Doug Burgum is about to drop hundreds of thousands of dollars on gift cards to qualify for the debate

Want free money? You’re in luck. GOP presidential candidate Doug Burgum has a gift card for you.

The North Dakota governor’s presidential campaign is offering $20 cards to donors who give his campaign as little as $1. It’s a bold and expensive fundraising tactic designed squarely to allow him to hit the donor threshold to qualify for the debate stage — while also raising a new set of legal questions.

The effort — billed in a fundraising text as an attempt to “help ease the burden of Bidenflation” — is a sign of just how unafraid Burgum is to dip into his personal wealth as he seeks the Republican Party’s nomination. It also reflects the difficulties of lesser-known candidates in reaching the Republican National Committee’s donor threshold to qualify for upcoming debates.

The Burgum campaign’s WinRed page indicated gift cards would be available for up to 50,000 donors — enough to make the August debate stage at a cost of $950,000 to the campaign if all donors only gave $1. A donor can only receive one gift card. His campaign said on Twitter that 50,000 people who donated would receive Visa or Mastercard gift cards at their mailing addresses. The scheme was first reported by FWIW, an email newsletter.

The total amount this may cost Burgum in his bid to reach 40,000 donors under the RNC's rules to make the debate stage, along with hitting certain polling requirements and taking a loyalty pledge to support the party’s nominee, might not matter to him, since he has an estimated net worth of more than $1 billion and can also self-finance his campaign.

Burgum's team, which hasn't yet disclosed how many donors he has, framed it as a bit of altruism rather than political opportunism.

“Doug knows people are hurting because of Bidenflation and giving Biden Economic Relief Gift Cards is a way to help 50,000 people until Doug is elected President to fix this crazy economy for everyone,” spokesperson Lance Trover said. “It also allows us to secure a spot on the debate stage while avoiding paying more advertising fees to social media platforms who have owners that are hostile to conservatives.”

The scheme also raises some legal questions, and several campaign finance lawyers who spoke with POLITICO had different perspectives on its legality. Paul S. Ryan, a longtime campaign finance and ethics lawyer, said the plan raised concerns that Burgum was effectively acting as a straw donor — a person who makes the contribution in the name of another, which is illegal.

“It sounds like this candidate is using these individuals as straw donors to make it look like he has a bunch of campaign donors when in fact, he’s coaxing these contributions by reimbursing donors out there money that really, at the end of the day, is the candidate’s money,” Ryan said.

Even though Burgum’s campaign finance report would be expected to include the gift cards as expenses, it would not be clear which donors were “legitimate” and which were reimbursed via a gift card, Ryan noted.

But Saurav Ghosh, director of federal campaign finance reform at the Campaign Legal Center, said that the reimbursed offered to donors differed from the typical straw donor context, where the donor is used to conceal the original source of funds.

“Campaigns generally have a tremendous amount of flexibility as far as how they spend their money,” Ghosh said.

Campaigns have long offered non-cash incentives, such as yard signs, books and other merchandise, in exchange for donations. The RNC's donor threshold has pushed lesser-known candidates to get creative with their fundraising pitches in order to land in front of a national audience alongside GOP frontrunners.

Michigan businessperson Perry Johnson, another longshot candidate whose campaign said he surpassed 10,000 donors last week, has been giving away T-shirts supportive of former Fox News personality Tucker Carlson.

For many, hitting the 40,000 threshold could be a steep climb: Former Arkansas Gov. Asa Hutchinson said last week that his campaign had 5,000 contributors so far.

Burgum’s campaign is not the only one pushing for fundraising innovation this cycle. Biotech entrepreneur Vivek Ramaswamy, who said he has already met the RNC’s threshold for the first debate, announced a new fundraising program this week that would give supporters a share of the total donations they raise.