Guidelines for Hosting Political Candidates or Elected Officials
As a tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code, the University is absolutely prohibited from participating or intervening, directly or indirectly, in any political campaign on behalf of or in opposition to any candidate for public office at any level (federal, state, or local). Violation of this prohibition could lead to excise taxes or even jeopardize the University’s tax-exempt status.
Whether any particular activity constitutes impermissible participation or intervention in a political campaign depends on all of the facts and circumstances of the situation. However, hosting political candidates and elected officials on campus will always raise issues that must be addressed appropriately and consistently to ensure that improper participation or intervention by the University in a political campaign is avoided.
The following guidelines have been developed to manage appearances on the Notre Dame campus by all individuals seeking political office or who are elected officials at any level (federal, state, or local). The guidelines are based on Internal Revenue Service guidelines for tax-exempt organizations, University historical precedent, academic freedom, and the University’s open speaker policy.
In order to be allowed to speak on campus, an elected official, political candidate, or any surrogate who wishes to speak on their behalf must be either an invited guest of the University President or invited under the sponsorship of an officially recognized University organization or unit.
In either case, the following requirements apply:
- There may be no fundraising of any kind by political candidates, elected officials, political campaigns, political parties, or other political organizations in association with a University event, or on campus in or outside of an election cycle. This prohibition also applies to fundraising by student organizations recognized by the University.
- In accord with IRS regulations that prohibit the endorsement or the appearance of an endorsement of a political candidate by a tax-exempt organization, traditional political rallies are prohibited. Rather, any events involving an elected official, political candidate, or a surrogate should be educational in nature.
- The elected official, political candidate, or surrogate will be introduced by a University representative (which may include student leaders of clubs and organizations), and the introduction and all communication concerning the political guest’s appearance cannot include comments on their qualifications and must explicitly state that the University neither supports nor opposes the candidate.
- No banners, placards, or other signage typically found at a political rally are allowed in or around the venue where the elected official, political candidate, or surrogate is being hosted.
- Only invited elected officials, political candidates, and surrogates may speak. Surrogates must be approved as participants in advance. No political leaders, endorsers, or elected officials other than the invitee may participate.
- Other politicians or celebrities who support candidates may attend and receive special seating, and be introduced, but they may not speak on behalf of a candidate.
- If a candidate is invited to speak on campus, the University must provide equal opportunity to all candidates for that particular office to speak on campus in accord and consistent with University policies. The same parameters and provisions must apply for all such candidates.
It has been the tradition of Notre Dame Presidents since 1952 to invite the nominees for the presidency of the United States to speak on campus during the fall general election campaign. An invitation to leading candidates for the presidency also is appropriate during the Indiana primary, when the primary plays a significant role in the presidential nomination process. The following requirements govern invitations to presidential candidates to appear on campus:
- An invitation from the University President will be to the candidate/nominee but not to surrogates.
- Should the candidate/nominee accept, it is expected that he or she will deliver a substantive address on one of the important issues of the campaign.
- Candidates/nominees may not deliver a stump speech, or engage in a political rally.
- The candidate/nominee will be hosted on campus and introduced by the President of the University, absent an unavoidable scheduling conflict. In lieu of the President, a University official designated by the President will host and introduce.
- The above policies related to fundraising, neutrality, signage, attendance by other political figures and celebrities, and equal opportunity to all candidates apply in full to presidential campaigns.
- Each invited candidate/nominee should speak at events and venues of a similar nature in order to meet the requirement that an equal opportunity has been extended by the University to each candidate.
Should a political campaign seek to send a surrogate to campus to speak on behalf of a candidate, that appearance must be sponsored by an officially recognized University organization or unit.
The University will accommodate all reasonable requests, but it will be the responsibility of the sponsoring organization or unit to make all arrangements related to the event.
A sponsoring University academic unit or officially recognized organization is expected to comply with the above policies related to fundraising, neutrality, signage, attendance by other political figures and celebrities, and equal opportunity to all candidates.
It is University protocol for the Office of the President to extend an invitation to presidential candidates or nominees. For other political candidates or surrogates, sponsoring University units or organizations must communicate their intent to extend an invitation to the Office of the President and University Communications. The plans for the event shall be subject to review by the University’s Office of General Counsel and Tax Department for compliance with IRS requirements, and by University Communications for duplication of invitations and/or scheduling conflicts. Such notice also alerts the administration to the potential need for external communication and media inquiry that may ensue.
All media outreach for presidential invitees should be directed through University Communications, which will manage and direct all press credentials and on-site coverage. Similarly, University units and organizations sponsoring surrogate events must alert University Communications, which will respond on behalf of the University to all inquiries.