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ELC88-2

TO:    James M. Ruvolo, Chairman, Ohio Democratic Party:

You have requested an opinion on the following question:

Are contributions to a federal nonconnected political committee, with which the holder of a public office is associated, considered contributions to the officeholder or his campaign committee under divisions (I) and (J) of Ohio Revised Code section 3517.13?

SYLLABUS : For purposes of divisions (I) and (J) of Ohio Revised Code section 3517.13, contributions to a federal nonconnected political committee would also be considered contributions to the holder of a public office when the officeholder is closely identified with the committee, exercises decision-making influence within the committee, and derives a substantial benefit from contributions received by the committee.