Successful PAC Prior Approval Campaigns

Trey Richardson, Managing Partner
Sagac Public Affairs, LLC

Revised: September 18, 2015

Despite the critical importance of prior approval, few trade associations have mastered the science of gathering approvals from member-corporations. This activity must be performed before implementing solicitations for political action committees (PACs). Moreover, prior approval is frequently looked upon as one of the most difficult jobs in the fundraising process for PAC professionals. Dread often stems from a lack of understanding by association members and an inexperienced staff. However, the task at hand becomes much more feasible when people are well educated and start to experience success.

Successful PAC Prior Approval Campaigns

Despite the critical importance of prior approval, few trade associations have mastered the science of gathering approvals from member-corporations. This activity must be performed before implementing solicitations for political action committees (PACs). Moreover, prior approval is frequently looked upon as one of the most difficult jobs in the fundraising process for PAC professionals. Dread often stems from a lack of understanding by association members and an inexperienced staff. However, the task at hand becomes much more feasible when people are well educated and start to experience success.

Prior approval is not a new concept. The Federal Election Commission has required approval before soliciting from member corporations since 1977. Specifically, approval is required before an association’s PAC can begin soliciting contributions from a member company’s restricted class. This 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. First, the trade association must obtain written approval from the member corporation; second, the association then conducts the solicitation.[1]

The Federal Election Commission allows a trade association to make written requests to member-corporations for permission to solicit their restricted class, in addition to allowing permission through email and on the association’s website.  In all cases, 1) the approval form must include 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.

Now that the fundamentals of prior approval are out of the way, we can get on to describing an effective campaign. You may find out more about the rules for approval at www.fec.gov.

An effective prior approval 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 become apprehensive when discovering approval is required before they may begin solicitations for the PAC. This is particularly true of boards that are active in the fundraising process. To overcome this obstacle, prior approval should encompass annual legal compliance training 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.

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 main corporate representative. These communications often receive a response rate of two to five percent. There are two reasons for this. 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, although direct mail receives a slightly better response, letters are often 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 – 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 limiting the association’s class for solicitations.

Effective prior approval campaigns use multi-channel marketing techniques. These include a mix of letters, emails, 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 an increase in prior approvals of some 30 to 70 percent among members annually.

To assist you in your efforts, I have created this simple model based on 30 years of experience in PAC fundraising to illustrate the success that can be achieved through a multi-channel prior approval effort.

Before you begin: Clean up and verify your membership records by confirming name, address, fax, and 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 approval 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 approval, 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 Ten: 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 let’s your members know that you’re paying attention. Further, in today’s communication environment “dear friend” letters are trashed and emails get ignored, but personalized faxes are frequently read. This is especially true if your fax includes language about their response being a requirement for participation under federal law.

Day Twenty: 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 immediately. Nearly 50 percent of people contacted will say they don’t remember seeing the letter or email.

Days Thirty – Fifty: 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, financial officer or general counsel do the asking. Limit your follow-up communications to email, fax and phone calls. Because many members never hear from your lawyers, finance staff or others in a leadership role, they tend to pay particular attention to these communications.

Day Sixty: 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 Seventy: 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

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Trey Richardson is Managing Partner of Sagac Public Affairs, a national company providing communications, research and fundraising solutions to hundreds of corporations, trade associations and political organizations. Sagac is the leader in the political community for strategy and implementation of PAC finance operations.


[1] Federal Election Commission, Campaign Guide for Corporations and Labor Organizations, Pages 107-108, 2007.

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