The Iowa Farm Bureau is the second largest company/entity contributor to Iowa Republican candidates. They have brought in over $2 million and given $730,000 to currently active, registered republican candidates. Contributions to the Farm Bureau are 78.2% from company/entities. That number includes $380,000 in unitemized contributions, which are contributions that legally must be less than $25, and several contributions from county-level farm bureaus. The Iowa Farm Bureau also received 7.8% in individual contributions more than $200 and 14% in individual contributions less than $200.

The Shell Game

Right off the bat, what struck me as interesting while looking into the Iowa Farm Bureau is that their biggest company/entity contributor (after unitemized contributions) is themselves, at least on paper. They reported two large contributions from themselves to themselves -- one for $100,000 on 9/20/2018 and another for $35,000 on 10/17/2018. I looked into these contributions and found the investigative journey as interesting as the contributions themselves.

Where did the money go?

Based on 10/17/2018 Iowa Ethics and Campaign Disclosure Board (IECDB) filings by the Iowa Farm Bureau, at least some of that $100,000 must have been given as campaign contributions to the campaigns of Governor Kim Reynolds and Secretary of Agriculuture, Mike Naig. A contribution of $50,000 was made to Governor Reynolds's campaign one day before the $100,000 receipt, and a contribution of $50,000 was made to Mike Naig the day of the $100,000 receipt. Based on the Farm Bureau's reported cash-on-hand at the end of the reporting period and their reported contributions and expenditures, the Farm Bureau would not have had sufficient funds in their account to make contributions to Reynolds or Naig without the $100,000 receipt. No other candidate received funds from the Farm Bureau between the date of the contribution and the end of the reporting period.

The $35,000 contribution is harder to trace. While the Farm Bureau's 1/18/2019 IECDB filings indicate no expenditures other than political contributions to candidates, the Farm Bureau gave to several candidates over the reporting period, and it's impossible to tell who specifically received a piece of that specific $35,000. Their Schedule B expenditure report lists all candidates who received funds from the Farm Bureau during this reporting period.

Where Did the Money Come From?

When I asked the IECDB about the contributions, I learned that the Iowa Farm Bureau has a federal, corporate-connected PAC registered with the Federal Election Commission (FEC) and a state-level PAC registered with the IECDB. The state level PAC is affiliated with that federal-level corporate-connected PAC. The $100,000 and $35,000 contributions were transfers from the federal PAC to the state PAC. Because the IECDB does not have the federal PAC listed in the state system, these contributions were coded as from the state PAC to itself, and a note was made clarifying that it was a transfer from the federal PAC. I reached out to the FEC about contribution limits, and they explained that contribution limits for federal PACs do not apply to contributions to state-level candidates and PACs that do not contribute to federal candidates. There are no contribution limits for PAC-to-PAC contributions or PAC-to-candidate committee contributions in Iowa. The shuffling of money between federal and state level committees, while interesting, is legal to do. I looked into contributors to the federal PAC and found that contributions were predominately from unitemized contributors and individual donors giving $250-$1,000.

Aren't Corporate Contributions Illegal?

Well, yes and no. PACs can take money from corporations, but they can only spend that money on the administration of their PAC. The Iowa Farm Bureau made 4 such $250 in-kind contributions to its state-level PAC in 2018. The federal corporate-connected PAC is not considered a corporation and has similar restrictions on taking money from the parent corporation.

County Farm Bureaus

Most of the remainder of funds to the Iowa Farm Bureau state-level PAC come from county-level Farm Bureaus. If you visit, for example, the Polk County Farm Bureau website, you will be met with the Farm Bureau logo and slogan and the text "We are one of 100 county Farm Bureaus that are an extension of the Iowa Farm Bureau Federation, a grassroots organization" as well as a chance to win a scholarship from the Iowa Farm Bureau. But these county-level farm bureaus are registered with the Iowa Secretary of State as separate companies from the Iowa Farm Bureau (The Polk County Farm Bureau is even registered to the same agent as the Iowa Farm Bureau). Unlike corporations, companies are allowed to contribute to PACs and candidates in Iowa, and there are no contribution limits.