies f all payrll deductin cards with member signature. Because a signed frm can authrize deductins that cntinue fr years, frms are smetimes misplaced r nt carried ver when, fr example, there is a crprate change r relcatin. Lcals shuld retain every frm fr members whse PAC payrll deductin is still active. Secnd, retentin f these frms must cntinue fr at least three years after the emplyee s deductins stp. It is fine t maintain the frms indefinitely if that is easier. Third, Lcals must maintain a cpy f every newly signed PAC payrll deductin authrizatin frm, even after the frm itself is submitted t the emplyer fr prcessing. Unin maintenance f cpies f the frms is necessary t verify the accuracy f emplyer administratin f the PAC payrll deductin plan, including the list f deductins that the emplyer transmits either t the Lcal r directly t CWA- COPE PCC. Finally, Lcals must make PAC payrll deductin frms available t CWA r CWA- COPE PCC if requested t d s. We will request them nly if we are legally required t r if we need t verify smething in cnnectin with the frms. IMPORTANT NOTE Each District/Sectr has enacted a District/Sectr-wide plicy t implement these prcedures. Please check with yu District/Sectr ffice fr a cpy f the District/Sectr PDA plicy
2 3. Recrd Keeping Fr Cash/Check Cntributins Lcals cllecting vluntary cntributins frm CWA members t the CWA Plitical Actin Fund are required by law t keep the fllwing recrds: A. Cntributins t the CWA Plitical Actin Fund (CWA-COPE PCC) in amunts f $50.00 r less per member cllected at a fundraising event: A Lcal must keep a recrd f the date f the cllectin, the name f the event at which the cllectin tk place, and the ttal amunt cllected; r, The name and address, date, and amunt f cntributin fr each cntributing member. Als, checks shuld shw the cntributr s name and address. Never accept a cash cntributin frm any individual in an amunt ver $100. B. Cntributins t the CWA Plitical Actin Fund (CWA-COPE PCC) by cash r check in amunts ver $50.00 per member: A lcal must keep a recrd f the cntributr's name and address and the date received and amunt f each cntributin, whether made in cash r by check. A cpy f this infrmatin shuld be sent t the CWA Plitical Actin Fund via the District/Sectr ffice alng with the cntributins cllected. Checks shuld be made payable t "CWA-COPE PCC". C. Cntributins t the CWA Plitical Actin Fund by cash r check aggregating ver $200 during a calendar year frm a member: A lcal must keep a recrd f the cntributr's ccupatin and name f emplyer, in additin t the cntributr s name and address, date received and amunt f each cntributin. 4. Transmittal f Cntributins CWA discurages lcals frm accepting cash r engaging in fundraising activities invlving cash. The preferred methds f the CWA Plitical Actin fundraising are signing up members n payrll check-ff (where available) r cntributins by check, mney rder, and/r credit card. A. Methd f Transmittal Cash cntributins shuld be frwarded t the CWA Plitical Actin Fund (via the District/Sectr ffice) in ne f the fllwing ways: A Lcal may depsit cash cntributins int the Lcal's CWA Plitical Actin Fund transmittal accunt, a bank accunt used nly t depsit and transfer cntributins t the CWA Plitical Actin Fund. This - 2 -
3 accunt must be separate frm the Lcal's general fund accunt(s) and may nt cntain any funds ther than vluntary cntributins t be sent t the CWA Plitical Actin Fund. [While the Federal Electin Cmmissin permits Lcals t transmit cntributin mney frm their general fund checking accunt, if prper and detailed recrds are kept, the CWA Plitical Actin Fund believes that it is safer and easier t establish a separate transmittal accunt fr frwarding these cntributins.] Cash cntributins may be frwarded t the CWA Plitical Actin Fund (via the District/Sectr ffice) by btaining a mney rder r cashiers check in the ttal amunt f thse cntributins made payable t CWA-COPE PCC and sending it t the CWA Plitical Actin Fund alng with the necessary cntributr infrmatin described abve. Checks in any amunt made payable t CWA-COPE PCC that represent vluntary cntributins frm CWA members must be transmitted t the CWA Plitical Actin Fund (via the District/Sectr Office) directly alng with the necessary cntributr infrmatin described abve. Cntributins made via payrll deductin must either be transmitted directly t the CWA Plitical Actin Fund by the emplyer making the deductin r, if received by the Lcal, must be transmitted via a check drawn n the Lcal s separate transmittal accunt, made payable t CWA-COPE PCC alng with the recrds f the date and amunt f each member s cntributin, the name and address f the member, and the member s ccupatin and emplyer. Never depsit CWA Plitical Actin Fund cntributins in an individual's bank accunt in rder t transmit them t the CWA Plitical Actin Fund. B. Timing f transmittal: All individual cntributins f $50 r less must be transmitted t the CWA Plitical Actin Fund within 30 days frm the date f receipt. All individual cntributins ver $50 must be transmitted t the CWA Plitical Actin Fund within 10 days f receipt. T meet this legal requirement, lcals must transmit any cntributins cllected by the Lcal t their District/Sectr ffice within ne week f the date f cllectin. 5. Allcatin and Crediting f CWA Plitical Actin Fund dllars When a lcal reaches 10% f its membership at a minimum f $1 weekly r higher, the mney will be allcated as fllws: 40%- Natinal 40% District 20% Lcal - 3 -
