Are you tracking in-kind contributions to political candidates as well as cash?
Political contributions by employees are becoming an area of focus for compliance executives in real estate investment management. But are you tracking in-kind donations, such as volunteering time or even allowing fundraisers at private homes?
The big picture. The NAREIM Legal and Compliance meeting last week discussed best practices surrounding political contributions. At state and local levels, contributions were typically banned, with the majority of cash contributions to federal, state and local candidates and PACs requiring pre-clearance by compliance teams and executives.
However, in-kind contributions, and how to handle potential conflicts, were also raised, not least how firms monitor the volunteering of time or providing a personal residence for fundraising events.
Tools that can help ease the burden. While members agreed in-kind contributions are being dealt with on a case-by-case basis, they did discuss resources that help track and monitor political contributions among employees and their partners, including:
Opensecrets.org. Created by the non-profit Center for Responsive Politics, this website tracks campaign, lobbying and PAC contributions. The largest real estate PAC contributions for the 2020 cycle can be found here.
Followthemoney.org. Created by the non-profit National Institute on Money in Politics, the website compiles campaign and lobbying donations from government disclosure agencies.
CompliSci. Compliance software which also provides political contribution verification services.
Include internal policies and practices, such as:
Create a conflicts of interest committee. Not just related to political contributions, but a committee dedicated to resolving corporate and fund conflicts, such as affiliated party transactions, end of life issues for assets and funds, principal trades and runs a conflicts of interest register
Designate a corporate ethics officer
Ensure the CEO and executive management set the compliance tone, with regular, visible support for compliance training.