FEC Record January 2016Ellen L. Weintraub Staff Director: Alec Palmer Acting General Counsel: Daniel A. Petalas The FEC Record is produced by the Information Division, Office of Communications

FEC Record JanuaryFebruary 2016

Contents

1 Commission

5 Litigation

13 Advisory Opinions

17 Public Funding

18 Compliance

18 Outreach

23 Reporting

Federal Election Commission 999 E Street NW Washington DC 20463

Commissioners Matthew S Petersen Chairman

Steven T Walther Vice Chairman

Lee E Goodman Caroline C Hunter Ann M Ravel

Ellen L Weintraub Staff Director Alec Palmer

Acting General Counsel Daniel A Petalas

The FEC Record is produced by the Information Division Office of Communications

Toll free 800-424-9530 Local 202-694-1100 Email infofecgov

Greg Scott Asst Staff Director George Smaragdis Deputy

Asst Staff Director Publications

Alex Knott Senior Writer

Commission

Statement of Chairman Matthew Petersen and Vice Chairman Steven Walther With the 2016 presidential election cycle well underway the Commission anticipates one of its busiest years in recent memory This election season will present many challenges but it will also offer many opportunities As Chairman and Vice Chairman we look forward to work-ing with our fellow Commissioners to make this as pro-ductive a year as possible Being an election year we expect that the number of complaints filed with the Commission will likely surge as will the vol-ume of advisory opinion re-quests We stand ready to act quickly on these items to ensure greater clarity regard-ing the scope and meaning of the Federal Election Campaign Act and Commission regulations and to provide timely resolution and closure for those involved in the enforcement process Much has been written about disagreements on the Commission While we do not deny the existence of vig-orous debates among Commissioners they need not limit the Commissionrsquos ability to identify and move for-ward on issues and initiatives that improve compliance with the law provide helpful information to the public and enhance Commission operations To that end we are committed to finding common ground and to com-promise where necessary to make tangible progress on constructive proposals For instance we plan to build on the efforts of past-Chairs Goodman and Ravel to improve the design and functioning of the Commissionrsquos website in order to pro-vide the most useful and user-friendly website possible

for practitioners the regulated community and the public alike Earlier this month the Commission released a new customizable download feature that allows users to quickly export summary level data in a readily understandable format Soon users will similarly be able to download transaction-level data regarding contributions and disbursements and new website features will be unveiled such as (i) an improved Commission calendar featuring filters subscriptions and automatic updates and (ii) improved access to Com-mission legal documents including regulations advisory opinions and enforcement and compliance matters Furthermore the FEC continues to expand its outreach programs to provide practitio-ners and the public with valuable compliance tips and up-to-date information regarding recent developments in campaign finance law The Commission will offer a series of day-long webinars for candidates parties and PACs along with workshops and regional con-ferences on election-year reporting requirements and other timely topics These pro-grams constitute a core component of the Commissionrsquos obligation to promote voluntary compliance Finally we would like to thank the employees here at the Commission for their hard work and dedication It is our hope that as a result of the efforts of Commissioners and staff 2016 will be an effective and rewarding year (Posted 02112016 By Chairman Matthew Petersen and Vice Chairman Steven Walther) Resources Meetings and Hearings Campaign Finance Disclosure Portal

Commission Elects Officers for 2016 At its open meeting of December 17 2015 the Federal Election Commission elected Mat-thew S Petersen as Chairman and Steven T Walther as Vice Chairman for 2016 Mr Pe-tersen has served once before as Chairman and twice as Vice Chairman Mr Walther too has previously served in both positions From 2005 until his appointment to the Commission in 2008 Mr Petersen served as Re-publican chief counsel to the US Senate Committee on Rules and Administration providing counsel on issues relating to fed-eral campaign finance and election admini-stration laws as well as the Standing Rules of the Senate Prior to that position Mr Petersen served as counsel to the US House of Represen-tatives Committee on House Administra-tion Mr Petersen was extensively involved in the crafting of the Help America Vote Act of 2002 (HAVA) and the House-Senate ne-gotiations that culminated in HAVAs pas-sage From 1999 to 2002 Mr Petersen specialized in election and campaign finance law at the law firm of Wiley Rein LLP in Washington DC Mr Petersen received his JD in 1999 from the University of Virginia School of Law where he was a member of the Virginia Law Review He graduated magna cum laude with a BA in philosophy from Brigham Young University in 1996 He also received an AS with high honors from Utah Valley University

Commission Recommends Legislative Changes On December 16 2015 the Commission unanimously approved seven recommenda-tions for changes to current campaign finance law Some of the recommendations re-late to the lawrsquos registration and reporting requirements including expansion of elec-tronic filing requirements while others seek Congressional authority needed in order to better fulfill the agencys mission Electronic Filing of Senate Reports The Commission recommends that Congress require electronic filing by senatorial com-mittees that have or expect to have financial activity in excess of an established threshold (currently $50000 per calendar year) Senate filers are the only political committees not required to file disclosure reports electronically once they reach this threshold The Commission recommendation notes that reports filed electronically are normally available to the public within minutes while Senate paper filings (which often comprise thousands of pages) can take up to 30 days to be integrated into the Com-missionrsquos searchable databases The Commission estimates at least $681000 per year in costs directly attributable to current Senate filing procedures would be saved by re-quiring electronic filing Electronic Filing of Electioneering Communication Reports The Commission recommends Congress require reports of electioneering communica-tions be filed electronically with the Commission rather than on paper Many independ-ent expenditure reports are already subject to mandatory electronic filing However

Mr Petersen received his JD in 1999 from the University of Virginia School of Law where he was a member of the Virginia Law Review He graduated magna cum laude with a BA in philosophy from Brigham Young University in 1996 He also received an AS with high honors from Utah Valley University Before joining the FEC as a Commissioner in 2006 Mr Walther practiced law in the Reno Nevada law firm he co-founded Walther Key Maupin Oats Cox amp LeGoy now known as Maupin Cox amp LeGoy Mr Walther is a co-founder and past chair of the American Bar Association (ABA) Cen-ter for Human Rights and currently serves as the Special Advisor He is a former presi-dent of the State Bar of Nevada the Western States Bar Conference and the National Caucus of State Bar Associations He has served as past chair of the 6000-member Fellows of the American Bar Foundation the legal research arm of the ABA From 1971 until his FEC appointment Mr Walther served as a member of the Nevada State Advi-sory Committee to the US Commission on Civil Rights Mr Walther has lectured extensively both domestically and internationally on rule of law human rights and international law issues and has served as an official election observer in several countries He served on the Board of the ABA Rule of Law Initiative (ROLI) which oversees the ABArsquos democracy-building programs in over 50 countries Mr Walther received his JD from Boalt Hall School of Law University of California Berkeley He received his undergraduate degree with a major in Russian from the Uni-versity of Notre Dame Notre Dame Indiana (Posted 12282015)

because political committees do not file electioneering communication reports and because funds spent on electioneering communications are considered ldquodisbursementsrdquo and not ldquoexpendituresrdquo the mandatory electronic filing provisions generally do not ap-ply to electioneering communication reports The Commission suggests only entities that report more than $50000 of electioneering communications should be subject to mandatory electronic filing Authority to Create Senior Executive Service Positions The Commission recommends Congress allow the FEC to create Senior Executive Ser-vice (SES) positions within the agency Currently the agency has several senior man-agement positions that the Commission believes would satisfy the criteria for SES posi-tions codified at 5 USC sect3132 but the agency is prohibited by law from creating SES positions The recommendation states these changes are needed to bring the Commis-sionrsquos personnel structure in line with that of other comparable federal agencies and to ensure the Commission is better able to compete in recruiting and retaining key man-agement employees The recommendation estimates the Commissions expenses would not increase significantly if allowed to participate in the SES program Fraudulent Misrepresentation of Campaign Authority The Commission recommends Congress revise the existing prohibitions on fraudulent misrepresentation of campaign authority to include all persons claiming to act on behalf of candidates and real or fictitious political committees Currently the statute does not prohibit fraudulent misrepresentation or solicitation on behalf of for example a sepa-rate segregated fund or a non-connected political committee The Commission recom-mendation states that the fraudulent misrepresentation prohibition should extend to any person who would disrupt a campaign by unlawful means rather than being limited to candidates and their agents and employees The Commission also recommends Con-gress remove the current requirement that the fraudulent misrepresentation must per-tain to a matter that is ldquodamagingrdquo to another candidate or political party as proving damages is often difficult and impedes the Commissions ability to pursue persons who employ fraud and deceit Make Permanent the Administrative Fine Program for Reporting Violations The Commission recommends Congress make permanent the agencyrsquos authority to as-sess administrative fines for violations of the law requiring timely filing of disclosure re-ports The Administrative Fine Program was first implemented in 2000 In December of 2013 President Obama signed legislation extending the program until the end of 2018 From its inception through the end of fiscal year 2015 the Commission has processed and made public 2857 cases and assessed more than $53 million in fines The Com-mission feels the Administrative Fine Program has been very successful and cost-effective resulting in a decrease in the number of late and non-filed reports Increase and Index for Inflation Registration and Reporting Thresholds The Commission recommends Congress increase and index for inflation certain registra-tion and reporting thresholds contained in the Federal Election Campaign Act (the Act) Most of the contribution limits and registration and reporting thresholds were set in the 1970s and decades of inflation has effective reduced FECAs contribution limits in real dollars The Bipartisan Campaign Reform Act of 2002 increased most of the Actrsquos contri-bution limits to adjust for some of the effects of inflation but that Act did not cover cer-tain registration and reporting thresholds which have remained static The Commission asks Congress to index for inflation the $1000 per calendar year registration threshold for political committees at 52 USC sect 30101(4)(A) and the $250 per year threshold for

reporting independent expenditures The Commission suggests these increased thresholds will ease the compliance burdens on smaller organizations (especially local party committees) and exempt some smaller organizations that engage in only minimal spending from the Actrsquos registration and reporting requirements The Commission requests both thresholds be increased to an amount determined by Congress and indexed for inflation Authority to Accept Gifts The Commission recommends Congress give the agency authority to accept gifts of goods and services that will assist the agencys goal of enhancing transparency The Commission seeks authorization to accept gifts from private sources in order to further its goal of facili-tating transparency through a state-of-the-art web-based public disclosure system The Commission only seeks the authority to accept gifts for the purpose of carrying out this mission The Commission recognizes that vigilant review would be required to limit con-flicts of interest and would promulgate a rule governing disclosure of any gifts prior to their acceptance The complete legislative recommendations document is available on the FECrsquos website (Posted 12282015 By Isaac Baker) Resources 2015 Legislative Recommendations [PDF]

