FEDERAL ELECTION COMMISSION

Washington, DC 20463

MEMORANDUM

TO:

FROM:

DATE:

SUBJECT:

The Commission 

Office of the Commission Secretary 

March 25, 2024

AOR 2024-03 (politicalmeetings.com) Supplemental Material

requested from Commissioners

Attached is AOR 2024-03 (politicalmeetings.com) Supplemental 

Material requested from Commissioners. This will discussed at the 

Open Meeting of March 27, 2024.

Attachment 
From: Sue Rose

To: Cheryl Hemsley

Cc: Neven Stipanovic; Robert Knop

Subject: RE: AOR 2024-03 (PoliticalMeetings.com) further information requested by Commissioners

Date: Monday, March 25, 2024 12:38:01 PM

Hi Cheryl, please see below.

Sue

From: Cheryl Hemsley

Sent: Friday, March 22, 2024 4:42 PM

To: Sue Rose

Cc: Neven Stipanovic; Robert Knop

Subject: AOR 2024-03 (PoliticalMeetings.com) further information requested by Commissioners

Sue,

We have been asked by one or more Commissioners to ask you these questions regarding your

advisory opinion request on behalf of PoliticalMeetings.com.

1. On page 7 of the request, it states that “if PM receives an enquiry from a Visitor or Subscriber

who wants to donate to a candidate, PM will contact the Candidate Campaign Committee. If

the Candidate Campaign Committee agrees to participate, PM will email instructions on how

to complete the Permission Slip allowing PM to proceed with the process as described.”

What if the Candidate Campaign Committee agrees to provide the necessary information to

process the transaction (e.g. bank account information for direct deposit), but does not want

to otherwise “opt in” to the terms of the Permission Slip?

In that case, their answer would be a “no” and we would then notify the Visitor or Subscriber

that the Candidate is not cooperating with PM and that we cannot facilitate their request.

How will PM.com decide which committees to contact for the purpose of asking them to opt-in

to program? Our plan is to involve as many committees, candidates and those identified as

eligible sponsors as possible in several ways. One plan is to reach out to the public by having

tables at major shopping centers and malls to sign up subscribers and talk to those interested in

Subscribing which is where PM can learn who each person wants to support, and that is one

way, PM can be charged with the task of contacting the campaign unless the campaign has

already provided permission. The calls from potential Subscribers and Subscribers to candidates

will be based on their requests. We will also make an effort to call on all campaigns equally aside

from individual requests since the success for our Subscribers is that we provide the most robust

and fully developed source of information possible on politics, the issues at hand on all

candidates running for office. 

2. On page 4 of the request it states that donors will have “Private Agenda access,” described as

“access that Donors are provided by the Platform to meetings or events that are not ordinarily

open to the public and are by invitation specifically for donors” of an eligible Meeting

Sponsor. On page 3, it states that the Enhanced Candidate Profile will include “a link to

Received by OGC on Mar. 25, 2024
content such as fundraisers and special events.” Will either the Enhanced Candidate Profile

or the Private Agenda Access include links to a committee’s solicitations for fundraisers or

links that will allow the Subscriber to directly RSVP to the event and make any required

contribution to attend?

Or will it just provide , for example, the date and name of the event, such that a subscriber

would need to contact the committee directly to receive an invitation or to register for the

event?

There can be direct links to contribute to a campaign or to RSVP. There will be links to

fundraising events or other special events like a private meet & greet or other meetings such as

meetings focused on building a team of volunteers for the campaign, etc. The website page by

the campaign or candidate that is advertising or asking for registration to an event may have a

link to donate.

3. On page 3 of the request it states that the Enhanced Candidate Profile will include “a link to

donate.” Will this be a link to a donation page on PM’s website, or will this link to the

committee’s website or the committee’s ActBlue/WinRed page? If the campaign provides us

the link to ActBlue or WinRed, we will add that link. Will this be the only way for a subscriber

to make a contribution? In other words, would making a contribution through the link on the

Enhanced Candidate Profile be different from the contributions that a Subscriber makes as

part of their subscription fee? Yes, we will only facilitate the $1 donation per subscriber per

month for as long as the Candidate is legally able to solicit donations. PM will not have any

other method to facilitate a donation.

4. On page 8 of the request it states that once a Prospective Candidate completes the

Permission Slip, they will receive additional information including “a commitment to

cooperate and other general terms and conditions.” What is this commitment to cooperate?

Is this something else that candidates must agree to? It is not separate agreement. The

commitment to cooperate means that the candidate or candidate’s legal representative must

provide information on meetings or events that are not open to the general public so that the

Subscriber is benefitting from access to their Enhanced Profile.

Your response to this email may be considered a supplement to the advisory opinion request and

posted on the Commission’s website.

Best regards,

Cheryl Hemsley

Attorney

OGC/Policy

Federal Election Commission