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2000ELC-01

TO:                          Susan J. Kyte, Esq.

You have requested an advisory opinion on the following issues:

Can a national professional association, which is incorporated, but not sited in Ohio, accept on behalf of its Ohio affiliated association, a single check from a member constituting multiple payments to the Federal and State associations, which check combines association dues payments with contributions to their related Political Action Committees (PACs)?

If so, can the national professional association then make a single disbursement to the Ohio association by subsequently disbursing funds for multiple Ohio state members in one negotiable instrument, again for multiple purposes (dues and PAC contributions)?

Please define the term "members" as used in Ohio Revised Code §3599.03(A)?

SYLLABUS:        A national professional association, which is incorporated, but not sited in Ohio, may accept from a member on behalf of its Ohio affiliated association, a single check constituting multiple payments to the Federal and State associations, which check combines association dues payments with contributions to their related Political Action Committees (PACs). Further, the national professional association may then make a single disbursement to the Trustee of the Ohio association by subsequently disbursing funds for multiple Ohio state members in one negotiable instrument, again for multiple purposes (dues and PAC contributions). All of this will be in compliance with R.C. §3599.031 and Ohio Administrative Code §111-5-19. Finally, the term "members" as used in R.C. §3599.03 is intended to refer to persons affiliated with a labor union and has no corresponding use that can be attributed to anyone affiliated with a corporation for the purposes of R.C. §3599.03.