Federal law prohibits congressional candidates who are state officials from transferring campaign money from their local accounts to their federal accounts. When a candidate receives a contribution to a federal account and reimburses the contributor from a separate state account, it is akin to a transfer, the Federal Election Commission has said in an advisory opinion.

Hollinger, a Baltimore County Democrat who is running in an eight-way primary for the 3rd Congressional District seat, denied directing campaign staff to offer money from her state account in exchange for a donation to her federal account - or making such offers herself.