Libertarian National Committee Inc v FEC (New) On January 25 2016 the Libertarian National Committee Inc (LNC) filed suit against the Commission in the US District Court for the District of Columbia challenging the Federal Election Campaign Actrsquos (the Act) annual limits on contributions to national party commit-tees Background The LNC the national committee of the Libertarian Party of the United States seeks imme-diate access to the full $23557520 bequeathed to it by the late Joseph Shaber Last year in response to an advisory opinion request from Mr Shabers trustee the Com-mission reaffirmed its longstanding interpretation that the Acts annual limit on contribu-tions from an individual to a national party committee mdash currently $33400 (the Party Limit) mdash applies to contributions made by testamentary bequest See AO 2015-05 and 52 USC sectsect 30116 30125 As a result Mr Shabers bequest must be distributed to the LNC in installments of no more than that annual limit as adjusted for inflation every two years National party committees may also establish separate accounts to cover certain costs as-sociated with presidential nominating conventions election recounts and other legal pro-ceedings and headquarters buildings The contribution limits applicable to the separate accounts are 300 of the Party Limit--currently $100200 for individuals The LNC has de-clined to accept any portion of the Shaber bequest into one of these accounts

Litigation

Complaint The LNC argues that applying the annual Party Limit to bequests unconstitutionally in-fringes upon the speech rights of both donors and recipients The plaintiff further contends that in light of the higher limits on contributions to convention legal expense and building accounts the Party Limit effectively imposes a content-based restriction on a national partyrsquos speech a party can only spend $33400 of a donorrsquos money on general political speech but nearly ten times that amount on government-favored purposes The LNC also asserts that bequeathed funds do not ldquocreate the appearance or possibility of quid pro quo corruption hellip [and] cannot effectively circumvent contribution limits to politi-cal candidates because the donor often has no idea which candidates might benefit from the contribution no candidate can predictably rely on receiving the money from a bequest and neither candidates nor political parties risk offending the donors of bequests once the money is receivedrdquo The plaintiff asks the court to grant it declaratory relief and to enjoin the Commission from enforcing the Party Limit generally or in relation to the Shaber bequest US District Court for the District of Columbia Case 116-CV-00121 (Posted 02082016 By Alex Knott) Resources Libertarian National Committee Inc v FEC Ongoing Litigation Page Advisory Opinion 2015-05 (PDF)

Van Hollen v FEC On January 21 2016 the US Court of Appeals for the District of Columbia reversed a 2014 district court decision that invalidated a Commission regulation governing the disclo-sure of certain donations used to fund electioneering communications The regulation in question (11 CFR 10420(c)(9)) requires disclosure of only those donations made for the purpose of furthering electioneering communications In reversing the US District Court for the District of Columbias 2014 decision the appellate court upheld the Commission regulation as a reasonable interpretation of the disclosure provisions of the Federal Election Campaign Act (FECA) Background The Federal Election Campaign Act (the Act) defines an electioneering communication as any broadcast cable or satellite communication that refers to a clearly identified candidate for federal office is publicly distributed within certain time periods before an election and is targeted to the relevant electorate 52 USC sect30104(f)(3) Every person who makes dis-bursements for an electioneering communication aggregating over $10000 per year must file a report with the FEC identifying among other things the person who made the dis-bursement 52 USC sect30104(f)(1) (2) If the disbursement is paid out of a segregated account consisting of funds donated by individuals directly to the account for electioneering communications the report must disclose the names and addresses of all those who do-nated an aggregate of $1000 or more within a certain time period to the account If the disbursements were not made from a segregated account then the report must disclose the names and addresses of all contributors who contributed over $1000 within a certain

communications the report must disclose the names and addresses of all those who do-nated an aggregate of $1000 or more within a certain time period to the account If the disbursements were not made from a segregated account then the report must disclose the names and addresses of all contributors who contributed over $1000 within a certain time period to the person making the disbursement 52 USC sect30104(f)(2)(E) The regulation at issue in this case 11 CFR 10420(c)(9) was promulgated in 2007 after the Supreme Courtrsquos decision in FEC v Wisconsin Right to Life Inc which allowed all cor-porations and unions to make certain types of electioneering communications for the first time1 Because these corporations and labor organizations had not previously been permit-ted to make electioneering communications the statute did not specify how such election-eering communications should be reported The Commissionrsquos regulation requires corpora-tions or labor organizations that make electioneering communications to disclose the name and address of each person who made a donation aggregating $1000 or more to the cor-poration or labor organization ldquofor the purpose of furthering electioneering communica-tionsrdquo 11 CFR 10420(c)(9) (Emphasis added) In April 2011 Rep Christopher Van Hollen filed suit against the Commission challenging the regulation as contrary to the law it was supposed to implement In a 2012 opinion the district court found that the Act requires every person who funds electioneering communi-cations to disclose all contributors and the Act cannot be construed to include a purpose requirement On September 18 2012 the appellate court reversed the judgment of the district court finding the statutersquos disclosure provisions ambiguous The appeals court remanded the case to the district court for further consideration The district court then directed the Commission to inform the court whether the agency planned to initiate a rulemaking or defend its current regulation On October 4 2012 the Commission informed the court of its decision not to initiate a rulemaking to amend its regulations governing the disclosure of electioneering communications but instead to continue to defend the current regulation at 11 CFR 10420(c)(9) Having found the law in question to be ambiguous the appellate court directed the district court to determine whether the Commissionrsquos regulation is based on a permissible con-struction of the statute In its November 2014 opinion the district court concluded that the Commissions promulgation of 11 CFR 10420(c)(9) was arbitrary capricious and contrary to law because it requires disclosure of only those donations made for the purpose of fur-thering electioneering communications Court Decision In its January 21 opinion the appellate court found the Commissions purpose requirement to be reasonable and consistent with the text history and purpose of the law The opinion reiterates the opinion of the previous appeals panel that Congress left the meaning of contributor ambiguous and that Congress implicitly delegated authority to the agency to fill in the statutory gaps The opinion states the Commissions interpretation of the stat-ute is not only permissible but persuasive In analyzing whether the regulation was ldquoarbitrary and capriciousrdquo the opinion described the Commissionrsquos three explanations for the purpose requirement A Support Rationale Without the purpose requirement individual contributors to a

union or corporation who do not support the entityrsquos electioneering communications could be mistakenly characterized as supporting the messages

A Burden Rationale The purpose requirement ensures disclosing entities are not obliged to create an exhaustive list of every individual who provided more than $1000 which could be very costly and require an inordinate amount of effort

A Privacy Rationale The Commission tailored its regulations in a way that both effec-tuates the laws disclosure requirements and protects the constitutional interests in pri-vacy

The court concluded Because we can reasonably discern the FECrsquos analytical path from these three rationales we uphold its purpose requirement against Van Hollenrsquos challenge United States Court of Appeals for the District of Columbia Case 15-5016 (Posted 02012016 By Isaac Baker) 1 The Supreme Courtrsquos 2010 decision in Citizens United removed entirely the ban on corporate and union elec-tioneering communications Resources bull Van Hollen v FEC Ongoing Litigation Page bull Van Hollen v FEC Order bull Van Hollen v FEC Opinion

Stop Hillary PAC et al v FEC (District Court) On December 21 2015 the US District Court for the Eastern District of Virginia denied plaintiffs Stop Hillary PAC and Dan Backers Motion for Preliminary Injunction The plaintiffs had sought an interim order enjoining the FEC from taking any action to enforce the nam-ing restriction for unauthorized political committees in section 52 USC sect 30102(e)(4) against plaintiffs throughout the duration of their lawsuit challenging the constitutionality of that provision The plaintiffs had also sought to enjoin the FEC from enforcing section 30102(e)(4) either facially or as applied to nonconnected political committees with names that clearly and unambiguously oppose a candidate The court held that the plaintiffs did not show a likelihood of success on the merits of their claims that the naming restrictions for unauthorized political committees in 52 USC sect 30102(e)(4) and 11 CFR 10214 are a content-based restriction on speech or violate their First Amendment rights Background The Federal Election Campaign Act (the Act) states that any political committee which is not an authorized committee [of a federal candidate]hellipshall not include the name of any candidate in its name 52 USC sect 30102(e)(4) Commission regulations further state that any political committee that is not the authorized committee of a candidate shall not in-clude the name of any candidate in its name which also includes any name under which a committee conducts activities such as solicitations or other communications including a special project name or other designation 11 CFR 10214(a) However Commission regu-lations state that an unauthorized committee may include the name of a candidate in the title of a special project name or other communication if the title clearly and unambigu-ously shows opposition to the named candidate 11 CFR 10214(b)(3) Plaintiff Stop Hillary PAC is a nonconnected unauthorized committee that maintains a non-contribution account (Hybrid PAC) Its stated mission is to engage in political advocacy

