Advisory Opinions
The following list contains summaries of selected Advisory Opinions issued by the Minnesota Campaign Finance and Public Disclosure Board.

  • Full text of each opinion is available by clicking the desired link.
  • New opinions will be added to this page as they are issued.

Selected Advisory Opinions On Line
Listing begins with most recent opinion published and includes brief description of the subject

Advisory Opinion 438 Expenditures for which an individual will be deemed a candidate.
Advisory Opinion 437 Candidate fundraising for independent expenditure political committee or fund.
Advisory Opinion 436 The Purchase of Research and Polling Data Services
Advisory Opinion 434 A company that provides internet-based contribution processing and delivery services for a fee paid by visitors who use the company's website to make contributions to candidates is not, through that service activity, making a contribution to the recipient candidates. 
Advisory Opinion 433 A terminating principal campaign committee may donate committee funds to a county to help defray the cost of a special election, or may donate funds to the state of Minnesota.
Advisory Opinion 432 Withdrawn by Requester
Advisory Opinion 431 Potential Conflict of Interest
Advisory Opinion 430 Withdrawn by Requester
Advisory Opinion 429 Expenses that must be reported on lobbyist disbursement reports and annual reports of lobbyist principals.
Advisory Opinion 428 An association other than a principal campaign committee, party unit, or political committee, is not required to register and provide disclosure of communications naming candidates unless those communications use words of express advocacy.
Advisory Opinion 427 An association may permit donors to its political fund to indicate their preferences for candidates that the association should support. If donor preferences are not a direction or the equivalent of a direction to the association as to the candidates to whom it should donate, earmarking does not occur.
Advisory Opinion 426 Disclosure related to ballot question committees
Advisory Opinion 425 Creation and operation of a conduit fund by a union
Advisory Opinion 424 Cost of a reception given in honor of a candidate's retirement from public office may be reported as noncampaign disbursements
Advisory Opinion 423 Donations In-Kind to Ballot Question Committees
Advisory Opinion 422 Disclosure Related to Ballot Question Committees
Advisory Opinion 421 Disclosure Related to Ballot Question Committees
Advisory Opinion 420 Disclosure Related to Ballot Question Committees
Advisory Opinion 419 Disclosure Related to Ballot Question Committees
Advisory Opinion 418 Use of Information from Campaign Finance and Public Disclosure Board Records
Advisory Opinion 417 Withdrawn by Requestor
Advisory Opinion 416 Withdrawn by Requestor
Advisory Opinion 415 A contribution to a fund established to support a candidate's participation in a recount of ballots affecting that candidate's election is a noncampaign disbursement under Minnesota Statutes Section 10A.01, subd. 26(22).
Advisory Opinion 414

A presentation item that is in the form of a decorative axe is a plaque with a resale value of five dollars or less and, thus, is exempt from the gift prohibition of Minnesota Statutes Section 10A.071.

Advisory Opinion 413 Lobbyists must register on behalf of each association whose interests it promotes, regardless of the mechanism used to retain or direct the efforts of the lobbyists.
Advisory Opinion 412 Affect of a candidate's support of a political committee or fund on the independence of independent expenditures made by that committee or fund.
Advisory Opinion 411 Use of the noncampaign disbursement category for expenses of serving in office is not available to pay for home health care of a close relative while a public official is traveling.
Advisory Opinion 410 Communications that may defeat the independence of an expenditure.
Advisory Opinion 409 Activities that may require registration as a lobbyist, reporting of lobbyist expenditures.
Advisory Opinion 408 Use of a motor vehicle as an advertising device for a principal campaign committee.
Advisory Opinion 407 Gift of Minnesota Twins tickets
Advisory Opinion 406 Creation and Operation of Conduit Funds
Advisory Opinion 405 Definition of Political Committee
Advisory Opinion 404

Costs of candidate recruitment and education.

Advisory Opinion 403

Treatment of telephone survey costs as campaign expenditures or noncampaign disbursements.

Advisory Opinion 402

Gifts by a political subdivision’s employee-lobbyist to an official of the same political subdivision.

