Like any federally-chartered bank, PNC Bank is prohibited by law from making contributions to candidates and political parties in all federal and many state elections. Our policies reflect this prohibition. Even where permitted by law, PNC does not contribute corporate funds for election campaigns, nor do we make any political contributions to candidates, candidate campaign committees, political parties or committees, independent expenditure committees or Super PACs.
Consistent with campaign finance laws, PNC sponsors Political Action Committees (PACs), supported entirely by voluntary employee contributions, which contribute at the federal, state and local levels. Bipartisan contributions support candidates, parties or committees whose views align with PNC’s priorities. In 2019, federal candidate and federal PAC contributions made through PNC’s PACs totaled $416,000. As required by law, contributions made by the PNC PACs are reported in filings with the Federal Election Commission, as well as the relevant state or local commissions, which are publicly available.
PNC belongs to national trade associations, state banking associations and local chambers of commerce that represent the interests of both the financial services industry and the broader business community. These organizations work to represent the industry and advocate on major public policy issues of importance to PNC and the communities we serve.
While PNC employees have the right to voluntarily participate in the political process, there are legal restrictions on personal political activities. These restrictions, which are the result of some of PNC’s businesses, may limit or prohibit personal political contributions, solicitation of political contributions or sponsorship of political events. To help comply with these legal restrictions, PNC provides all employees with information to determine whether they are required to pre-clear their personal or immediate family’s political activities with the Corporate Ethics Office. PNC does not provide reimbursement or compensation to anyone for personal political contributions under any circumstances.
made by the PNC PACs in 2019
Statement of Political Activity
PNC’s business is subject to extensive laws and regulations at the federal, state and local levels, and changes to such laws can significantly affect PNC and our employees, shareholders, communities and customers. We believe that active engagement in the political and public policy process to advance and protect our interests is an important part of responsible corporate citizenship.
Lobbying and Trade Associations
We disclose publicly all U.S. federal lobbying costs – those paid directly as well as through trade associations – and the issues to which our lobbying efforts relate, on a quarterly basis, pursuant to reports required by the Lobbying Disclosure Act. These disclosures can be viewed at https://lobbyingdisclosure.house.gov. We also disclose state and local lobbying costs where required by applicable law.
We belong to national trade associations, state banking associations, and local chambers of commerce that represent the interests of both the financial services industry and the broader business community. These organizations work to represent the industry and advocate on major public policy issues of importance to PNC and the communities we serve. PNC’s participation comes with the understanding that we do not control these organizations and may not always agree with all the positions of an organization or its other members. A list of principal national trade associations to which we belong and total dues paid to those associations in 2019 if they exceed $25,000 is available below.
On a limited basis, PNC may consider requests from organizations seeking support for ballot referendum committees and certain limited Section 527 political organizations, such as the Republican and Democratic Governors Associations. Note that referendum committees do not influence candidate elections but rather the passage of laws. The practice for support of ballot or levy issues is especially prevalent in Ohio and Michigan in our footprint. The renewal of a local school district operating levy, a levy benefitting a local park, or a levy benefitting a regional transit system are examples of these issues. PNC reviews these requests with input from Government Affairs, senior management, including our regional presidents, and our Corporate Ethics Office to determine if PNC should support the issue and whether it is legally permitted under applicable law. If we determine that a request is something that we will support and a corporate contribution to the issue is permissible under applicable law, PNC will make the contribution and comply with any law that requires PNC to disclose it. Please note that these contributions are required to be disclosed by the organization that receives them. Annually, PNC will also voluntarily disclose the use of company funds in support of ballot or levy issues or organizations formed under Section 527 of the Internal Revenue Code. For 2019, PNC used corporate funds in support of such organizations, as listed below.
Additionally, PNC may occasionally make contributions to groups organized under Section 501(c)(4) of the Internal Revenue Code as a social welfare organization, but does not do so to support the election of any specific candidate or for the purpose of funding specific expenditures or communications.
2019 Other Contributions
|Organization Type||Organization Name||Amount|
|Ballot Referendum Committee||Franklin County Children’s Services Levy
(Committee 4 Children)
|Political Organizations||Republican Governors Association
Democtratic Governors Association
Compliance and Oversight
All corporate political activities conducted by or on behalf of PNC are managed by our Government Affairs department, which reports to the General Counsel of PNC. Requests for contributions are evaluated and approved by Steering Committees composed of PNC officers. Prior to approval by a Steering Committee, contributions are also reviewed by the Corporate Ethics Office for compliance with applicable laws.
The Audit Committee of the Board of Directors reviews on an annual basis this Statement of Political Activity, major lobbying priorities, expenditures made in support of ballot or levy issues and other organizations formed under Section 527 of the Internal Revenue Code and the activities of and total dues paid to our principal national trade associations if they exceed $25,000. The non-management members of our Board of Directors reviews the contributions of our political action committees.
PNC belongs to national trade associations that represent the interests of both the financial services industry and the broader business community. These organizations work to represent the industry and advocate on major public policy issues of importance to PNC and the communities we serve. Below is a list of our principal national trade associations and total dues paid to these associations in 2019 if they exceeded $25,000:
|Association||Dues (in thousands)|
|Bank Policy Institute
|U.S. Chamber of Commerce||$350|
|American Bankers Association||$245|
|Mortgage Bankers Association||$176|
|Consumer Bankers Association||$173|