make political contributions and expenditures and organize supporters to help stop Hillary Rodham Clinton from becoming President of the United States Plaintiff Dan Backer serves as its attorney and treasurer The committee registered with the FEC on May 16 2013 After Hillary Rodham Clinton reg-istered as a candidate for president in April 2015 the FEC asked Stop Hillary PAC and Mr Backer to amend the committeersquos Statement of Organization so that its name would not include the name of a federal candidate Mr Backer and Stop Hillary PAC refused to change the committeersquos name On September 22 2015 the plaintiffs filed suit in the US District Court for the Eastern District of Virginia challenging the Act and Commission regulations naming restrictions On October 6 2015 the plaintiffs filed a Motion for Preliminary Injunction asking the court to prohibit the FEC from taking any action to enforce section 30102(e)(4) against plaintiffs throughout the duration of their lawsuit and from enforcing the political committee naming requirements either facially or as applied to non-connected political committees with names that clearly and unambiguously oppose a candidate District Court Decision The court explained that a party seeking a preliminary injunction must establish that 1) he is likely to succeed on the merits 2) he is likely to suffer irreparable harm in the ab-sence of preliminary relief 3) the balance of the equities tips in his favor and 4) an in-junction is in the public interest The court held that the plaintiffs did not show a likeli-hood of success on the merits to justify granting the Motion for Preliminary Injunction In this case the plaintiffs claimed that a political committees name is a protected form of political speech and that the naming restrictions impose a substantial burden on their First Amendment rights without furthering an important or compelling government interest However the court held that there was no showing that the Act restricts plaintiffs speech or that the naming restrictions were enacted because of the content of their speech The court first recounted the naming restrictions long history of alleviating the constant public confusion surrounding [PACs] The court noted that prior to the naming restric-tions the name of unauthorized PACs could contain a candidates name without being au-thorized or endorsed by that candidate The voting public would mistake such unauthor-ized PACs as a candidates official authorized PAC resulting in misdirected campaign con-tributions and increased voter confusion The court found that such confusion is still likely and is exactly why 30102(e)(4)s mandate why should not be disturbed The court rejected the plaintiffs argument that section 30102(e)(4) is content based and subject to strict scrutiny and citing Citizens United and McConnell explained that section 30102(e)(4) does not prevent anyone from speaking The court found that on the con-trary the naming restrictions allow unauthorized PACs all forms of political speech by allowing them [the freedom] to discuss candidatesmdasheven by using a candidates namemdashthroughout their website solicitations special projects and various other communications and even in the titles of their special projects if the title clearly and unambiguously shows opposition to the named candidate The court pointed out that the only area where the plaintiffs are not allowed to use a candidates name is in the official title of the unauthor-ized PAC The court found this narrow and specific requirement does not prohibit speech but limits potential confusion about which person group or candidate the PAC represents and ensures transparency

Instead the court found section 30102(e)(4) requires exacting or intermediate scrutiny since it is part of the Acts disclosure regime The court found the naming restrictions are tailored to the governmental interest of limiting confusion fraud and abuse of the political process Further the fact that the governments interest only impedes on Plaintiffs abil-ity to include a candidates name in its title alone further demonstrates that 30102(e)(4) is the least restrictive means of accomplishing the governments interest for transparency in PACs Given the courts finding that the naming restrictions for unauthorized political committees are disclosure requirements that are substantially related to important government inter-ests the court found the plaintiffs unable to satisfy the first prong required for a prelimi-nary injunction The court also briefly noted that in light of the fact that the requirements only require plaintiff Stop Hillary PAC to change its official committee name it was not con-vinced that plaintiffs would suffer irreparable harm if the Motion is not granted or that the balance of hardships tips in the plaintiffs favor The court noted that despite having to change the PACs name the plaintiffs are afforded under the statute the unique ability to retain their official website Facebook and Twitter page Finally the court noted that with the election approaching it is not in the publics interest to upend a statute that was cre-ated for the very purpose of ensuring the public are clearly informed (Posted 12292015) Resources Stop Hillary PAC v FEC Ongoing Litigation Page Record article Pursuing Americas Greatness v FEC (District Court)

FEC v Lynch (New) On December 18 2015 the Federal Election Commission (FEC) filed suit in the US Dis-trict Court for the Southern District of Florida against Edward Lynch Sr Lynch for Con-gress and Edward Lynch Sr in his official capacity as treasurer (defendants) The Com-mission seeks a declaration that defendantsrsquo conversion of campaign funds to personal use on or after August 12 2010 was a violation of 52 USC sect 30114(b) The FEC further seeks a permanent injunction against similar future violations and appropriate civil penal-ties against the defendants as well as an order requiring Mr Lynch to disgorge the con-verted funds Background Lynch for Congress was the principal campaign committee for Edward J Lynch Sr for his 2008 and 2010 campaigns for US Congress Between 2008 and 2010 evidence was un-covered that the defendants may have converted as much as $53500 of campaign contri-butions for Mr Lynchrsquos personal use however the complaint focuses on specific expendi-tures made on or after August 12 2010 The FEC alleges that Mr Lynch used campaign funds to pay for various personal expenses during that time period including gym mem-bership dues personal loan payments automobile expenses and retail purchases Compliance Action The Federal Election Campaign Act defines ldquopersonal userdquo as the use of campaign funds ldquoto fulfill any commitment obligation or expense of a person that would exist irrespective of the candidatersquos election campaign or individualrsquos duties as a holder of Federal officerdquo 52

USC sect 30114(b)(2) Personal use includes among other things payments of home mort-gages rent or utilities clothing purchases non-campaign related automobile expenses and health club dues among other payments 52 USC sect 30114(b)(2) 11 CFR 1131(g) The Commission initiated enforcement proceedings against the defendants after reviewing information in the normal course of carrying out its supervisory responsibilities Unable to secure acceptable conciliation agreements with the defendants following a finding of prob-able cause to believe that the defendants violated 52 USC sect 30114(b) the Commission voted 6-0 to authorize this suit The FEC seeks a declaration that defendantsrsquo conversion of $1622 of campaign funds for Mr Lynchrsquos personal use on or after August 12 2010 violated the Federal Election Cam-paign Act the assessment of a $7500 civil penalty against Mr Lynch in his personal ca-pacity and the assessment of a $7500 civil penalty against Lynch for Congress and Mr Lynch in his official capacity as treasurer of that committee The FEC also seeks an order requiring Mr Lynch to disgorge the $1622 of campaign funds converted to personal use on or after August 12 2010 and a permanent injunction against future similar violations by defendants (Posted 12292015) Resources FEC v Lynch Ongoing Litigation Page

FEC v Johnson (215-cv-00439-DB) (District Court) On December 10 2015 the Commission moved to amend its complaint against Utah busi-nessman Jeremy Johnson to add John Swallow as a defendant In June the Commission had filed suit against Johnson alleging that he knowingly and willfully used straw donors to exceed contribution limits to federal candidates The Commission alleges that Swallow violated the Federal Election Campaign Act by know-ingly and willfully making contributions in the names of others when he caused helped and assisted Johnsonrsquos scheme See 52 USC sect 30122 The FEC argues that its motion should be granted because of the overlapping fact patterns and legal issues involved and states that both Swallow and Johnson reasonably should have been aware that Swallow could be added as a defendant (Posted 12152015 By Christopher Berg) Resources FEC v Johnson Ongoing Litigation Page

CREW v FEC (15-cv-02038) (New) On November 23 2015 Citizens for Responsibility and Ethics in Washington (CREW) and Melanie Sloan filed a Complaint for Injunctive and Declaratory Relief in the US Dis-trict Court for the District of Columbia The Complaint alleges that the FECs dismissal of CREWs administrative complaint against the Commission on Hope Growth and Opportu-

nity (CHGO) was arbitrary capricious an abuse of discretion and contrary to law CREW seeks an order declaring that the dismissal was contrary to law and requiring the Commis-sion to conform with that decision Background CREW and its former Executive Director Melanie Sloan filed a complaint with the FEC on May 23 2011 and an amended complaint on April 26 2012 They alleged that CHGO spent over $23 million in the 2010 elections in violation of FECA by disseminating electioneering communications and independent expenditures without including proper disclaimers re-porting its activity or registering as a political committee with the FEC (MUR 6471) On October 1 2015 the Commission by a vote of three to three did not find reason to believe that CHGO violated the Act and the Commission then voted to close the file On November 23 2015 CREW and Melanie Sloan filed a Complaint for Injunctive and De-claratory Relief in the US District Court for the District of Columbia challenging the Com-missions dismissal of its administrative complaint Legal Provisions Under the Act and Commission regulations an independent expenditure is an expenditure by a person for a communication that expressly advocates the election or defeat of a clearly identified candidate and that is not coordinated with a federal candidate or political party 52 USC sect 30101(17) 11 CFR 10016(a) Independent expenditures must be re-ported to the FEC by political committees and by every person that is not a political com-mittee once the expenditures aggregate in excess of $250 in a calendar year with respect to a given election 52 USC sect 30104(c)(1) 11 CFR 10910 Electioneering communications are any broadcast cable or satellite communication that refers to a clearly identified candidate for federal office that is publicly distributed within certain time periods before an election and that is targeted to the relevant electorate 52 USC sect 30104(f)(3)(A) 11 CFR 10029(a) Electioneering communications must be re-ported to the FEC once spending exceeds $10000 in a calendar year See 52 USC sect 30104(f)(1) 11 CFR 10410(b) Both independent expenditures and electioneering communications must include a dis-claimer stating who paid for the communication and whether it was authorized by any can-didate or campaign committee See 52 USC sect 30120(d)(2) 11 CFR 11011(c)(4) Finally any committee club association or other group of persons which receives contri-butions aggregating in excess of $1000 during a calendar year or which makes expendi-tures aggregating in excess of $1000 during a calendar year and whose major purpose is the nomination or election of a federal candidate is a political committee that must regis-ter and report to the FEC 52 USC sect 30101(4)(A) 11 CFR 1005 Buckley v Valeo 424 US 1 79 (1976) Court Complaint Plaintiffs allege that the Commissions dismissal of their administrative complaint was arbi-trary capricious an abuse of discretion and contrary to law in that the dismissal rested on impermissible interpretations of the Act ignored Commission and judicial precedent and mischaracterized political campaign activities