4 When a lcal reaches 15% f its membership at a minimum f $1 weekly r higher, the mney will be allcated as fllws: 37.5% Natinal 37.5% District 25% Lcal When a lcal reaches 20% f its membership at a minimum f $1 weekly r higher, the mney will be allcated as fllws: 33-1/3% Natinal 33-1/3% District 33-1/3% Lcal When a lcal reaches 35% f its membership at a minimum f $1 weekly r higher, the mney will be allcated as fllws: 30% Natinal 30% District 40% Lcal Credit fr the amunt cntributed t the CWA Plitical Actin Fund will be given t the Lcal and the District/IUE frm which it is received fr purpses f the CWA Plitical Actin Fund Awards Prgram. Because f stringent Federal Electin Cmmissin requirements, all cntributins t the CWA Plitical Actin Fund (CWA-COPE PCC) shall cntinue t be maintained in ne bank accunt in Washingtn, D.C. The prtins allcated t the District/IUE and Lcals will be available fr expenditure upn request by the Districts/Sectrs and the Lcals. Lcals must make their requests fr expenditures frm their prtin thrugh their respective District/Sectr ffices. CWA Plitical Actin Fund mnies shall nly be used t supprt a candidate wh is an AFL-CIO r CWA Plitical Actin Fund-endrsed candidate. 6. Credit fr CWA Plitical Actin Fund Awards Cnventin Stage Awards The time perid fr qualifying fr CWA Plitical Actin Fund awards will be all funds cllected between January 1 and December 31 unless therwise stated in the CWA Plitical Actin Fund Awards Prgram. District Meeting Awards The time perid fr qualifying fr CWA Plitical Actin Fund awards will be all funds cllected between January 1 and December 31 unless therwise stated in the CWA Plitical Actin Fund Awards Prgram
5 7. Check Cntributins All checks which represent vluntary individual cntributins frm members t the CWA Plitical Actin Fund federal accunt must be made payable t: "CWA- COPE Plitical Cntributins Cmmittee" r "CWA-COPE PCC." 8. Disclaimer Language Required n Fundraising All written slicitatins fr the CWA Plitical Actin Fund by a Lcal must cntain the fllwing language: A. "Cntributins t CWA-COPE PCC are vluntary. CWA members are nt required t cntribute t the CWA Plitical Actin Fund as a cnditin f membership in the unin r as a cnditin f emplyment and may refuse t d s withut fear f reprisal. The CWA Plitical Actin Fund will use the cntributins it receives fr plitical purpses including cntributins t and expenditures n behalf f federal and state/lcal candidates." B. "Paid fr and authrized by CWA n behalf f a jint fundraising effrt fr CWA-COPE PCC and AFL-CIO COPE PCC." C. "Cntributins r gifts t CWA-COPE PCC are nt deductible as charitable cntributins fr federal incme tax purpses." D. "Federal law requires us t use ur best effrts t cllect and reprt the name, mailing address, ccupatin, and name f emplyer f individuals whse cntributins exceed $200 in a calendar year". Requirements fr all Membership Club and Qurum Awards Cntributins may be in the frm f persnal checks, mney rders r payrll deductins (check-ff) payable t CWA-COPE PCC. CWA members wh are eligible fr membership will be given an incentive item frm the apprpriate club/qurum level, when they sign up fr membership. Credit fr Annual Awards will be given fr full amunt cntributed by a COPE member fr the previus calendar year. This credit will be given t the Lcal designated by the member t receive credit and t the District/IUE in which the Lcal is lcated. N mre than ne (1) Lcal can be designated t receive credit fr the member s cntributin. COPE Membership Club All CWA members wh vluntarily cntribute $1.00 a week r mre each mnth membership in the CWA Plitical Actin Fund COPE Club. Platinum Qurum All CWA members wh vluntarily cntribute $5.00 a week r mre each mnth membership in the CWA Plitical Actin Fund Platinum Qurum
6 Triple Qurum All CWA members wh vluntarily cntribute $7.00 a week r mre each mnth membership in the CWA Plitical Actin Fund Triple Qurum. President's Club All CWA members wh vluntarily cntribute $10.00 a week r mre each mnth membership in the CWA Plitical Actin Fund President s Qurum. 9. Unless specifically apprved by the CWA Executive Bard, CWA Plitical Actin Fund (CWA-COPE PCC), 501 Third Street, NW, Washingtn, D.C shall be the nly authrized plitical actin cmmittee affiliated with the Cmmunicatins Wrkers f America. 10. In n event shall a plitical actin r plitical educatin cmmittee ther than CWA-COPE PCC make expenditures in cnnectin with a Federal electin. Nnfederal plitical actin cmmittees spnsred by CWA Lcals and CWA Districts/Sectrs shuld crdinate with the CWA Plitical Actin Fund when making cntributins t state and lcal candidates. This will ensure that cntributins made by the natinal CWA Plitical Actin Fund and by such nn-federal PACs d nt exceed applicable state/lcal cntributin limits
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