Advisory Opinion 401 This advisory opinion is not available to the public.
Advisory Opinion 400 Independence of Expenditures When a Consultant Performs Services for Both Candidates and Political Committees, Political Funds and Party Units that Wish to Make Independent Expenditures on Behalf of the Same Candidates.
Advisory Opinion 399 Contribution to Political Party Unit
Advisory Opinion 398 Actions to influence the nomination or election of candidates; requirement to establish a political fund.
Advisory Opinion 397 Eligibility for spending increase for candidate running for office for the first time
Advisory Opinion 396 Gift to officials of a commercially available digital video disk
Advisory Opinion 395 Ballot Question Activities
Advisory Opinion 394 Payment of Public Official’s Expenses of Participation in Television or Radio Messages
Advisory Opinion 393 Application of Gift Prohibition to Random Drawings
Advisory Opinion 392 Reporting of Lobbying Disbursements
Advisory Opinion 391 Transition Costs of a Constitutional Office
Advisory Opinion 390 Use of Principal Campaign Committee Funds
Advisory Opinion 389 Potential Conflict of Interest for a Public Official
Advisory Opinion 388 Cost of Mailing Informational Magnet and Note to Constituents
Advisory Opinion 387 Cost of Credit Card Transactions
Advisory Opinion 386 Candidate Running for Two Offices in the Same Election Year.
Advisory Opinion 385 Candidate participation in fundraising event; use of national political committee funds by political committee registered in Minnesota.
Advisory Opinion 384 First Time Candidate
Advisory Opinion 383 State Political Party Convention Expenses
Advisory Opinion 382 Withdrawn by requester.
Advisory Opinion 381 A Web Site Provided as a Donation In Kind to Candidates
Advisory Opinion 380 Gift Prohibition; Registration Fees for an Educational Program
Advisory Opinion 379 Compensation to a Candidate for Running for Office
Advisory Opinion 378 Constituent Services; Non Campaign Disbursement
Advisory Opinion 377 Multicandidate Political Party Expenditures
Advisory Opinion 376 Allocation of a Media Campaign Used for Multiple Purposes
Advisory Opinion 375 Segregated Accounts; Registration and Reporting
Advisory Opinion 374 First Time Candidate Spending Limit; Value of Automobile Use
Advisory Opinion 373 Timing of Notification Required by Minnesota Statutes 10A.25
Advisory Opinion 372 Gift Prohibition; Services to Assist in Performance of Official Duties.
Advisory Opinion 371 Unregistered Association Reporting Obligations; Contributions from Seperate Segregated Funds as Corporate Contributions
Advisory Opinion 370 Contributions to a Political Party Unit from a Principal Campaign Committee and Multicandidate Political Party Expenditures
Advisory Opinion 369 Collection of Contributions to Candidates Over the Internet
Advisory Opinion 368 Potential Conflict of Interest for a Member of the Legislature
Advisory Opinion 367 Withdrawn by requester.
Advisory Opinion 366 Reimbursement of Use of an Automobile
Advisory Opinion 365 In-Kind Contribution of a Local Access Cable TV Program
Advisory Opinion 364 Gift Prohibition; Education Sessions; Food and Beverages
Advisory Opinion 363 Solicitation of Funds During a Regular Legislative Session
Advisory Opinion 362 Campaign Expenditures and NonCampaign Disbursements
Advisory Opinion 361 Membership in a Group as an Exception to the Gift Prohibition
Advisory Opinion 360 Use of Party Unit Web Site to Collect Contributions for Specific Candidates
Advisory Opinion 359 Registration and Reporting Requirements for Political Committees and Political Funds
Advisory Opinion 358 Determination and Reporting of Lobbying Disbursements
Advisory Opinion 357 Compensation for Staff Services, In-Kind Donation to Pay for Living Expenses of Staff
Advisory Opinion 356 Fundraising and Expenditures by a Political Party Unit
Advisory Opinion 355 Potential Conflict of Interest for Legislature
Advisory Opinion 354 Noncampaign Disbursements Cost of Providing Food
Advisory Opinion 353 Withdrawn by requester.
Advisory Opinion 352 Use of party account check off funds by the state committee of a political party
Advisory Opinion 351 Reporting the use of a personal airplane for campaign purposes
Advisory Opinion 350 Lobbying on a contingency fee basis
Advisory Opinion 349 Communications for the purpose of obtaining a contract with the State of Minnesota.
