Sue Rose, Founder and 

Managing Member

PoliticalMeetings.com

600 17th ST, 2800 S 

Denver, CO 80202

(202) 760-8961

Federal Election Commission

999 E St., N.W., Washington, 

DC 20463 

Reg: Advisory Opinion

01/16/2024

Pursuant to 2 U.S.C. § 437f, this letter requests an advisory opinion on the permissibility of a proposed

business plan pertaining to PoliticalMeetings.com LLC as deemed permissible by the Federal Campaign

Election Act of 1971 ("the Act"). PoliticalMeetings.com LLC was formed on 09/23/2019 with Sue Rose

as the sole member. Sue Rose currently manages and operates PolticalMeetings.com LLC. Please

consider that this proposed business plan includes a future conversion from a sole member Limited

Liability Company to a Limited Liability Limited Partnership. The Privacy Policy and Terms of Service are 

available to the public on the website at web domain address https://PoliticalMeetings.com. 

The PoliticalMeetings.com business plan is to provide subscribers the opportunity to donate to their

favorite political candidates and an option to donate $0.50 cents per month to a Non-profit

organization and a National Committee of a Political Party recognized by the Federal Elections 

Commission. Those people who subscribe to the PoliticalMeetings.com Platform will donate to at

least one favorite candidate and can access the nationwide database to learn about politics, public

policy, and the candidates competing in elections. The goal has always been to provide people with a

way to conduct research on political issues and to learn about candidates running in elections.

History of PoliticalMeetings.com:

During late Spring, 2018, while working as a Federal Contractor, Rose had the desire to provide

information on political issues and candidates to employees of corporations and the public. In early

2019, IntegrityLives, LLC was formed and PoliticalMeetings.com was listed as a registered Trade Name

and had one customer. The brand has been dormant since that time until now and on 9/22/2023,

PoliticalMeetings.com LLC (PM) was formed as its own entity within the State of Colorado and is on

record with the office of the Colorado Secretary of State as a Sole Proprietorship and taxed as such by 

the Internal Revenue Service. PM is a solution that can provide information to the public on meetings

about politics.

PROBLEM:

There has not been a national database with political meetings data available in our nation’s history.

Precinct meetings go unattended and public opinion isswayed by media outlets framing political news.

SOLUTION:

In-house data teams conduct research for meetings on the local, state, and national levels in the top

three largest counties of each state to locate meetings. PM publishes this information on our Platform.

The Subscriber is the Customer. 

1 For the purposes of this Advisory Opinion Request, the term “user” may refer to all visitors and subscribers who utilize the features on the 

mobile App or website. PoliticalMeetings.com LLC is the same as PoliticalMeetings.com and throughout this document can be referred to as PM, 

Where the word “candidate” is used, it means “Candidate Campaign Committee” or a legally formed entity according to campaign finance laws 

in the jurisdiction of the “Election Campaign.” Where the term “Campaign” is used, it is to indicate “Election Campaign” or other legal entity 

based on campaign finance laws.

Received by OGC on Feb. 1, 2024

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PM Business Model:

To provide subscribers with a way to donate to their favorite political candidates and benefit from our

database of political meetings.

FEATURES and ADVANTAGES

SUBSCRIBERS

• Increased awareness of public policy, government and the political candidates running for elected 

office.

• Have access to publicly known political meetings postings within their party affiliation.

• Support candidates with a $1 donation per month. 

• Receive Private Agenda Access to the candidates they donate to. 

• Option to support a National Committee of a Political Party recognized by the Federal Elections 

Commission and a short list of up to five Non-profit organizations focused on supporting the 

homeless population within the United States.

CANDIDATE

• No cost to the candidate.

• Provides written permission by completing a (Permission Slip.) SEE ADDENDUM “A”

• Candidates receive $1 per donor per month as a political contribution from the

Subscriber.

GOVERNMENT AND POLITICAL PROCESS 

• Increased precinct meeting attendance.

• Increased voter participation.

PM will verify that the user has one profile on the Platform by their email address and name on their 

verified method of payment. A legal identification card is not required.

USER TYPES:

1. Subscriber- The donor that agrees to a subscription rate of $2.98 per month which includes

$1 per month as a donation to a “Candidate” or “Campaign Committee” and has the option to

add to a donation of $0.50 cents to a Non-profit, and a National Committee of a Political 

Party recognized by the Federal Elections Commission.

2. Visitor- A visitor to the PM Platform who does not have login credentials and has access to 

general information and Basic Profiles only.

The following is a list of defini�ons and terms applicable to this document. 

