By Trey Richardson
Master the science of gathering approvals from member-corporations—an activity that must be performed before implementing PAC solicitations—with this easy eight-step approach. By following a specific plan to contact members within specific timeframes via a multichannel approach, you’ll avoid a lot of the stress usually related to this type of requirement and begin your PAC solicitation in compliance with the rules of the Federal Election Commission.
In spite of the critical importance of prior approval, few trade associations have mastered the science of gathering approvals from member-corporations. This is an activity that must be performed before implementing political action committee (PAC) solicitations. Moreover, prior approval is frequently looked upon as one of the most difficult jobs in the fundraising process for PAC professionals.
A lot of the dread stems from a lack of understanding by association members and inexperience among staff. However, the task at hand becomes much more pleasant when people are well educated and begin to see success.
Understanding Prior Approval
Prior approval is not new. The Federal Election Commission has required approval to solicit from a member-corporation since 1977. Specifically, approval is required prior to soliciting contributions to the association’s PAC from the restricted class of a member-corporation. The restricted class includes the corporation’s executive and administrative personnel, stockholders, and the families of both groups.
Solicitation of a corporate member’s restricted class is a two-step process, according to the Federal Election Commission’s Campaign Guide for Corporations and Labor Organizations. First, the trade association obtains the corporate member’s written approval for solicitation; second, the association then conducts the solicitation.
The Federal Election Commission allows a trade association to make written requests to member-corporations for permission to solicit the member’s restricted class, in addition to allowing permission through email and on the association’s website. In all cases, the approval form must include 1) a specific designation for each year a member-corporation approves solicitation; 2) a statement that the approval is necessary before any solicitation may be conducted; and 3) a notice describing that a corporation may only provide approval to one trade association per year.
More information about the rules for prior approval can be found at www.fec.gov.
Running an Effective Prior Approval Campaign
An effective prior authorization effort, like solicitation, begins with educated solicitors and an aware constituency. Trade association members who are active in fundraising for schools, charities, and candidates often push back when they are advised that approval is required before they may begin solicitations for the PAC. This is particularly true of boards active in the fundraising process. To overcome this obstacle, prior authorization should represent a significant component of legal compliance training annually for the board, staff, and other volunteer solicitors. In addition, materials and handbooks should be created and distributed to all solicitors detailing the dos and don’ts of fundraising.
Once training is complete, the association should implement an awareness effort among its members. This effort may include articles in association publications, email marketing, and/or brochures detailing the rules for enrolling in the PAC. Forums and small group presentations are also helpful in laying the foundation for prior approval activities.
Ensuring Effective Implementation
In spite of a well-educated membership, prior approval campaigns often fail at the implementation stage. The typical campaign relies on a single marketing channel, such as a letter or email from the chairman or president to the corporate representative with whom the association normally conducts business.
These communications often receive a response rate of two to five percent. The reason for this is two-fold. First, emails with embedded online forms are difficult to print and share with decision makers, so they are forwarded and lost in the blizzard of emails received every day. Second, letters get a little better result, but are ignored unless they are from the right person and include a sense of urgency. For example, if you send a letter to 1,000 members, you should expect to receive approximately 20 to 50 responses to your request. This response rate is consistent for political direct mail among association members whether asking for prior approval or a PAC contribution. Unfortunately, such low response often demoralizes staff and leaders, not to mention limits the association’s class for solicitations.
Effective prior approval campaigns use multichannel marketing techniques. These include a mix of letters, email, faxes, and phone calls. This approach has worked very well among trade associations with as few as 700 and as many as 40,000 member-corporations. By dividing the campaign into separate tactics, we typically see response rates of some 30 to 50 percent among members.
8 Steps to Success
To assist you in your efforts, follow this simple model based on 25 years of experience in PAC fundraising. By following these eight steps, you will achieve success in your a multichannel prior approval effort.
- Before you begin: Clean up and verify your membership records by confirming name, address, fax, email, and phone information. When you complete this phase, household your file so you are only communicating with your association’s point of contact within the corporation. The curse of any marketing effort is a bad file.
- Day One: Send a formal prior authorization letter from your president or chairman to your association’s point of contact within the corporation. The package should include a cover letter explaining prior authorization, approval form, reply envelope, due date for responding, number for fax responses, and a web address to find the form online. This online form must go behind a member login, but in front of your online giving page if one exists.
- Day Seven: Send an email consistent with the content of the letter to your association’s point of contact within the corporation. Include a link to the online approval page (discussed above) and attach a link to a printable form that may be returned via fax or mail.
- Day 10: Fax a cover letter and approval form to every point of contact that has not responded. The fax should be a two-page fax merge with the contact’s name, company, address, etc., on the form itself. This lets your members know that you’re paying attention. Further, in today’s communication environment, “Dear Friend” letters go to the trash and emails get ignored, but personalized faxes get read. This is especially true if your fax includes language about the recipient’s response being a requirement for participation under federal law.
- Day 20: Make a call to every point of contact. Don’t be discouraged if you only get through to 30 percent of your file after three attempts. That’s normal. Leave messages for everyone you don’t speak with telling them they should have received a letter and/or email, and ask them to respond by a specific date. If those you speak with say they didn’t receive the letter or email, confirm their contact information and resend. Nearly 50 percent of people contacted will say they don’t remember seeing the letter or email.
- Days 30 Through 50: Identify any approvals you have received via mail, email, or fax on your contact file and repeat the process described above. This time, however, have your association’s treasurer or general counsel do the asking. Limit your follow-up communications to email, fax, and phone calls. Interestingly, because many members never hear from your lawyers or others in leadership, they pay particular attention and response rates may increase.
- Day 60: Send a “final notice” via faxes and email to all of the contacts that have yet to respond. Let the contacts know you have extended the deadline by five days and their response is necessary for legal compliance purposes.
- Day 70: Update your file and begin your PAC solicitation.
If you follow this process and your content accurately reflects the legal compliance nature of this activity, you should receive approval from at least 30 percent of your member corporations. Figure 1 represents a sample matrix for any successful prior approval campaign regardless of the size of your association.
Figure 1: Sample Prior Approval Campaign Activities
Trey Richardson is principal of Sagac Public Affairs, a national company providing communications, research, fundraising, and management solutions to hundreds of corporations, trade associations, and political organizations. Email firstname.lastname@example.org.