EAO 163

An incorporated trade association may finance costs directly connected with a fundraiser held for the benefit of a general-purpose committee it assists under Election Code section 253.100(a), including the cost of meals and invitations, for stockholders, members, employees, or the families of stockholders, members, or employees of the corporation. Any costs associated with the fundraiser attributable to individuals who are not stockholders, members, or employees, or families of stockholders, members, or employees of the corporation may not be paid from the funds of the corporation. Such costs shall be calculated as the actual cost of an individual’s attendance at the event, or if actual cost is not reasonably determinable, then the cost shall be calculated as a pro rata share of the total cost of the event. Members of a trade association that has no stockholders are treated as stockholders for purposes of the solicitation restrictions. If the members of such a trade association are themselves incorporated entities, the association may also finance the solicitation of contributions to the general-purpose committee from the stockholders, employees, and the families of stockholders and employees of its incorporated members.