TERMS: 

1. Pay Gateway Fee- A payment processing fee charged by a Pay Gateway Merchant such as PayPal, 

Stripe or other financial ins�tu�on who facilitates payment processing. 

2. Administra�ve Fee- The fee charged by Poli�calMee�ngs.com for the services it provides to cover 

administra�ve costs of the company.

3. PM Pla�orm- Poli�calMee�ngs.com website or mobile Applica�on and all other rela�ve 

components including servers that enables systems to store the data on poli�cal mee�ngs, 

candidates, subscribers, and other mee�ngs sponsors including all other informa�on available on 

the website or mobile App. The PM Pla�orm provides data through its database called the PM 

Database.

4. PM Database- All data listed within the Pla�orm. 

5. Subscribers- Customers of the PM Platform who subscribe to the PM Database and donate to

at least one candidate. 2

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6. Donee- the entity receiving the donations.

7. Donor- The individual making the donation who successfully completes and is qualified based on the 

requirements listed on the Online Donor Registration Form.

8. PM Customer- Subscribers who are Donors utilizing the PM Platform who successfully completed and 

are qualified based on the requirements listed on the Online Donor Registration Form. 

9. Subscription-An agreement between the user of the PM Platform and PoliticalMeetings.com to

provide a service monthly that automatically renews and is cancelable at any time.

10. Base Rate- The advertised rate to "get started" is currently at $2.98 per month which includes a 

donation of $1 to a political candidate who is eligible to receive donations through the PM 

Platform.

11. Subscription Rate- The amount charged in total monthly by PM to the Subscriber.

12. Basic Profile- A profile containing information about a candidate seeking elected office who we

publish to the Platform with general information that is found on public websites such as a 

candidate’s, Secretary of State, or the Federal Election Commission. General information such

as the political office the candidate is seeking and the contact information for the campaign

may be published. 

13. Enhanced Candidate Profile- The profile of a Candidate only visible to Subscribers. Three added 

features differentiate the Enhanced Candidate Profile from the Basic Profile, and they are:

a. A link to donate.

b. A link to content such as fundraisers and special events. 

c. A Dashboard where the campaign can track donations and run reports.

14. Private Agenda Access- access that Donors are provided by the Platform to meetings or events 

that are ordinarily not open to the public. 

15. Candidate Campaign Committee-: the Candidate Campaign Committee is the legally formed 

entity by whatever name is deemed appropriate and approved according to law as it pertains to 

“campaign finance” in the jurisdiction where the candidate running for elected office resides.

16. Campaign Donation- The amount of funds donated to the candidate. 

17. Campaign Finance- Rules and regulations by a governmental body as it relates to fundraising 

and how funds are handled in an election campaign.

18. Candidate’s Authorized Committee Representative- A representative who is appointed to 

conduct business on the Candidate Campaign Committee’s behalf.

19. Election Campaign- a time according to law that precedes an election when politicians try to 

persuade people to vote for them.

20. National Committee Donation- A National Committee of a Political Party recognized by the 

Federal Elections Commission.

21. Non-profit Org. Donation- The amount of funds donated to a Non-profit organization.

22. Services- The act of providing political meetings data electronically to Subscribers of the 

Platform.

23. Dashboard- Subscribers of PM are provided access to a private dashboard where they can see 

any names for candidates they support and are able to view records of donations made. 

24. Campaign Dashboard- A candidate who receives donations on the Platform will have a 

dashboard to login at any time to download reports and view donation records. 

PM Electronic Agreements:

 Permission Slip 

Electronic form (See Addendum “A”) signed by an authorized party on behalf of the Donee who is a

Candidate, Campaign Committee, Non-profit organization, or a National Committee of a Political Party

granting permission to publish the ‘private agenda’ for the benefit of Subscribers. The Permission Slip

will also request banking account or Pay Gateway details and permission to make automatic donation

deposits into the appropriate designated bank account. Step-by-step instructions and information 

about the process involving donation funds shall be provided and contact information for any questions 

or concerns. 3 

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The Permission Slip will require an attestation by the election campaign that: 

1. The campaign acknowledges it is the responsibility of the campaign to examine all

contributions received for evidence of illegality and compliance with the FEC and any

other applicable governing body.

2. When the election is over it will notify PM to remove its Enhanced Candidate Profile.

Online Subscription Registration Form- Form accessible on the PM Platform where a user enters into 

an agreement to subscribe for services. The Form shall comply with FEC regulations and include the 

disclaimer that contributions must comply with the federal limits and prohibitions and is not from a 

prohibited source. PM will require each Subscriber to confirm certain statements are true and 

accurate. See page 8 for the detailed list.