Advisory Opinion 348 Acceptance of Gifts by a Local Official in a Metropolitan Governmental Unit
Advisory Opinion 347 Reporting the Cost of Producing and Disseminating Information Related to Legislative Action as a Lobbying Disbursement.
Advisory Opinion 346 Noncampaign Disbursements for Expenses of a Transition Office.
Advisory Opinion 345 Potential Conflict of Interest From an Associated Business.
Advisory Opinion 344 Judicial districts may not organize and register as a political party unit under Chapter 10A
Advisory Opinion 343 Revoked by the Board June 30, 2011
Advisory Opinion 342 Mailings to members of an organization for the purpose of influencing the nomination or election of a candidate is a campaign expenditure
Advisory Opinion 341 Providing the services of an employee to a candidate is an in-kind contribution from the employer.
Advisory Opinion 340 Revoked by Board, August 15, 2006
Advisory Opinion 339 Use of e-mail and websites in political campaigns.
Advisory Opinion 338 Definition of the term agent in relation to independent expenditures.
Advisory Opinion 337 Gift of coffee mug to officials.
Advisory Opinion 336 Use of specific words or phrases in campaign expenditures, independent expenditures, or lobbying communications and disclosure of funds used for lobbying purposes.
Advisory Opinion 335 Gifts to groups that may contain public officials.
Advisory Opinion 334 Definition of political committees and funds, reporting requirements of lobbyists.
Advisory Opinion 333 Definition of first time candidate.
Advisory Opinion 332 Disclosure of fees related to lobbying.
Advisory Opinion 331 Reporting of contributions to a political party.
Advisory Opinion 330 A public officials presence at a party paid for by a lobbyist principal.
Advisory Opinion 329 Use of campaign funds for travel expenses related to a legislative special session.
Advisory Opinion 328 Use of campaign funds for legal expenses.
Advisory Opinion 327 Withdrawn by requester.
Advisory Opinion 326 Definition of a Lobbyist.
Advisory Opinion 325 Potential conflict of interest for a legislator.
Advisory Opinion 324 Limits for candidates registering after an election.
Advisory Opinion 323 Use of principal campaign committee funds.
Advisory Opinion 322 Definition of first-time candidate.
Advisory Opinion 321 Use of campaign funds; anonymous contributions; and authority of deputy treasurer.
Advisory Opinion 320 Reporting of political expenditures
Advisory Opinion 319 Providing on-line contribution service.
Advisory Opinion 318 Use of principal campaign committee funds.
Advisory Opinion 317 Gift to officials of informational book.
Advisory Opinion 316 Application of gift prohibition; definition of official.
Advisory Opinion 315 Gift Prohibition; public official solicitation of contributions
Advisory Opinion 314 Use of principal campaign committee funds.
Advisory Opinion 313 Use of Principal Campaign committee funds for informational mailing.
Advisory Opinion 312. Withdrawn by requester.
Advisory Opinion 311 Publishing candidate links on state government office's website
Advisory Opinion 310 Fundraising activities of political committees.
Advisory Opinion 309 Lobbyist contributions to retirement party and gift.
Advisory Opinion 308 Definition of a lobbyist.
Advisory Opinion 307 Definition of constituent services.
Advisory Opinion 306 Status of Nonprofit Corporation as a Political Committee.
Advisory Opinion 305 Multi-candidate expenditure for Political Party fundraising.
Advisory Opinion 304 Lobbying Municipal Government Units.
Advisory Opinion 303 Special source contribution limit.
Advisory Opinion 302 Official party sample ballot.
Advisory Opinion 301 Registration of political committee
Advisory Opinion 298 Campaign expenditure definition; reporting contributions.
Advisory Opinion 297 Definition of Lobbyist Principal
Advisory Opinion 296 Definition of independent expenditures.
Advisory Opinion 295 Requirement to register a political committee.
Advisory Opinion 294 Definition of Constituent Services.
Advisory Opinion 293 Campaign fundraising activities.
Advisory Opinion 292 Determination of Lobbyist Principal .
Advisory Opinion 290 Contributions to political committee by Indian tribe.
Advisory Opinion 289 Application of gift prohibition to referral of legal client.
Advisory Opinion 288 Lobbyist Registration requirement for employee of public higher education system.