The plaintiffs ask the court to declare the dismissal contrary to law and issue an order re-quiring the Commission to conform with that decision (Posted 12032015) Resources MUR 6471

AO 2015-15 Website May Help Users Make Contributions to Federal Can-didates A corporation may establish a website designed to help users identify candidates whose actions they support If they choose users may contribute to those candidates through the website Background WeSupportThatcom is a for-profit corporation that proposes to offer an internet-based service through which users will be able to support or oppose certain actions of federal candidates It plans to create a website that allows users to find research and contribute to candidates based on their legislative votes sponsorship of bills and public statements The requestorrsquos website will focus on current events and will feature activities and candi-dates that are gaining the most media interest The website will provide to users who se-lect a featured activity information about candidates associated with that activity If there are candidates on both sides of an issue the user will be able to click a button labeled I support this or I dont support this to bring up a list of candidates who align with the userrsquos views Then those users will be able to make contributions to one or more of the listed candidates by selecting the ldquocontribute nowrdquo button WeSupportThatcom plans to collect each contributors necessary disclosure information and require each user to confirm that he or she may lawfully make the contribution The corporation will also request the contributing users credit or debit card information It plans to cover its costs and make a profit by assessing a processing fee The userrsquos credit or debit card will be charged for the full amount and proceeds deposited into two separate bank accounts mdash one for the processing fee and another that will be used exclusively for contributions WeSupportThatcom will forward all contributions and contributor informa-tion to candidate committees within 10 days of receipt The requestor plans to advertise its services through online banner ads and on Facebook and Google The requestor will not offer its services to candidates or their committees nor will it re-ceive payment from recipient committees The requestor also will not ldquoadvanc[e] any par-ticular issue position on an issue or any political outcomerdquo WeSupportThatcom asked the Commission whether its proposed business plan complies with the Federal Election Campaign Act (the Act) and Commission regulations and whether the users payment of a processing fee to the corporation constitutes a contribution to the recipient candidate committee

Advisory Opinions

Analysis The Act and Commission regulations prohibit a corporation from making a contribution in connection with a federal election See 52 USC sect 30118(a) 11 CFR sect 1142(b)(l) A con-tribution includes any direct or indirect payment distribution loan advance deposit or gift of money or any services or anything of valueto any candidate [or] campaign com-mitteein connection with any [federal] election 52 USC sect 30118(b)(2) 11 CFR sect 1142(b)(1) see also 52 USC sect 30101(8)(A)(i) 11 CFR 10052(a) The Commission has previously concluded that entities that process contributions as a ser-vice to contributors and not to the recipient political committees are not making contribu-tions to those committees See eg AO 2014-07 (Crowdpac) at 6 (distinguishing between companies that process contributions as service to contributors and companies that proc-ess contributions as service to recipient political committees) AO 2012-22 (skimmerhat) at 4-6 (same) AO 2011-19 (GivingSphere) at 7 (same) AO 2011-06 (Democracy Engine) at 5 (same) The requestorrsquos proposed service differs from those previously approved by the Commission in that the requestorrsquos website and advertising will list certain candidate activities that the requestor believes are most likely to motivate individuals to use its web-site to make contributions The requestorrsquos proposal however does not raise concerns that the requestor is selecting candidate recipients to influence the outcome of the elec-tion Accordingly under the circumstances presented in the request the requestorrsquos pro-posed business plan complies with the Act and Commission regulations The Commission further concludes that the fees will not be in-kind contributions to the re-cipient committees because the fees paid to the requestor are for services rendered for the benefit of the contributors not of the recipient political committeesrdquo and thus ldquosuch fees do not relieve the recipient political committees of a financial burden they would oth-erwise have had to pay for themselves AO 2014-07 (Crowdpac) at 6 AO 2011-06 (Democracy Engine) at 6 Date Issued 01142016 6 pages (Posted 02042016 By Alex Knott) Resources Advisory Opinion 2015-15 [PDF]

Commission Discussion of AOR 2015-15

AO 2015-11 App for Making Contributions by Rounding Up Purchases Made on Contributorsrsquo Credit Cards Permissible A limited liability company (LLC) taxed as a corporation may provide an app that ldquorounds uprdquo each transaction on a users credit or debit card to the next dollar and provides the difference between that amount and the original chargemdashminus a service feemdashto political committees or other nonprofits chosen by the user The Commission concluded that this arrangement would not result in the LLC making contributions or serving as a conduit or intermediary but was unable to agree on the legal basis for its conclusion by the required four affirmative votes Background FYP LLC plans to develop a contribution processing platform called MyChange The app will round up each credit or debit card transaction to the next dollar and transmit the dif-ference between that amount and the original charge to political committees or other non-profit organizations designated by the user For example if a user were to purchase a cup of coffee for $230 the app would charge an additional $70 to the users card and trans-mit that amount minus FYPs service fee to the users designated recipients (which could include federal political committees)

To enroll in MyChange users must provide their credit or debit card information If they intend to use the app to make political contributions they must also verify their eligibility to make contributions under federal law and provide their contributor information such as employer and occupation Users will select recipients for their rounded up contributions from a pre-determined list included in the app FYP will update that list each month and will include only committees that are in good standing with the Federal Election Commis-sion and that share users ideology and values Within one business day after a users credit or debit card is charged funds that are desig-nated as rounded-up amounts will be transferred from FYPs merchant account to the users indicated recipient less FYPs service fee At the end of each month FYP will recon-cile funds processed via the MyChange app with its internal records User fees charged by FYP will be deducted from the rounded-up amounts before the rounded-up amounts are remitted to the political committees or organizations who are the recipients The service fees will be calculated as a percentage of the total funds charged to the users credit or debit card in a given transaction FYP expects the fee to cover all of its costs in providing the processing and forwarding services and to provide FYP with a reasonable profit Analysis The Federal Election Campaign Act (the Act) and Commission regulations generally prohibit any corporation from making contributions in connection with federal elections 52 USC sect 30118(a) 11 CFR 1142(b)(1) The term contribution includes any direct or indirect payment distribution loan advance deposit or gift of money or any services or any-thing of valuein connection with any [federal] election 52 USC sect30118(b)(2) 11 CFR 1141(a)(1) Anything of value includes in-kind contributions such as the provision of goods or services without charge or at a charge that is less than the usual and normal charge 11 CFR 10052(d)(1) The usual and normal charge is the price of those goods in the market from which they ordinarily would have been purchased at the time of the contribution or [the] commercially reasonable rate prevailing at the time the services were rendered 11 CFR 10052(d)(2) The Commission concluded that FYPs proposal would not result in prohibited corporate contributions from FYP to any recipient political committee but the Commission was un-able to agree on the legal basis for its conclusion by the required four affirmative votes Nor could the Commission agree whether a MyChange userrsquos payment of fees for the proc-essing of a contribution to a political committee would constitute a contribution from the user to the recipient committee Similarly the Commission also concluded but could not agree on the legal basis by the required four affirmative votes that FYP would not be acting as a conduit or intermediary of earmarked contributions when processing contributions from users to recipient political committees Commission regulations prohibit corporations from serving as conduits or in-termediaries of earmarked contributions to federal candidates 11 CFR 1106(b)(2)(ii) Date Issued December 2 2015 6 pages (Posted 12152015 By Myles Martin) Resources Advisory Opinion 2015-11 [PDF]

Pending Advisory Opinion Requests as of January 31 2016 Advisory Opinion Requests (AORs) pending before the Commission as of the end of the month are listed below Procedures for commenting on pending AORs are described here AOR 2015-14 [PDF] Permissibility of providing school credit and stipend to student performing campaign-related activities (Hillary for America October 29 2015 Extension of time to February 16 2016 to respond to this request granted on January 27 2016) AOR 2015-16 [PDF] Use and disposition of general election contributions received before primary (Niger Innis for Congress received on December 15 2015) (Posted 02032016 By Alex Knott) Resources Advisory Opinion Search

Pending Advisory Opinion Requests as of December 31 2015 Advisory Opinion Requests (AORs) pending before the Commission as of the end of the month are listed below Procedures for commenting on pending AORs are described here AOR 2015-13 [PDF] Use of campaign funds for post-retirement employment of assistant (Senator Harry Reid October 28 2015 Extension of time to January 25 2016 to respond to this request granted on December 17 2015) AOR 2015-14 [PDF] Permissibility of providing school credit and stipend to student performing campaign-related activities (Hillary for America October 29 2015 Extension of time to January 25 2016 to respond to this request granted on December 17 2015) AOR 2015-15 [PDF] Use of web platform to make contributions to federal candidates (WeSupportThatcom re-ceived on November 20 2015) AOR 2015-16 [PDF] Use and disposition of general election contributions received before primary (Niger Innis for Congress received on December 15 2015) (Posted 01042016 By Dorothy Yeager) Resources Advisory Opinion Search