PM Online Donor Registration Form – The form that is automatically generated when a Subscriber 

on the PM Platform is donating to a candidate requiring answers to specific questions as required by 

law and then enabling prompts to choose party affiliation, the candidate campaign committee 

name, and an option to donate (currently $0.50 cents) to a National Committee of a Political Party, 

and a choice of Non-Profit Organizations.

PM Access

Private Agenda Access- access that Donors are provided by the Platform to meetings or events that 

are ordinarily not open to the public and are by invitation specifically for donors of any eligible 

“Meeting Sponsor.” Eligible PM Meetings Sponsors are defined below and according to the 

PoliticalMeetings.com Terms and Conditions.

PM Meeting Sponsors

1. Candidate- A person who is running for elected office and appears on a candidate list released 

by the government elections agencies.

2. Campaign Committee- The political campaign committee designated by a candidate for 

Congress as the candidate's principal campaign committee for purposes of the Federal Election 

Campaign Act (2 U.S.C. § 432(e)).

3. Prospective Candidate- A declared candidate is someone who has not taken steps to become an 

official candidate.

4. Political Action Committee- An organization whose purpose is to solicit and make political 

contributions.

5. Political Committee- Any committee, club, association, or other group either formerly organized 

or not.

6. State Party Committee- A committee with an official party structure by virtue of the bylaws of a 

political party or by the operation of the state law who has at least one candidate for federal 

office whose name appears on the ballot as a candidate of the committee and that has an 

agreement with the political party to perform activities commensurate with the day-to-day 

operation of the party at the state level.

7. Non-profit organizations- An organization who has completed one IRS 990 form and is in active 

status.

8. Political based groups or clubs- A group of five or more individuals whose purpose is to discuss 

political topics and who operate within the bounds of the law of the respective local and state 

and the federal government.

9. Political Party Committee- Political Party Committees that are organized on the County, State or 

Federal level.

10. Registered Political Party- An organized group who is qualified according to state law in their 

state according to the Secretary of State’s office (or equivalent.) 4

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Meetings

1. Political Meeting- political meeting means a meeting for the purpose of discussing the 

performance of the government, a local authority, or the program of any political party or for 

the purpose of supporting or opposing the candidature of any individual as against any other or 

others at an election.

2. Open Meeting or Public Meeting is a meeting at which the public may be present.

3. Kick-off meetings- The first meeting with the project team members.

4. Quarterly meetings- Meetings are held once every three months.

5. Fundraising Meeting- Meeting to discuss all aspects of fundraising.

6. Fundraising Events- An event created with the objective of raising donations for a political 

campaign or charitable cause.

7. Candidate Meet and Greet- An event especially orchestrated to introduce a political candidate 

to public citizens.

8. Precinct Meetings- Precinct caucuses are neighborhood-level meetings hosted by the 

Democratic and Republican Parties in advance of a Primary Election. The precinct is the smallest 

subdivision of the county.

9. Private Agenda- Meetings or events not otherwise open to the public.

10. Team Building- A meeting you call to build bonds or facilitate collaboration among team 

members.

The Payment Process

Only Subscribers have Private Agenda Access to those Enhanced Candidate Profiles on the PM Platform.

Subscribers donate $1 to at least (1) candidate when they subscribe at the current subscription rate

of $2.98 per month. An Administrative Fee of $1.98 and one (1) Donation of $1 (One USD) is included

within the subscription rate of $2.98 and subsequent donations are added. The Subscriber can donate 

up to (3) candidates without incurring another Administrative Fee of $1.98.

Subscribers have access to the PM Database where they can search for meetings posted by “meetings

sponsors” listed by candidate's name, state, entity name or ‘key word’ within the same party affiliation.

 

 

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Subscribers may donate to as many candidates as they want. PM will monitor for suspicious activity and

will act based on any situation that may arise according to law. The Subscriber does not incur additional

fees from PM if they do not donate to more than three candidates and a choice of one non-profit

organization or National Committee of a Political Party as recognized by the Federal Elections 

Commission. Please note the figure above demonstrates how when the number of candidates supported

increases to over three candidates, the subscription rate increases. The Subscriber pays for Pay Gateway

fees on any subscription that is more than $3.48 excluding taxes. PayGateway fees are determined by the 

entity providing the payment processing service. PM may switch to ACHservices provided directly through a major 

bank such as Wells Fargo in the future if rates are more affordable and the speed with which transactions occur are 

more prompt. Current Pay Gateway fees are 2.9% + .30 cents per transaction. PM will not profit by adding any 

amountto a Pay Gateway fee. Subscribers will only pay the cost associated with the transaction according to the 

terms. Subscribers may cancel at any time by contacting the office by email, telephone, or electronic

form; however, it is recommended that the Subscriber cancel by email or electronic form so that the

cancellation is in writing. Visitors on the Platform have access to free information including the basic 

profiles of political candidates, news, nonprofit listings, or other information. Visitors are not Subscribers

and are not required to complete a Subscription Registration Form and have limited access.

