All pages for conduit accounts on WinRed will include a paid for by WinRed disclaimer like the one below.
Why does WinRed include a disclaimer?
The WinRed disclaimer is necessary because WinRed is paying for the website (development, platform, hosting, etc.), and as a federal PAC, it’s required to include the disclaimer for the website platforms that it funds.
Conduited contributions flow through WinRed, Inc., which is a federal PAC, and subject to the FEC’s disclaimer requirements. While we agree that the disclaimer requirements aren’t always logical, the inclusion of the WinRed, Inc. disclaimer is required by federal law as it has been currently interpreted and is in keeping with the same practices that others in the space have adopted for well over a decade. Lastly, we give committees and candidates the option to also include their own disclaimers (see below), and we encourage them to seek counsel as to whether that is required or recommended.
The processing fees paid by the contribution recipients do cover the cost of hosting for the individual page on the website platform (which is important because otherwise, an in-kind contribution would result). But because WinRed is paying for the platform, and without the platform, there would be no individual page, the WinRed disclaimer is required on all pages.
Can I add another Disclaimer?
Whether or not you decide to include an additional disclaimer on the pages is up to and your legal counsel. WinRed does not require additional disclaimers nor prohibits them.
Why is there another candidate or committee’s disclaimer on the page I created?
Another candidate or committee’s disclaimer may appear on your webpage if you solicit contributions for that candidate or committee using slates. WinRed users can solicit contributions to other candidates or committees simply by choosing other WinRed participants to add to their webpages. Candidates and committees that receive funds from independent solicitations do not opt in to being included in such solicitations. Committees may contact support if they have concerns about content on pages they didn’t create.
Committees and candidates who participate in WinRed have the option to create a Global Disclaimer that will appear on any page where a donor is solicited for that candidate or committee. This is so that the disclaiming committee can ensure their disclaimer is visible even on pages they don’t control. If you create a page featuring a solicitation for another candidate or committee and they have a global disclaimer, it will appear at the bottom of the page. This disclaimer cannot be edited by you or anyone else except the candidate or committee that created it.
Conduited contributions flow through WinRed, Inc., which is a federal PAC, and subject to the FEC’s disclaimer requirements. While we agree that the disclaimer requirements aren’t always logical, the inclusion of the WinRed, Inc. disclaimer is required by federal law as it has been currently interpreted and is in keeping with the same practices that others in the space have adopted for well over a decade. Lastly, we give committees and candidates the option to also include their own disclaimers, and we encourage them to seek counsel as to whether that is required or recommended.
Questions?
If you have questions or are unsure on any of these steps, please reach out to our support team by clicking the red chat box at the bottom right corner of your screen.