Advisory Opinion 287 Gift to official of special seating rights at athletic event
Advisory Opinion 286 Gift to officials of informational booklet.
Advisory Opinion 285 Application of noncampaign disbursement definition.
Advisory Opinion 284 Campaign finance laws applicable to nonprofit corporation.
Advisory Opinion 283 Gift to official, greeting card.
Advisory Opinion 282 Definition of volunteer time in reference to gift law.
Advisory Opinion 281 First-time candidate expenditure limit in a year prior to an election.
Advisory Opinion 280 Gift of services to assist an official.
Advisory Opinion 279. Contribution limit for political fund of merged associations.
Advisory Opinion 278 Application of gift prohibition exception for program participant.
Advisory Opinion 277 Gift of travel and lodging; use of principal campaign committee funds.
Advisory Opinion 276 Consideration for a transaction, otherwise a prohibited gift.
Advisory Opinion 275 Definition of constituent services.
Advisory Opinion 273 Gift to members of a group of conference reception or meals.
Advisory Opinion 272 Withdrawn by requester.
Advisory Opinion 271 Disposition of political committee assets.
Advisory Opinion 270 Sale of goods by an individual to a party unit.
Advisory Opinion 269 Gift of informational audio tapes to legislators.
Advisory Opinion 268 Gift of transportation.
Advisory Opinion 267 Potential conflict of interest for public official.
Advisory Opinion 266 Use of principal campaign committee funds for computer training.
Advisory Opinion 265 Use of funds by political party unit committee.
Advisory Opinion 264 Potential conflict of interest for legislator.
Advisory Opinion 263 Use of funds by legislative caucus committee.
Advisory Opinion 262. Withdrawn by requester.
Advisory Opinion 261 Use of candidate committee funds to promote a constitutional amendment.
Advisory Opinion 260 Fundraising for local office campaign by Ch. 10A candidate.
Advisory Opinion 259 Gift of dinner to legislators.
Advisory Opinion 258 Gift exception for members of a group.
Advisory Opinion 257 Revoked by the Board June 30, 2011
Advisory Opinion 256 Noncampaign disbursement for replacement of stolen campaign signs.
Advisory Opinion 255 Use of campaign funds for costs of serving in public office
Advisory Opinion 254 Activities related to student lobbying.
Advisory Opinion 253 Noncampaign disbursements for newly elected candidates.
Advisory Opinion 252 Gift of a dinner to legislators.
Advisory Opinion 251 Spending increase for candidate running for office for first time.
Advisory Opinion 250 Gift prohibition applied to legislative day activities.
Advisory Opinion 249 Application of lobbying statutes to internet worldwide website.
Advisory Opinion 248 Campaign expenditures and noncampaign disbursements.
Advisory Opinion 247 Free services used by candidate or party unit are not contributions.
Advisory Opinion 246 Gift to officials of guide to the Minnesota legislature.
Advisory Opinion 245 Gift of plaque to official.
Advisory Opinion 244 Use of Campaign Finance and Public Disclosure Board data.
Advisory Opinion 242 Legal defense fund for political official.
Advisory Opinion 241 Definition of first-time candidate.
Advisory Opinion 240 Political activity as a bona fide occupational qualification.
Advisory Opinion 239 Replacement of destroyed campaign materials.
Advisory Opinion 238 Award of plaque valued at $20 - $100.
Advisory Opinion 237 Conflict of interest statute applied to public official.
Advisory Opinion 236 Application of gift prohibition to employment search.
Advisory Opinion 235 Gift to official of computer mouse pad.
Advisory Opinion 234 Relationships between lobbyist principal and legislators.
Advisory Opinion 233. Withdrawn by requester.
Advisory Opinion 232 Gift prohibitions applicable to lobbyist giving baby shower.
Advisory Opinion 231 Independent contracts with officials are not prohibited gifts.
Advisory Opinion 230 Prohibition of indirectly controlled political committees.
Advisory Opinion 229 Trip awarded to official's spouse not a gift.
Advisory Opinion 228 Expenditure limits; purchase of computer.
Advisory Opinion 227 Gift of free admission to public performance.
Advisory Opinion 226 Gift of informational calendar.
Advisory Opinion 225 Allocation of cost of publication between campaign expenditures and noncampaign disbursements.
Advisory Opinion 224 Lobbyist Principal Definition
Advisory Opinion 223