BANK CASH FLOW:

Below is an explanation of how the bank accounts will function. Funds for Candidates, Non-profits, or a 

National Committee are all automatically diverted to the account holders for the respective entities

upon payment by the Subscriber/Donor.

Contribution and Payment Processing for PM:

The donation of $1 is paid directly through the Platform utilizing a Pay Gateway such as Stripe. PM may in the 

future utilize Straight Through Processing technology which would allow funds to flow straight through to the 

appropriate bank account while avoiding the use of a third party such as a Pay Gateway. In any case, the donation 

is split so that PM’s bank account does not receive donor funds as the donations are directly deposited into the

designated Candidate Campaign Committee, (Donee) bank account. The remaining $1.98 is directed to

the PM.com Subscription Account. Should the Subscriber/Donor opt to donate $0.50 cents to a National 

Committee of a Political Party or a Non-profit charity, the funds donated will be directed straight into

the respective entity’s bank account through the Platform. Should there be an issue with compatibility of

systemsthat causes problems with a valid automatic fundstransfer, fundsshall be released to the donee

within two (2) business days by electronic wire. The Candidate Campaign Committees, Non-profits, and 

National Committee shall have real-time access to all activity including donations, errors or returns so that

all matter of record is made visible and can be audited at any time.

The funds paid to PM cover the cost of doing business to include data research, payroll, accounting, legal,

office and other expenses arising in the normal course of work on a day-to-day basis. Currently, PM uses

Stripe Pay Gateway for transaction processing.

We do not accept donations on behalf of candidates. Should an error occur where funds were

inadvertently deposited into PM bank account, the error would be corrected, and the funds

returned to the Donor or the Donee within two (2) business days. The Donor or the Donee would be

notified of the error and provided any instructions necessary to remedy the situation. 

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Bank Account #1 - PM Subscription Account-Gross Subscription Fees minus donations

Bank Account #2 - PM Operating Account-Once the Subscriptions Account is reconciled, funds

are transferred here for company use.

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The Donee is not a client or customer of PM.

Without the permission of the Donee, PM cannot provide a method to donate directly through the PM

platform. 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. 

 Example Situa�on PM

A Visitor to the PM Pla�orm realizes that although they can learn about publicly held mee�ngs, they do 

not have access to private informa�on and cannot donate to one of their favorite candidates. A Visitor 

contacts our office to find out how to donate to their favorite Candidate. PM has a Basic Profile on the 

Candidate which was set up as a mater of regular process and was visible to Visitors and other 

Subscriber/donors. A�er the Visitor contacted the office, administra�ve personnel called the 

candidate’s campaign to advise that a Visitor to the PM Pla�orm would like to u�lize the pla�orm while 

dona�ng to the campaign. The elec�on campaign's designated representa�ve follows through by 

comple�ng a Permission Slip gran�ng PM permission to publish specified mee�ngs that will be provided 

to Subscribers of PM who are Donors to the Candidate or Campaign Commitees. The Visitor is then 

directed to register for access by comple�ng the Online Subscrip�on and Donor Registra�on Forms. If 

the Subscriber answers a ques�on which causes them to be ineligible as a donor, the pla�orm will not 

allow him to proceed, and will state the reason for the error and refer the Subscriber to a customer 

service telephone number and email address.

Upon comple�ng the Online Subscrip�on and Donor Registra�on Forms, the Subscriber will be able to 

login and will be instructed to create a unique password. Our Pla�orm will u�lize HTTPS which is the 

most secure way to transmit subscriber creden�als since the subscriber’s creden�als are encrypted 

before being sent. If Subscriber checks a box and answer any ques�ons on the electronic form which 

causes them to be ineligible to donate according to the Federal Elec�on Campaign Act, the system will 

not allow Subscriber to proceed. Should a Subscriber show inappropriate behavior or ac�ons, we may 

catch an impropriety at some point and if we do, we will immediately disable the account, no�fy the 

(would-be) Subscriber, and no�fy the campaign. 