Commission Certifies Matching Funds for OrsquoMalley

On January 20 2016 the Commission certified $84636509 in federal matching funds to presidential candidate Martin J OrsquoMalley for the 2016 primary election OrsquoMalley is seeking the Democratic nomination for president The certified amount was in response to the first regular submission for matching funds made by the OrsquoMalley campaign In November OrsquoMalley became the first 2016 presidential candidate to be declared eligible by the Commission to receive federal matching funds Based on his initial threshold sub-mission the Commission requested that the United States Treasury make an initial pay-ment of $100000 to OrsquoMalleyrsquos campaign The United States Treasury transferred the ini-tial payment on January 4 2016 The Commission will now ask the Treasury to make an additional payment of $84636509 to OrsquoMalley for President1 To become eligible for matching funds candidates must raise a threshold amount of $100000 by collecting $5000 in 20 different states Although an individual may contribute up to $2700 to a primary candidate in the current election cycle only a maximum of $250 per individual is matched with funds from the Presidential Election Campaign Fund Other requirements to be declared eligible include agreeing to an overall spending limit abiding by spending limits in each state using public funds only for legitimate campaign-related expenses keeping financial records and permitting an audit of campaign financial activity (Posted 01222016 By Alex Knott) 1 Following the tally vote completed today the Commission will request the Treasury to make a payment of $84636509 to OrsquoMalley for President

Resources FEC Press Release Brochure Public Funding of Presidential Elections Brochure The $3 Tax Checkoff Press Office Backgrounder on Presidential Election Campaign Fund 2016 Presidential Matching Fund Submissions Income Tax Check-off Data

Public Funding

FEC Introduces Online Payment Option for Administrative Fines The Commission is now accepting online payments for administrative fines Respondents in Administrative Fine Program (AFP) cases now have the option of remitting payment by automated clearing house (ACH) withdrawal from a bank account or by debit or credit card through Paygov the federal governments secure portal for online collections Staff in the Commissionrsquos Reports Analysis Division and Office of Administrative Review will be available to help respondents submit online payments and to update them on the status of their payments This added convenience was created through a collaboration of the Com-mission and the Department of the Treasurys Bureau of the Fiscal Service Please visit the new wwwfecgovafpayshtml to view the available payment options and be directed to Paygovs AFP payment application (Posted 02042016 By Alex Knott) Resources Administrative Fine Program

FEC to Host March 23 Webinar for Candidate Committees The Commission will hold a one-day online seminar for federal candidates and their cam-paign committees on Wednesday March 23 2016 Commission staff will conduct several technical workshops on the federal campaign finance laws affecting candidate committees Workshops are designed for those seeking an introduction to the basic provisions of the law as well as for those more experienced in campaign finance law Attendees can choose one of two options for the morning session Basics and Best Prac-tices or Recent Developments in the Law The afternoon will feature a two-part work-shop on Campaign Committee Operations Participants will be able to download elec-tronic copies of the workshop materials in advance and will receive additional instruc-tions and technical information shortly before the event For more information and a de-tailed agenda please visit the Candidate We-binar web pagehttpwwwfecgovinfoconferences2016candidatewebinarshtml The cost to participate is $80 Refunds (minus a $20 registration fee) will be made for all cancellations received by Friday March 18 no refund will be made for cancellations re-ceived after that date Register online athttpwwwcventcomd1fqqq9 Please direct

Compliance

Outreach

all questions about registration and fees to Sylvester Management Corporation (Phone 1-800246-7277 email Rosalynsylvestermanagementcom) For other questions call the FECrsquos Information Division at 1-800424-9530 (press 6) or send an email to Confer-encesfecgov Webinar Schedule March 23 2016 Morning Sessions Option 1 Basics and Best Practices 1030 AM - 1200 PM EDT Option 2 Recent Developments in the Law 1030 AM - 1200 PM EDT Afternoon Sessions Campaign Committee Operations Part 1 115 - 245 PM EDT Campaign Committee Operations Part 2 300 - 430 PM EDT (Posted 02112016 By Isaac Baker) Resources FEC Educational Outreach Opportunities

Lobbyist Bundling Disclosure Threshold Unchanged

The Federal Election Campaign Act as amended by the Honest Leadership and Open Gov-ernment Act of 2007 (HLOGA) requires certain political committees to disclose contribu-tions bundled by lobbyistsregistrants and lobbyistregistrant PACs once the contributions exceed a specified threshold amount The Commission must adjust the threshold amount for inflation at the beginning of each calendar year The threshold is adjusted by multiplying the $15000 statutory threshold by the difference between the preceding yearrsquos price index as certified by the Secretary of Labor and the price index for the base period (CY 2006) The resulting amount is rounded to the nearest multiple of $100 52 USC sectsect 30104(i)(3) 30116(c)(1)(A)-(B) Based on this formula ($15000 times 117569) the lobbyist bundling disclosure threshold for 2016 remains un-changed at $17600 (Posted 02102010 By Alex Knott) Resources Federal Register Notice [PDF] Lobbyist Bundling Disclosure FAQ

Coordinated Party Expenditure Limits Adjusted The 2016 coordinated party expenditure limits are now available The limits are $23821100 for Presidential nominees $96100 for House nominees in states that have only one US House Representative

This adjustment is calculated by multiplying $20000 by the Cost of Living Adjustment provided by the Secretary of Labor (COLA) and rounding to the nearest $100 The ap-plicable COLA is 480703

$48100 for House nominees in states that have more than one US House Represen-tative ($10000 x COLA) and

A range from $96100 to $2886500 for Senate nominees depending on each states voting age population (the greater of $20000 x COLA or 2cent x state voting age popula-tion (VAP) x COLA)

Party committees may make these special expenditures on behalf of their 2016 general election nominees (including in special elections) National party committees have a sepa-rate limit for each nominee Each state party committee has a separate limit for each House and Senate nominee in its state Local party committees do not have their own separate limit One party committee may authorize another committee of that party to make an expenditure against the authorizing committeersquos limit Local committees may make coordinated party expenditures only with advance authorization from another com-mittee within the party Coordinated party expenditure limits are separate from the contribution limits Unlike con-tributions the national Senatorial and Congressional committees do not have their own coordinated party expenditure limits however they may receive authorization to spend against the national limit or state party limits They also differ from contributions in that the party committee must spend the funds on behalf of the candidate rather than give the money directly to the campaign These expenditures may be made in consultation with the candidate however only the party committee making the expenditure ndash not the candidate committee ndash must report them Coordinated party expenditures are reported on FEC Form 3X line 25 and are always itemized on Schedule F regardless of amount Click here to view the 2016 coordinated party expenditure limits The link also in-cludes information on which party committees have the authority to make coordinated party expenditures the formula used to calculate the coordinated party expenditure limits and a listing of the state-by-state coordinated party expenditure limits for Senate candi-dates (Posted 02102016 By Alex Knott) Resources Federal Register Notice [PDF] Chapter 7 Campaign Guide for Political Party Committees [PDF] Compliance Map

FEC to Host February 24 Webinar for Party Committees The Commission will hold a one-day online seminar for political party committees on Wednesday February 24 2016 Commission staff will conduct several technical workshops on the federal campaign finance laws affecting party committees Workshops are designed for those seeking an introduction to the basic provisions of the law as well as for those more experienced in campaign finance law Attendees can choose one of two options for the morning session Basics and Best Prac-tices or Recent Developments in the Law The afternoon will feature a two-part workshop on Party Committee operations Participants will be able to download electronic copies of the workshop materials in advance and will re-ceive additional instructions and technical in-formation shortly before the event For more information and a detailed agenda please visit httpwwwfecgovinfoconferences2016partyseminarshtml The cost to participate is $80 Refunds (minus a $20 registration fee) will be made for all cancellations received by Friday February 19 no refund will be made for cancellations re-ceived after that date Register online athttpwwwcventcomdxfq1wm Please direct all questions about registration and fees to Sylvester Management Corporation (Phone 1-800246-7277 email Rosalynsylvestermanagementcom) For other questions call the FECrsquos Information Division at 1-800424-9530 (press 6) or send an email to Confer-encesfecgov Webinar Schedule February 24 2016 Morning Sessions Option 1 Basics and Best Practices 1030 AM - 1200 PM EST Option 2 Recent Developments in the Law 1030 AM - 1200 PM EST Afternoon Sessions Party Committee Operations Part 1 100 - 230 PM EST Party Committee Operations Part 2 245 - 415 PM EST (Posted 01222016 By Isaac Baker) Resources FEC Educational Outreach Opportunities Filing Dates

FEC Hosts Year-End Reporting and E-Filing Webinars The Commission will offer its annual Year-End Reporting and FECFile workshops in January 2016 The webinars for PACs and party committees will be held on January 13 while the webinars for candidates will be offered on January 20 The reporting session will provide an overview of the Reports Analysis Division review process address common filing problems and provide answers to questions committees may have as they prepare to file their January 31 Year-End Reports The electronic filing session will demonstrate the Commis-sionrsquos FECFile software and address questions filers may have concerning electronic filing Webinar Information All sessions will be online only Additional instructions and technical information will be pro-vided to those who register Registration Information The registra-tion fee is $25 per webinar For the PAC and party webinars a full refund will made for all cancellations received before 5 pm EST on Friday January 8 no refunds will be made for cancellations received after that time For the candidate we-binars a full refund will made for all cancellations received before 5 pm EST on Friday January 15 no refunds will be made for cancellations received after that time Complete registration information is available on the FECrsquos website at httpwwwfecgovinfooutreachshtmlroundtables Registration Questions Please direct all questions about the roundtablewebinar registration and fees to Sylvester Management at 1-800246-7277 or email Rosalynsylvestermanagementcom For other questions call the FECrsquos Information Division at 800424-9530 (press 6) or send an email to Conferencesfecgov (Posted 12162015 By Isaac Baker) Roundtable Schedule

