The FEC regulation addresses the distinction here: “However, this exception does not cover payments made to maintain unlimited access to such a facility, even if access if (sic) maintained to facilitate fundraising activity. The exception is limited to payments for the costs of a specific fundraising event.”
Cassidy has been paying dues at the exclusive Penn Club — located in midtown Manhattan and established for alumni and affiliates of the Philadelphia-based Ivy League school, which Cassidy did not attend but his son did — since 2014.
In total, Bill Cassidy for US Senate has spent more than $12,400 at the club since 2013. In addition to dues, the costs were described as going for food, drink, fundraising events and hotel accommodations.
Erin Chlopak, campaign finance strategy director at the Campaign Legal Center who previously served as an FEC attorney, said if a campaign were to use funds for membership dues to a social club, it would not be permissible.
“Using campaign money for a social club membership, regardless of the amount, would be personal use and not legal,” Chlopak said.
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