The Subscriber must complete the Online Subscrip�on and Donor Registra�on and Forms and 

acknowledgment that $1 per month will automa�cally route to Candidate’s campaign as a contribu�on 

to the campaign each month the transac�on is completed successfully. The Subscriber completes the 

transac�on for $2.98 or the amount which corresponds with the number of candidates supported and 

any added dona�on to a Non-profit, a Na�onal Commitee of a Poli�cal Party. The subscrip�on will 

automa�cally renew monthly. The Subscriber understands that they can cancel at any �me. PM will 

cover any Pay Gateway fees for charges that do not exceed $3.48 excluding taxes (Three Dollars and 

48/100s,) and these will not be passed on to Subscriber. Subscriber is the “Customer” and the funds 

that Subscriber pays excluding the dona�on are specifically for the mee�ngs data and overhead of PM 

that Subscriber u�lizes. 

Candidate’s Authorized Commitee Representa�ve Perspec�ve: 

Before the Visitor can donate to an Elec�on Campaign or learn about and other mee�ngs that otherwise 

may have been deemed exclusive for donors of the campaign through the PM Pla�orm, the Candidate 

must upgrade the Basic Profile to an Enhanced Candidate Profile by comple�ng a Permission Slip. The 

only difference between a Basic Profile and Enhanced Profile is that the Candidate is voluntarily 

providing the data necessary for the PM Pla�orm to facilitate dona�ons to its campaign on behalf of our 

subscribers and by doing so commits to providing by email on a regular basis a list of special events that 

are only for donors to the campaign. 

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The PM Database will make those mee�ngs and invita�ons available exclusively to those who donate to 

the respec�ve candidates that have the Enhanced Profile. Administra�ve personnel with PM emails or 

provides instruc�ons via telephone to the Candidate Campaign Commitee where to locate the on-line 

Permission Slip. Upon comple�on of the Permission Slip, the Prospec�ve Candidate is converted to an 

Enhanced Candidate Profile and will be provided instruc�ons on se�ng up the Pay gateway or other 

system used to facilitate dona�ons, instruc�ons on how to access the dashboard, a commitment to 

cooperate and other general terms and condi�ons. There is no cost to the Candidate. 

 

• Candidates can invite voters to par�cipate with PM’s Pla�orm and can share their profile. 

• Candidate does not have any control over the informa�on on the campaign’s page and would 

be required to complete a form or email PM with any informa�on it would like published or 

informa�on on mee�ngs or fundraisers. 

• Candidates would be able to share a link to its website which would likely have a dona�on 

buton. This is not a problem for PM since we have already earned our fee from the user.

• Any person who wants to donate to the Candidate may do subject to government law and FEC 

Regula�ons.

Pla�orm Security Measures 

We require loca�on monitoring and do not allow access on our mobile App from outside of the United 

States to unknown new visitors. A visitor to the Pla�orm within the United States who successfully 

subscribes to the Pla�orm becomes a Subscriber and will have access outside of the United States by 

u�lizing their account login creden�als. Those who atempt accessing the site as a visitor outside of the 

United States will not have access. We would be monitoring the Pla�orm on the website and mobile 

App daily and would most o�en be alerted to any cause for concern which would be reported to the 

appropriate authori�es for appropriate ac�on. 

Online Subscrip�on and Donor Registra�on Form disclosures: 

• Federal Elec�on Campaign Act requires candidates and other poli�cal commitees to use best 

efforts to report that informa�on for contribu�ons aggrega�ng over $200 in a calendar year 

from the contributor to that candidate, and that the informa�on, once reported is made public 

on the Commission’s website.

• Each contribu�on made through PM must be aggregated with all other contribu�ons made by 

the User to that candidate and that aggregate must be less than (legal contribu�on rate) per 

elec�on.

PM will verify the legal contribu�on limits per cycle and office held when applicable. We realize that this 

is an important record keeping aspect to comply with Federal, State and any local regula�ons. 

PM Online Donor Registra�on Form has required atesta�on by the Subscriber that they are providing 

the following informa�on and that it is true and accurate:

1. Legal name

2. Mailing address

3. Occupa�on and Employer

4. Whether or not they are a federal contractor

5. Atest whether they are a US ci�zen or legal permanent resident

6. That they are using their own personal funds to make the contribu�on and not using funds given to 

them by another person for the purpose of contribu�on

7. That they are using their own credit card and not a corporate or business card, or a card issued to 

another person

8. That they are over the age of 18 and they are not a minor

9. That the contribu�on is not being made at the request or direc�on of another individual 8

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The PM Pla�orm provides encryp�on which hides all sensi�ve informa�on from our database including 

passwords and credit card or other informa�on used in making payments. Thank you so much for your 

time and efforts in reviewing this request for an Advisory Opinion. 

Sue Rose

Founder 

 

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Advisory Opinion Request (FEC) 11/16/2023 Addendum A

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