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To:    James Aeppli, Treasurer
         Committee to Retain Rick Stauffer

You have requested an advisory opinion on a question concerning Ohio campaign finance law. The question posed to the Commission is as follows:

Is it proper for a candidate or a candidate's campaign committee to produce a political publication, as defined in Ohio Revised Code §3517.20(A)(1)(a) that includes some form of mutual advertising for the benefit of a local business along with the candidate's or campaign committee's pertinent political information?

SYLLABUS: The provisions of R.C. §3599.03 prohibit the participation of a corporation established under R.C. §1701 & §1702, in this mutual advertisement scheme as such participation would be considered a direct contribution to a candidate's campaign committee. Further,  the Commission holds that other entities that can make lawful contributions under Ohio's campaign finance laws can participate in this mutual advertisement scheme, but that any such participation will be considered a contribution, either direct or in-kind, to the candidate's campaign committee and must be reflected on the appropriate campaign finance report to be filed by the campaign committee.