January 13 2016 Webinar Only

Reporting for PACs amp Party Committees 100 - 230 PM Eastern

FECFile for PACs amp Party Committees 245 - 415 PM Eastern

Reporting for Candidate Committees 100 - 230 PM Eastern

FECFile for Candidate Committees 245 - 415 PM Eastern

Check the Box to Report Memo Entries In an effort to increase reporting clarity the Commission has added a new memo item box to the Forms 3 3P and 3X filed by campaigns parties and political action committees Treasurers will use the new check box to identify memo entries Memo entries are used to provide supplemental or explanatory information on a reporting schedule and the dollar amount is not included in the line item total These entries are commonly used to report reimbursements redesignations reattributions transactions associated with credit card payments and other complex transactions Up to now committees have identified memo entries by writing the phrase Memo Item on the form The new check box will add clar-ity and consistency to memo item disclosure shorten the Commis-sionrsquos document processing times and allow the public to access disclosed data faster Paper forms that include the new check box are available for download on the reporting forms page of the FEC website The FECFile update (Build 8104) is also available and commercial software vendors are expected to incorporate the change in the coming days Filers should use the updated forms for their next FEC report (Posted 02092016 By Alex Knott) Resources Updated Form 3 [PDF] Updated Form 3X [PDF] Updated Form 3P [PDF] FECFile Campaign Guides

Reports Due in 2016 This article on filing requirements for 2016 is supplemented by the reporting tables linked at httpwwwfecgovinforeport_dates_2016shtml Year-End Reports Covering 2015 Activity All committees must file a 2015 Year-End Report due January 31 2016 that covers activ-ity through December 31 2015 To help committees prepare their reports the Commission will host reporting workshops for PACs and party committees on January 13 and for candi-dates on January 20 Since the January 31 deadline falls on a weekend in 2016 monthly and quarterly filers us-ing methods other than electronic filing or registered certified or overnight mail must en-

Reporting

sure that their reports are received by the Commissionrsquos (or the Secretary of the Senate Public Records Officersquos) close of business on the last business day before the deadline (ie Friday January 29) [FN1] Reports Covering 2016 Activity To find out which reports your committee must file in 2016 check the Filing Frequency by Type of Filer section of our reporting web page Then check the links to tables for various categories of reporting dates Please note that committees active in special elections in 2016 may have to file additional special election reports All known FEC reporting dates are also available on the Commissionrsquos website at httpwwwfecgovinforeport_datesshtml Notification of Filing Deadlines In addition to publishing this article and the online reporting tables the Commission noti-fies committees of filing deadlines through reporting reminders called prior notices Prior notices are distributed exclusively by electronic mail so every committee should ensure that the email address on its Statement of Organization (FEC Form 1) is current Each committee may list up to two email addresses To amend Form 1 electronic filers must submit Form 1 filled out in its entirety Paper filers should include only the committeersquos name address FEC identification number and the updated or changed portions of the form Treasurerrsquos Responsibilities The Commission provides reminders of upcoming filing dates as a courtesy to help commit-tees comply with the filing deadlines set forth in the Federal Election Campaign Act (the Act) and Commission regulations Committee treasurers are responsible for filing commit-tee reports on time Not receiving a prior notice does not excuse committee treasurers for failing to comply with any filing deadline Filing Electronically Under the Commissionrsquos mandatory electronic filing regulations individuals and organiza-tions required to file with the FEC that receive contributions or make expenditures includ-ing independent expenditures aggregating in excess of $50000 in a calendar year mdash or that have reason to expect to do so mdash must file all reports and statements electronically[FN2] Reports filed electronically must be received and validated by the Commission by 1159 pm Eastern Time on the filing date 11 CFR 10019(c) Electronic filers who file on paper or submit an electronic report that does not pass the Commissionrsquos validation pro-gram by that time on the filing deadline will be considered nonfilers and may be subject to enforcement actions including administrative fines 11 CFR 10418(a)(2) and (e) Senate campaigns and other committees that file with the Secretary of the Senate must file their FEC reports on paper but may file an additional unofficial electronic copy of their report with the Commission in order to enhance disclosure The Commissionrsquos electronic filing software FECFile is free and can be downloaded at httpwwwfecgovelecfilupdatelisthtml All reports filed after January 5 2016 must be filed in Format Version 8103 Reports filed in previous formats will not be accepted Fil-ers may also use commercial or privately developed software as long as the software meets the Commissionrsquos format specifications which are available on the Commissionrsquos website Committees using commercial software should contact their vendors to ensure their software meets the latest specifications

Timely Filing for Paper Filers Registered and Certified Mail Quarterly reports sent by registered or certified mail are con-sidered to be filed on the date of their postmark 52 USC sect 30104(a)(5) and 11 CFR 1045(e) Accordingly quarterly reports sent by registered or certified mail must be post-marked on or before the filing deadline to be considered timely filed 11 CFR 10019(b) A committee sending its reports by certified or registered mail should keep its mailing receipt with the US Postal Service (USPS) postmark as proof of mailing because the USPS does not keep complete records of items sent by certified or registered mail 11 CFR 1045(i) Overnight Mail Reports sent via overnight mail [FN1] will be considered timely filed if the report is postmarked on or before the filing deadline A committee sending its reports by Priority Mail or Priority Express Mail or by an overnight delivery service should keep its proof of mailing or other means of transmittal of its reports See 52 USC sect 30104(a)(5) and 11 CFR 10019(b) and 1045(e) Other Means of Filing Reports sent by other means mdash including first class mail and courier mdash must be received by the FEC (or the Secretary of the Senate) before close of business on the filing deadline See 11 CFR 10019(b) and 1045(e) (If the deadline falls on a weekend or federal holiday such filers should plan accordingly and file reports by the close of business on the last business day before the filing deadline) Forms may be downloaded at httpwwwfecgovinfoformsshtml and are available from FEC Faxline the agencyrsquos automated fax system (202501-3413) Authorized Committees of Candidates House and Senate Candidates All campaigns that have a reporting obligation must file quarterly reports in 2016 Generally an individual becomes a candidate for federal office thus triggering registration and reporting obligations when his or her campaign exceeds $5000 in either contributions received or expenditures made If the campaign has not ex-ceeded the $5000 threshold it is not required to file reports See 11 CFR 1003(a)(1) See also 11 CFR 1003(a)(2) and (3) The authorized committees of House and Senate candi-dates must also file pre-primary election and pre-general election reports before any elec-tion in which the candidate participates in 2016 These committees also must file a post-general election report if the candidate participates in the general election 11 CFR 1045(a)(2) Principal campaign committees of candidates who ran in past elections or are running in future elections must also file quarterly reports in 2016 Before a committee can stop filing with the FEC it must file a termination report with the Commission or the Secretary of the Senate as appropriate See 11 CFR 1023 Committees must continue to file reports until the Commission notifies them in writing that their termination report has been accepted Presidential Candidates All principal campaign committees of Presidential candidates must file on either a monthly or a quarterly schedule in 2016 If on January 1 2016 the com-mittee has received or anticipates receiving contributions aggregating $100000 or has made or anticipates making expenditures aggregating $100000 the committee files monthly reports in 2016 Committees which do not anticipate or have not exceeded the $100000 thresholds file quarterly reports in 2016 See 11 CFR 1045(b)(1)(i) and (ii) Note that quarterly filers must also file a pre-election report for each election in which the candidate seeks nomination or election See 11 CFR 1045(b)(1)(ii)

Presidential committees able to change their reporting schedule and that wish to do so are required to notify the Commission in writing Electronic filers must file this request elec-tronically After filing this notice of change in filing frequency with the Commission all fu-ture reports must follow the new filing schedule 11 CFR 1045(b)(2) Please note that as explained above Presidential committees that have received contributions or made expen-ditures of $100000 or more during the current presidential election cycle must file monthly reports in 2016 11 CFR 1045(b)(1)(i) The committee will receive a letter from the Commission approving the frequency change State District and Local Party Committees State district and local party committees that engage in reportable federal election activ-ity must file on a monthly schedule See 11 CFR 30036(b) and (c)(1) Committees that do not engage in reportable federal election activity may file on a quarterly basis in 2016 See 11 CFR 1045(c)(2)(i) National Party Committees National committees of political parties must file on a monthly schedule 52 USC sect 30104(a)(4)(B) and 11 CFR 1045(c)(4) Political Action Committees PACs (separate segregated funds committees with non-contribution accounts (also some-times called ldquoHybridrdquo PACs) independent expenditure-only committees (Super PACs) and other nonconnected committees) that filed on a semi-annual basis in 2015 file on a quar-terly basis in 2016 Monthly filers continue on a monthly schedule PACs may change their filing schedule but must first notify the Commission in writing Electronic filers must file this request electronically A committee may change its filing frequency only once a year 11 CFR 1045(c) The committee will receive a letter from the Commission approving the frequency change Pre- and Post-Election Reports Please note that in 2016 party committees and PACs that file monthly reports must file a pre-general election report and a post-general election report in lieu of the reports other-wise due in November and December Party committees and PACs that file quarterly re-ports also file A pre-primary election report and a pre-general election report before any election in which the committee makes a contribution to or an expenditure on behalf of a candidate in that election if not previously disclosed and s post-general election report11 CFR 1045(c)(1)(ii) and (iii) Where to File Committee treasurers must file campaign finance reports with the appropriate federal of-fice as discussed below State filing requirements also apply to campaign finance reports filed by the principal campaign committees of candidates seeking office in Guam Puerto Rico and the Northern Mariana Islands and to reports filed by PACs and party committees that support these candidates 52 USC sect 30113(a)(2)(B) House Candidate Committees Principal campaign committees of House candidates file with the FEC 11 CFR 1051

