As Republicans and Democrats search for campaign money in this presidential election year, banks are tip-toeing through a mine field of rules on contributions.
In many ways, banks are no different from other companies with respect to political contributions. Federal law says banks can't draw from their own coffers for contribution money, use company time and facilities to organize campaign events, or force their employees to support a politician.
Banks can't even offer a political hopeful loan terms more favorable than those available to another person in the same financial situation.
The penalty for even a tiny slip: huge fines, criminal prosecution, and a damaged reputation.
Most bankers said these rules haven't caused major compliance headaches. But with political fund-raising drives hitting high gear as a summer of national conventions approaches, compliance officers said bankers need to be cautious.
"We handle it like we do other outside activities," said Kate Barr, vice president and compliance officer at Riverside Bank, Minneapolis. "We tell (employees) not to mix business with personal things.
"It's the same as if we're being asked to give to something like the March of Dimes Walk-a-Thon. We have to make sure not to put pressure on employees to contribute."
They must also be careful not to give candidates breaks on loan terms. Politicians often spend thousands or even millions of their own dollars to finance their runs, but some need loans from banks to boost their campaign's bottom line.
Loans to the candidate must be given at the normal interest rate for any borrower in similar financial circumstances, with all terms disclosed in a written agreement. It also must have a reasonable repayment period, and should be secured to ensure that the bank is not making a contribution in disguise.
The Federal Election Commission toughened the rules after former Sen. John Glenn of Ohio failed to repay more than half of the $2 million borrowed from four Ohio banks in his unsuccessful 1984 campaign for the Democratic nomination.
"It has to be just like lending to any sort of borrower," said Tige Savage, a spokesman for Washington-based Riggs National Bank. "You've got to know the possible ramifications of what you do."
The rules also apply to checking accounts and other products. Candidates must receive the same terms as any other customer, according to Kenneth A. Gross, a partner at the Washington law firm of Skadden, Arps, Slate, Meagher & Flom. For example, a candidate only can get overdraft protection if the bank offers the service to everyone.
The consequences of noncompliance can be severe, Mr. Gross said. An illegal loan or contribution can cost $100,000 or more in fines. Banks also could face criminal charges, he said, since the election commission can refer cases to the Department of Justice for further investigation.
But lending isn't the most common way for bankers to get involved in political races. Most of banks' influence comes from political action committees, or PACs - a collection of money donated by people to support candidates for office.
The fund allows banks to publicly support candidates without dipping into the corporate coffers. There are no laws limiting the size of political action committees, but distribution of the money is another story.
For example, a bank can contribute up to $5,000 from its fund to a candidate for the Senate or House of Representatives for a primary, and another $5,000 for the general election. If a runoff is needed - some states call for them if, for example, a winning candidate doesn't draw more than 50% of the vote - another $5,000 may be given.
"It's very simple," said Pete Blocklin, senior legislative representative with the American Bankers Association. "All you have to know is $5,000, $5,000, $5,000."
Also, people cannot contribute more than $5,000 to a political action committee in a calendar year, though spouses may also contribute $5,000.
Citicorp spokesman Jack Morris said his company "takes great pains to be scrupulous" about contributions. For example, Citi routes all PAC contributions through a single administrator. Using more would reduce confidentiality and increase the likelihood of employee's being coerced to contribute or reprimanded if they don't, Mr. Morris said.
Citicorp has a committee responsible for disbursing the funds, as does Banc One Corp. Those two are among the top five biggest bank PACs. The Banc One committee donated $508,975 to candidates in 1995; the Citicorp committee, $209,993, according to the election commission.
Annie Hall, chairman of Banc One's political action committee, said her bank's amount is high because contributions to its 12 state funds are included in the national total. She said less than half of the reported amount supports federal candidates.
Contributions to any political action committee must be reported to the government either monthly or quarterly in an election year. In nonelection years, banks can report semiannually. The contributors' names, addresses, employers, and occupations must be disclosed, as must the dates of donations and amounts given.
With every contribution, Banc One employees must fill out forms that include a disclaimer saying they were not coerced.
"I bet we say a zillion times that it will not benefit or hinder you in your job if you do this," said Ms. Hall.
Fleet Financial Group drives that point home as well. In its companywide code of ethics, the Boston-based bank also states its employees cannot be reimbursed for campaign donations. If employees find out about any wrongdoing in the bank, the handbook instructs them to tell the president and chief auditor of their bank immediately.
The rules are couched with a disclaimer, saying they aren't intended to discourage "active personal involvement in the political process."
Of course, employees can contribute outside of the bank's political action committee. Federal law limits those donations to $1,000 per candidate per election.