Application of Minnesota Statutes Chap. 10A to fundraising for federal office.

Advisory Opinion 222. Withdrawn by the requester.
Advisory Opinion 221 Noncampaign disbursement categorization of certain costs incurred by a disabled candidate.
Advisory Opinion 220 Gift to official of food and beverage at employer reunion party; definition of "membership in a group".
A dvisory Opinion 219 Withdrawn by the requester.
Advisory Opinion 218 Gift to official of a plaque based on voting record.
Advisory Opinion 217 Application of gift law to wedding gift.
Advisory Opinion 216 Requirement to register as a political fund.
Advisory Opinion 215 Application of gift law to certain employment situations.
Advisory Opinion 214.
(Later reversed by Opinion 234)
Gifts to nonprofit corporation requested by an official.
Advisory Opinion 213 Official doing business with lobbyists and lobbyist principal.
Advisory Opinion 212 Application of gift law to family event for officials.
Advisory Opinion 211 Reporting by campaign committee for purchase of used computer.
Advisory Opinion 210 Meals provided to official who is a member of advisory council.
Advisory Opinion 209 Operation of multiple campaign committees.
Advisory Opinion 208 Activities included in time spent for lobbying purposes; reporting of strictly informational material.
Advisory Opinion 207 Aggregation of loans and contributions to campaign committee.
Advisory Opinion 206 Gift to official of transportation; gift to official's spouse.
Advisory Opinion 205 Gift to officials by association which is not a lobbyist principal.
Advisory Opinion 204 Gift to officials of lobbyist principal's membership directory.
Advisory Opinion 203 Gift to officials of federal tax guide.
Advisory Opinion 202 Gift to officials of issues forum and materials.
Advisory Opinion 201 Gifts to officials by lobbyist principal's employees.
Advisory Opinion 200 Gift to official of $30 book.
Advisory Opinion 199 Political party organization as defined by statute.
Advisory Opinion 198 Gift of plaque awarded to official.
Advisory Opinion 197 Gift requested by lobbyist or lobbyist principal.
Advisory Opinion 196 The Board was unable to approve an advisory opinion by the required four votes.
Advisory Opinion 195 Gift to official from nonprofit corporation for costs of an event.
Advisory Opinion 194 The Board voted not to issue an advisory opinion and voted to request guidance on the term "promise of future employment" from the legislature.
Advisory Opinion 193 Gift of meal served at program attended by official.
Advisory Opinion 192 Registration as a lobbyist for an employee of political subdivision or public body.
Advisory Opinion 191 Lobbyist principal providing food and beverage to officials at event.
Advisory Opinion 190 Self-employed official doing business with lobbyist principal.
Advisory Opinion 189 Gift of calendar book from lobbyist principal.
Advisory Opinion 188 Value of transportation provided by corporation which is a lobbyist principal.
Advisory Opinion 187 Gift of calendar or diary from labor organization.
Advisory Opinion 186 Providing food, beverage, door prizes at conference attended by official.
Advisory Opinion 185 Reception and dinner sponsored by lobbyist principal.
Advisory Opinion 184 Membership Directory Distribution.
Advisory Opinion 183 Gift of meal to official.
Advisory Opinion 181 Loan of a picture from a lobbyist principal.
Advisory Opinion 180 Membership in lobbyist principal organization does not make member a principal.
Advisory Opinion 179
(May be reversed by Opinion 273.)
Gift to official by lobbyist or lobbyist principal to pay for conference costs.
Advisory Opinion 178 Lobbyist principal offer to officials to purchase tickets to an event in advance of general public.
Advisory Opinion 177 Personal gift to an official by a member of a board of an association that is a lobbyist principal.
Advisory Opinion 176