Senate Candidate Committees Principal campaign committees of Senate candidates file with the Secretary of the Senate 11 CFR 1052 Presidential Committees Principal campaign committees of Presidential candidates file with the FEC 11 CFR 1053 Candidate Committees with More Than One Authorized Committee If a campaign includes more than one authorized committee the principal campaign committee files with its own report (FEC Form 3 or 3P) a consolidated report of receipts and disbursements (FEC Form 3Z) showing its own activity as well as the activity of all other authorized committees of the candidate 11 CFR 1043(f) PACs and Party Committees Generally PACs and party committees file with the FEC 11 CFR 1054 However committees that support only Senate candidates file with the Secre-tary of the Senate including the national Senatorial campaign committees 11 CFR 1052 Joint Fundraising Committees Joint fundraising committees supporting only Senate candi-dates file with the Secretary of the Senate 11 CFR 1052 All other joint fundraising com-mittees file with the FEC 11 CFR 1054 Please note that joint fundraising committees sup-porting only federal candidates file on Form 3 and follow the reporting schedule for author-ized committees 11 CFR 10217(a)(1)(i) (c)(8) Joint fundraising committees supporting both federal candidates and other party or non-party political committees (such as PACs) file on Form 3X and follow the reporting schedule for unauthorized committees 11 CFR 1045(c) Independent Expenditures Political committees and other persons[FN3] who make independent expenditures may have to disclose this activity within 48 or 24 hours based upon the date and amount of the ex-penditure Note that aggregations of independent expenditures must be calculated as of the first date on which a communication that constitutes an independent expenditure is publicly disseminated and as of the date that any such communication with respect to the same election is subsequently publicly disseminated 52 USC sect30104(g) and 11 CFR 10019(d) 1044(b) (c) and (f) and 10910(c) and (d) Political committees must use FEC Form 3X Schedule E to file 48- and 24-hour reports Persons that are not political committees must use FEC Form 5 Political committees must report all independent expenditures regardless of whether or not they trigger the 48- or 24-hour reporting thresholds on their regularly scheduled cam-paign finance reports These independent expenditure reports are not required when a party committee or PAC makes a contribution directly to a candidate Persons that are not political committees must disclose independent expenditures in a quarterly report filed on FEC Form 5 once the expenditures exceed $250 in a calendar year in connection with an election 11 CFR 1044(b)(1) and 10910(b) Form 5 filers are not required to file quarterly reports for periods in which they have not made any independent expenditures However they must file quarterly reports for periods in which they made expenditures aggregating over $250 in a calendar year for a given election regardless of whether or not they have already reported that activity in a 48- or 24-hour report For a chart of 2016 48- and 24-hour reporting periods for independent expenditures con-sult the FEC website at httpwwwfecgovinfocharts_ie_dates_2016shtml

All persons and political committees including committees that support Senate candidates must file their 24- and 48-hour reports of independent expenditures with the Commission 11 CFR 1054 See also 11 CFR 1044 and 10910 Committees Active in Special Elections Committees authorized by candidates running in any 2016 special election must file pre- and post-election reports in addition to regularly scheduled reports 11 CFR 1045(h) They are also required to comply with the 48-hour notice requirement for any contribution of $1000 or more per source (including loans) received shortly before an election See 11 CFR 1045(f) PACs and party committees supporting candidates running in special elections may also have to file pre- and post-election reports unless they file on a monthly basis 11 CFR 1045(c)(3) and 1045(h) All PACs as well as individuals corporations labor organiza-tions and all other persons are subject to 48- and 24-hour reporting of independent ex-penditures made before an election See 11 CFR 1044(b) and (c) and 1045(g) Reporting dates for special elections will be published in the Record and on the Reporting Dates page at httpwwwfecgovinforeport_dates_2016shtmlspecial Electioneering Communications Additionally individuals and other persons who make disbursements for electioneering communications that aggregate in excess of $10000 must file disclosure statements with the Commission within 24 hours of distribution of the communications to the public 11 CFR 1045(j) See also 11 CFR 10029 A chart detailing the electioneering communication periods for 2016 primary and runoff elections is available at httpwwwfecgovinfocharts_ec_dates_2016shtml Disclosure of Lobbyist Bundling Activity Campaign committees party committees and leadership PACs that are otherwise required to file reports in connection with an election (including special elections) must simultane-ously file FEC Form 3L if they receive two or more bundled contributions from any lobbyist registrant or lobbyistregistrant PAC that aggregate in excess of the lobbyist bundling dis-closure threshold during the election reporting period 11 CFR 10422(b)(1) The lobbyist bundling disclosure threshold for calendar year 2015 was $17600 This threshold amount may increase in 2016 based upon the annual cost of living adjustment (COLA) As soon as the adjusted threshold amount is available the Commission will pub-lish it in the Federal Register and post it on its website 11 CFR 10422(g) and 11017(e)(2) For more information on these requirements see the March 2009 Record Additional Information The 2016 Reporting Schedule is also available on the FECrsquos website at httpwwwfecgovinforeport_dates_2016shtml For more information on reporting call the FEC at 800424-9530 or 202694-1100 To obtain a list of 2016 reporting dates Call and request the reporting tables from the FEC at 800424-9530 or 202694-1100 Fax the reporting tables to yourself using the FECrsquos Faxline (202501-3413 document 586) or Visit the FECrsquos web page at httpwwwfecgovinforeport_dates_2016shtml to view the reporting tables online

_______________________________________ 1As used here ldquoovernight mailrdquo includes Priority or Priority Express Mail having a delivery confirmation or an overnight service with which the report is scheduled for next business day delivery and is recorded in the servicersquos online tracking system See 11 CFR 10019(b)(1) and (b)(3)(i) Note that ldquoExpress Mailrdquo as referred to in FEC regulations has been re-named ldquoPriority Express Mailrdquo by the USPS

2The regulation covers individuals and organizations required to file reports of contributions andor expenditures with the Commission including any person making an independent expenditure 11 CFR 10418(a) Disbursements for ldquoelectioneering communicationsrdquo are not considered ldquoexpendituresrdquo and thus do not count toward the $50000 threshold for mandatory electronic filing See 11 CFR 10418(a)

3As used in this article person means an individual partnership association corporation labor organization or group of persons See 11 CFR 10010 (Posted 01082016 By Katherine Carothers) Resources 2016 Reporting Dates Compliance Map FEC Electronic Filing Record article FEC to Host Year-End Reporting and E-Filing Webinars

Ohio Special Election Reporting 8th District Ohio will hold special primary and general elections to fill the US House seat in Ohiorsquos 8th Congressional District vacated by Representative John Boehner The Special Primary will be held on March 15 2016 and the Special General will be held June 7 2016 Candidate committees involved in these elections must follow the re-porting schedule posted at httpwwwfecgovpagesreport_notices2016oh08shtml That schedule also applies to PACs and party committees that file on a quarterly basis in 2016 and partici-pate in these elections PACs and party committees that file monthly should continue to file according to their regular filing schedule Please note that the FEC does not have au-thority to extend filing deadlines even when they fall on weekends

Filing Electronically Reports filed electronically must be received and validated by the Commission by 1159 pm Eastern Time on the applicable filing deadline Electronic filers who instead file on pa-per or submit an electronic report that does not pass the Commissionrsquos validation program by the filing deadline will be considered nonfilers and may be subject to enforcement ac-tions including administrative fines Timely Filing for Paper Filers Registered and Certified Mail Generally reports sent by registered or certified mail are considered to be filed on the date of their postmark See 52 USC sect 30104(a)(2)(A)(i) (a)(4)(A)(i) and (a)(5) 11 CFR 1045(e) Accordingly pre-election reports sent by regis-tered or certified mail must be postmarked on or before the mailing deadline to be consid-ered timely filed other reports must be postmarked by the filing deadline 11 CFR 10019(b) A committee sending its reports by certified or registered mail should keep its mailing receipt with the US Postal Service (USPS) postmark as proof of mailing because the USPS does not keep complete records of items sent by certified or registered mail 11 CFR 1045(i) Overnight Mail Reports filed via overnight mail [FN1] will be considered timely filed if the report is received by the delivery service on or before the mailingfiling deadline A com-mittee sending its reports by Priority Mail or Priority Express Mail or by an overnight deliv-ery service should keep its proof of mailing or other means of transmittal of its reports 52 USC sect 30104(a)(5) and 11 CFR 10019 and 1045(e) Other Means of Filing Reports sent by other meansmdashincluding first class mail and couriermdashmust be received by the FEC before the Commissionrsquos close of business on the filing dead-line 11 CFR 10019 and 1045(e) (If the deadline falls on a weekend or federal holiday such filers should plan accordingly and file reports by the close of business on the last business day before the filing deadline) Forms are available for downloading and printing at the FECrsquos website (httpwwwfecgovinfoformsshtml) and from FEC Faxline the agencyrsquos automated fax system (202501-3413) 48-Hour Contribution Notices A participating candidatersquos principal campaign committee must file a 48-hour notice each time it receives a contribution of $1000 or more between February 25 and March 12 2016 for the Special Primary and between May 19 and June 4 2016 for the Special Gen-eral Election 24- and 48-Hour Reports of Independent Expenditures Political committees and other persons must file 24-hour reports of independent expendi-tures that aggregate $1000 or more between February 25 and March 13 2016 for the Special Primary and between May 19 and June 5 2016 for the Special General This re-quirement is in addition to that of filing 48-hour reports of independent expenditures that (aggregate $10000 or more up to and including the 20th day before an election The 48-hour reporting requirement applies to independent expenditures that aggregate at or above $10000 prior to February 25 2016 for the Special Primary and prior to May 19 2016 for the Special General

