What is the Campaign Finance Board?
The Campaign Finance Board (CFB) is a nonpartisan city agency that provides oversight of candidates and independent spenders involved in New York City campaigns. Under the Campaign Finance Act (the Act), all candidates running for mayor, public advocate, comptroller, borough president, or City Council must register with the CFB and disclose and document the funds they raise and spend. The CFB also audits campaigns to ensure that they have complied with the Act and CFB Rules.
What is the purpose of this guide?
As part of the disclosure and audit process, all campaigns are required to provide comprehensive documentation of their expenditures. This is particularly true for campaigns that participate in the CFB matching funds program. In order to ensure that public money is spent in accordance with the law, the CFB requires detailed contemporaneous documentation. Campaigns that fail to provide compliant documentation may receive less funding or be required to return a portion of any public funds received. The CFB created this guide to demonstrate best practices and help consultants and vendors understand and prepare for the types of documentation that campaigns will request.
What are the CFB’s documentation requirements?
The following sections of this guide provide details on the specific types of documentation that campaigns will request from consultants and vendors. Additional documentation from consultants and vendors may be required by the CFB during the post-election audit if records are non-contemporaneous.
Additional Special Documentation Requirements
- Subcontractor disclosure: If a consultant or vendor pays an individual subcontractor more than $5,000 during a campaign, the name and address of the subcontractor, a description of the goods or services provided by the subcontractor, and the total cost of the subcontracted services must be disclosed. The best way to provide this information is by completing a Subcontractor Disclosure Form.
- Goods or services provided to more than one campaign: If a consultant or vendor is paid by two or more campaigns for shared campaign materials or activities, this is considered a joint expenditure. The CFB recommends that consultants and vendors directly bill each campaign for its equal or proportionate share. Invoices should display the total cost of the goods or services and itemize each campaign’s amount payable. If the vendor does not include the total cost on the invoice, the campaign must request additional confirmation of the full cost from the vendor, so that the proportional share can be verified.
- Outstanding liabilities: Consultants and vendors can provide collection notices, follow-up letters, or other documentation to show that an outstanding balance has not been paid or forgiven. Any outstanding liabilities will be considered an in-kind contribution to a campaign if left unpaid past 90 days of the bill’s due date, unless the campaign can properly document that the vendor is continuing to seek payment. These in-kind contributions are subject to contribution limits and prohibitions. Campaigns are prohibited from accepting contributions from political committees not registered with the CFB, corporations, LLCs, and partnerships.
NOTE: Discounts
Any discount not provided in the regular course of business to the general public is considered an in-kind contribution from the vendor to the campaign and is subject to contribution limits and prohibitions. Campaigns are prohibited from accepting such contributions from political committees not registered with the CFB, corporations, LLCs, and partnerships.
Please Note: The Consultant and Vendor Guide supplements – but does not replace—the Campaign Finance Handbook (Handbook), any provision of the Campaign Finance Act, or any CFB Rule. The samples and templates provided here are designed to fulfill minimum CFB documentation requirements and are not meant to supplement or replace tax or legal advice.