Gifts given to official by lobbyist principal for distributing to foreign visitors.

Advisory Opinion 175
(May be reversed by Opinion 273.)
Acceptance of payment conference costs by an official from lobbyist or lobbyist principal.
Advisory Opinion 174 Lobbyist or lobbyist principal payment to an official for conference costs.
Advisory Opinion 173
.(Later reversed by Opinion 273.)
Gift to an official who is a member of a group.
Advisory Opinion 172 Donation from lobbyist principal to government body for dstribution to officials to attend a seminar.
Advisory Opinion 171 Revised Gift requested by lobbyist principal.
Advisory Opinion 170. Withdrawn by requester.
Advisory Opinion 169 Fee charged to attending officials.
Advisory Opinion 168 Payment of conference costs to official.
Advisory Opinion 167 Providing complimentary copies of publication to officials.
Advisory Opinion 166 Gift of complimentary tickets to an official.
Advisory Opinion 165 Plaque presented to an official.
Advisory Opinion 164 Official accompanying spouse on business trip paid by lobbyist principal.
Advisory Opinion 163 Payment of conference costs by lobbyist principal.
Advisory Opinion 162 Free admission for officials to event sponsored by lobbyist principal.
Advisory Opinion 161 Prizes donated by lobbyist or lobbyist principal to charity event hosted by official.
Advisory Opinion 160 Hospitality suite provided by lobbyist principal for officials.
Advisory Opinion 159 Contemporaneous payment by official to lobbyist principal for gift.
Advisory Opinion 158 Campaign Finance.
Advisory Opinion 157 Computer training offered by lobbyist principal.
Advisory Opinion 156 Periodical given to officials by lobbyist principal in connection with legislation.
Advisory Opinion 155 Payment of officials' expenses to attend forum held by lobbyist principal.
Advisory Opinion 154 Campaign Finance.
Advisory Opinion 153 Meals provided at legislative breakfast meeting sponsored by lobbyist principal.
PLEASE NOTE: Advisory Opinions dated before August 1, 1994, have lapsed.   The following selected opinions are offered for informational purposes only.
Advisory Opinion 152 Governor/Lt. Governor contribution limit.
Advisory Opinion 151 Volunteer activities.
Advisory Opinion 150 Report of Receipts and Expenditures.
Advisory Opinion 149 Change in office sought.
Advisory Opinion 148 Gift of refreshments from lobbyist principal to public official.
Advisory Opinion 147 Gift to Officials.
Advisory Opinion 146 Contribution Plan.
Advisory Opinion 145 Governor and Lt. Governor joint expenditures
Advisory Opinion 143 Gift of complimentary copies of newspapers to legislators.
Advisory Opinion 142 Vendors contributing to costs of meeting attended by officials.
Advisory Opinion 141 Gift of desk diary or pocket calendar from lobbyist principal.
Advisory Opinion 139 First-time candidate.
Advisory Opinion 138 Fundraising during legislative session.
Advisory Opinion 137 Ballot Question disclosure.
Advisory Opinion 136 Hennepin County Disclosure Law.
Advisory Opinion 129 Campaign Finance Disclosure.
Advisory Opinion 127 Campaign Finance Disclosure.
Advisory Opinion 119 Potential Conflict of Interest.
Advisory Opinion 114 Independent expenditures made by political fund.
Advisory Opinion 111 Lobbyist Disclosure.
Advisory Opinion 106 Lobbyist Compensation.
Advisory Opinion 101 Legal Defense Fund
Advisory Opinion 89 Campaign Finance Disclosure.
Advisory Opinion 86 Contribution Plan.
Advisory Opinion 73 A corportation may spend money to promote or defeat a ballot question.
Advisory Opinion 46 Tax Court judges not considered public officials.
Advisory Opinion 6 Corporate contribution plans.