Electioneering Communications The 30-day electioneering communications period in connection with the Special Primary Election runs from February 14 through March 15 2016 The 60-day electioneering com-munications period for the Special General Election runs from April 8 through June 7 2016 Disclosure of Lobbyist Bundling Activity Campaign committees party committees and leadership PACs that are otherwise required to file reports in connection with the special elections must simultaneously file FEC Form 3L if they receive two or more bundled contributions from any lobbyistregistrant or lobbyistregistrant PAC that aggregate in excess of the lobbyist bundling threshold during the spe-cial election reporting periods 11 CFR 10422(a)(5)(v) and (b) The lobbyist bundling disclosure threshold for calendar year 2015 is $17600 This thresh-old amount may increase in 2016 based upon the annual cost of living adjustment (COLA) As soon as the adjusted threshold amount is available the Commission will publish it in the Federal Register and post it on its website For more information on these requirements see the March 2009 Record See 11 CFR 11017(e)(2)

1 ldquoOvernight mailrdquo includes Priority or Express Mail having a delivery confirmation or an overnight service with which the report is scheduled for next business day delivery and is recorded in the servicersquos online tracking system (Posted 12162015 By Katherine Carothers) Photo Source nationalatlasgov Resources Ohio 8th District Special Election Prior Notice 2015 Reporting Dates Ohio 8th District Special Election Compliance Page Federal Register Notice [PDF]

Libertarian National Committee Inc v FEC (New)13

Van Hollen v FEC13

Stop Hillary PAC et al v FEC (District Court)13

FEC v Lynch (New)13

FEC v Johnson (215-cv-00439-DB) (District Court)13

CREW v FEC (15-cv-02038) (New)13

AO 2015-15 Website May Help Users Make Contributions to Federal Candidates13

AO 2015-11 App for Making Contributions by Rounding Up Purchases Made on Contributorsrsquo Credit Cards Permissible13

Pending Advisory Opinion Requests as of January 31 201613

Pending Advisory Opinion Requests as of December 31 201513

Commission Certifies Matching Funds for OrsquoMalley13

FEC Introduces Online Payment Option for Administrative Fines13

FEC to Host March 23 Webinar for Candidate Committees13

Lobbyist Bundling Disclosure Threshold Unchanged13

Coordinated Party Expenditure Limits Adjusted13

FEC to Host February 24 Webinar for Party Committees13

Check the Box to Report Memo Entries13

Reports Due in 201613

Ohio Special Election Reporting 8th District13

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 DEU 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 ESP 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 GRE 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HEB 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HRV (Za stvaranje Adobe PDF dokumenata najpogodnijih za visokokvalitetni ispis prije tiskanja koristite ove postavke Stvoreni PDF dokumenti mogu se otvoriti Acrobat i Adobe Reader 50 i kasnijim verzijama)13 HUN 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 ITA 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 JPN ltFEFF9ad854c18cea306a30d730ea30d730ec30b951fa529b7528002000410064006f0062006500200050004400460020658766f8306e4f5c6210306b4f7f75283057307e305930023053306e8a2d5b9a30674f5c62103055308c305f0020005000440046002030d530a130a430eb306f3001004100630072006f0062006100740020304a30883073002000410064006f00620065002000520065006100640065007200200035002e003000204ee5964d3067958b304f30533068304c3067304d307e305930023053306e8a2d5b9a306b306f30d530a930f330c8306e57cb30818fbc307f304c5fc59808306730593002gt13 KOR ltFEFFc7740020c124c815c7440020c0acc6a9d558c5ec0020ace0d488c9c80020c2dcd5d80020c778c1c4c5d00020ac00c7a50020c801d569d55c002000410064006f0062006500200050004400460020bb38c11cb97c0020c791c131d569b2c8b2e4002e0020c774b807ac8c0020c791c131b41c00200050004400460020bb38c11cb2940020004100630072006f0062006100740020bc0f002000410064006f00620065002000520065006100640065007200200035002e00300020c774c0c1c5d0c11c0020c5f40020c2180020c788c2b5b2c8b2e4002egt13 LTH 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 NLD (Gebruik deze instellingen om Adobe PDF-documenten te maken die zijn geoptimaliseerd voor prepress-afdrukken van hoge kwaliteit De gemaakte PDF-documenten kunnen worden geopend met Acrobat en Adobe Reader 50 en hoger)13 NOR 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 POL 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 PTB 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 RUM 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 RUS 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 SKY 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 SLV 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 SUO 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 SVE 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 TUR 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 UKR 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 ENU (Use these settings to create Adobe PDF documents best suited for high-quality prepress printing Created PDF documents can be opened with Acrobat and Adobe Reader 50 and later)13 gtgt13 Namespace [13 (Adobe)13 (Common)13 (10)13 ]13 OtherNamespaces [13 ltlt13 AsReaderSpreads false13 CropImagesToFrames true13 ErrorControl WarnAndContinue13 FlattenerIgnoreSpreadOverrides false13 IncludeGuidesGrids false13 IncludeNonPrinting false13 IncludeSlug false13 Namespace [13 (Adobe)13 (InDesign)13 (40)13 ]13 OmitPlacedBitmaps false13 OmitPlacedEPS false13 OmitPlacedPDF false13 SimulateOverprint Legacy13 gtgt13 ltlt13 AddBleedMarks false13 AddColorBars false13 AddCropMarks false13 AddPageInfo false13 AddRegMarks false13 ConvertColors ConvertToCMYK13 DestinationProfileName ()13 DestinationProfileSelector DocumentCMYK13 Downsample16BitImages true13 FlattenerPreset ltlt13 PresetSelector MediumResolution13 gtgt13 FormElements false13 GenerateStructure false13 IncludeBookmarks false13 IncludeHyperlinks false13 IncludeInteractive false13 IncludeLayers false13 IncludeProfiles false13 MultimediaHandling UseObjectSettings13 Namespace [13 (Adobe)13 (CreativeSuite)13 (20)13 ]13 PDFXOutputIntentProfileSelector DocumentCMYK13 PreserveEditing true13 UntaggedCMYKHandling LeaveUntagged13 UntaggedRGBHandling UseDocumentProfile13 UseDocumentBleed false13 gtgt13 ]13gtgt setdistillerparams13ltlt13 HWResolution [2400 2400]13 PageSize [612000 792000]13gtgt setpagedevice13

for practitioners the regulated community and the public alike Earlier this month the Commission released a new customizable download feature that allows users to quickly export summary level data in a readily understandable format Soon users will similarly be able to download transaction-level data regarding contributions and disbursements and new website features will be unveiled such as (i) an improved Commission calendar featuring filters subscriptions and automatic updates and (ii) improved access to Com-mission legal documents including regulations advisory opinions and enforcement and compliance matters Furthermore the FEC continues to expand its outreach programs to provide practitio-ners and the public with valuable compliance tips and up-to-date information regarding recent developments in campaign finance law The Commission will offer a series of day-long webinars for candidates parties and PACs along with workshops and regional con-ferences on election-year reporting requirements and other timely topics These pro-grams constitute a core component of the Commissionrsquos obligation to promote voluntary compliance Finally we would like to thank the employees here at the Commission for their hard work and dedication It is our hope that as a result of the efforts of Commissioners and staff 2016 will be an effective and rewarding year (Posted 02112016 By Chairman Matthew Petersen and Vice Chairman Steven Walther) Resources Meetings and Hearings Campaign Finance Disclosure Portal

Commission Elects Officers for 2016 At its open meeting of December 17 2015 the Federal Election Commission elected Mat-thew S Petersen as Chairman and Steven T Walther as Vice Chairman for 2016 Mr Pe-tersen has served once before as Chairman and twice as Vice Chairman Mr Walther too has previously served in both positions From 2005 until his appointment to the Commission in 2008 Mr Petersen served as Re-publican chief counsel to the US Senate Committee on Rules and Administration providing counsel on issues relating to fed-eral campaign finance and election admini-stration laws as well as the Standing Rules of the Senate Prior to that position Mr Petersen served as counsel to the US House of Represen-tatives Committee on House Administra-tion Mr Petersen was extensively involved in the crafting of the Help America Vote Act of 2002 (HAVA) and the House-Senate ne-gotiations that culminated in HAVAs pas-sage From 1999 to 2002 Mr Petersen specialized in election and campaign finance law at the law firm of Wiley Rein LLP in Washington DC Mr Petersen received his JD in 1999 from the University of Virginia School of Law where he was a member of the Virginia Law Review He graduated magna cum laude with a BA in philosophy from Brigham Young University in 1996 He also received an AS with high honors from Utah Valley University

Litigation

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Reporting

Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

FEC v Lynch (New)13

Public Funding

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Van Hollen v FEC13

FEC v Lynch (New)13

Public Funding

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Van Hollen v FEC13

FEC v Lynch (New)13

Public Funding

Compliance

Outreach

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Van Hollen v FEC13

FEC v Lynch (New)13

Public Funding

Compliance

Outreach

Reporting

Van Hollen v FEC13

FEC v Lynch (New)13

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Reporting

Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

FEC v Lynch (New)13

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Van Hollen v FEC13

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Van Hollen v FEC13

FEC v Lynch (New)13

Van Hollen v FEC13

FEC v Lynch (New)13

Van Hollen v FEC13

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Van Hollen v FEC13

FEC v Lynch (New)13

Van Hollen v FEC13

FEC v Lynch (New)13

Van Hollen v FEC13

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Documents

FEC Record January 2016Ellen L. Weintraub Staff Director: Alec Palmer Acting General Counsel: Daniel A. Petalas The FEC Record is produced by the Information Division, Office of Communications