The Massachusetts Office of Campaign and Political Finance (OCPF) issued an advisory opinion last week to clarify when an organization may be required to register with the state as an independent expenditure political action committee (IEPAC). An IEPAC is a political committee or other entity receiving contributions to make independent expenditures.

On September 18, the OCPF issued AO-14-05, which explains how an organization raising funds for political purposes is generally not required to register as an IEPAC in Massachusetts unless donors are told or otherwise know “that at least a portion of funds given will be used to influence” an election in the state. Registration as an IEPC with the state would not be required even if a portion of the funds raised by the organization is subsequently transferred to a Massachusetts IEPAC or is used by the organization itself to make independent expenditures in the state.