The Illinois State Board of Elections made significant changes to disclosure rules of campaign contributions effective January 1, 2011. As a result of the new rules, many organizations, including labor organizations and their political action committees (PAC), may have additional filing requirements. Some of the major changes are summarized below.

Any organization that accepts contributions or makes expenditures exceeding $3,000 on behalf of, or in opposition to, a candidate for public office during a year must register with the Illinois State Board of Elections as a PAC and will be required to file periodic reports detailing receipts and disbursements. There are also additional reporting requirements for organizations that make more than $3,000 of “independent expenditures” during a year. An independent expenditure is defined as any payment made for electioneering communications or expressly advocating for or against a candidate, provided spending is not made in connection in any way with a candidate or their committee.

In addition to the changes to the disclosure rules, effective January 1, 2011, the amount of contributions a political committee can accept from individuals, labor organizations, and PACs is limited. The maximum contribution a committee can accept from a PAC is $50,000. There are special rules that apply to the transfer of member dues by a labor organization to their PAC.

The new rules have very specific reporting requirements that must be complied with in order to avoid substantial penalties. However, there are provisions of the new law that are unclear and subject to interpretation. Additional information is available on the State Board of Elections website at www.elections.il.gov.