July 2010 Federal Election Commission Volume 36, Number 7

Table of Contents

(continued on page 8) (continued on page 2)

Reports

1 July Reporting Reminder

9 FEC Form 3L Due in July

 

1 Advisory Opinions

 Court Cases

10 The Real Truth About Obama, Inc. 

v. FEC and U.S. Department of 

Justice

11 SpeechNow.org v. FEC

11 U.S. v. O’Donnell

 Nonfilers

12 Committees Fail to File PreElection Reports

13 Index

 

Reports Advisory 

Opinions

AO 2010-05

Sale of Ad Time on a 

Foreign-Owned Television 

Station

Starchannel Communications, 

Inc. (Starchannel), the domestic 

representative of Televisa, a Mexican 

broadcasting corporation, may sell 

advertising time on Televisa television stations to federal candidates. A 

prohibited contribution would not result from offering federal candidates 

the “Lowest Unit Charge” (LUC) for 

time slots on Televisa since it is the 

usual and normal charge for similar 

federal candidate advertisements in 

the market in which the advertisements will be aired.

Background

Starchannel is a Delaware corporation that sells advertising time 

slots on television broadcast stations 

in Mexico that are owned by Televisa. The broadcast stations that carry 

these ads broadcast into markets in 

areas of Texas that are located on 

the border between the United States 

and Mexico (“U.S. border market”). 

Through a contractual agreement, 

Starchannel acts as the exclusive 

representative of Televisa in the 

sale of advertising time in the U.S. 

border market. The contract states 

July Reporting Reminder

The following reports are due in 

July:

•	 All principal campaign committees of House and Senate candidates must file a quarterly report 

by July 15, 2010. The report covers financial activity from April 1 

(or the day after the closing date 

of the last report) through June 

30;

•	 Principal campaign committees

of Presidential candidates must 

file a report by July 15, if they are 

quarterly filers (the report covers 

financial activity from April 1 

through June 30), or by July 20, 

if they are monthly filers (the report covers activity for the month 

of June); and

•	 National party committees, political action committees (PACs) following a monthly filing schedule 

and state, district and local party 

committees that engage in reportable “federal election activity” 

(see “State, District and Local 

Party Committees, on page 9) 

must file a monthly report by July 

20. This report covers activity for 

the month of June. 11 CFR 104.5.

Notification of Filing Deadlines

In addition to publishing this 

article, the Commission notifies 
Federal Election Commission RECORD July 2010

2

Federal Election Commission

999 E Street, NW

Washington, DC 20463

800/424-9530 (Toll-Free)

202/694-1100 (Information Div.)

202/501-3413 (FEC Faxline)

202/219-3336 (TDD for the

 hearing impaired)

Matthew S. Petersen, 

 Chairman

Cynthia L. Bauerly, 

 Vice Chair

Caroline C. Hunter, 

 Commissioner

Donald F. McGahn II, 

 Commissioner

Steven T. Walther,

 Commissioner

Ellen L. Weintraub, 

 Commissioner

Alec Palmer,

 Acting Staff Director

Thomasenia Duncan, 

 General Counsel

Published by the Information

 Division of the Office of 

 Communications

Greg J. Scott, 

 Assistant Staff Director

Amy L. Kort,

 Deputy Assistant Staff Director

Myles G. Martin, 

 Editor

http://www.fec.gov

Advisory Opinions

(continued from page 1)

(continued on page 3)

that Starchannel may not negotiate 

a price with a buyer for an advertising time slot that is lower than the 

Televisa-established minimum price, 

but it may negotiate higher prices. 

The two corporations are independent of each other and Televisa 

does not exercise any ownership or 

control over Starchannel.

Starchannel wishes to expand its 

business by selling advertising time 

slots on Televisa’s broadcasting stations to federal candidates. Starchannel plans to offer federal candidates 

the LUC for time slots on Televisa. 

Starchannel does not believe it is required to offer federal candidates the 

LUC because Televisa is a Mexican 

corporation.1 Nevertheless, Starchannel plans to offer the LUC because, 

in its business judgment, it could not 

otherwise compete with American 

television stations that offer advertising time to federal candidates at the 

LUC. Starchannel plans to require 

federal candidates to comply with 

all paperwork, disclaimer and other 

requirements of the Communications 

Act and Federal Communications 

Commission regulations, just as if 

the ads were being run on a U.S. 

station.

Analysis

The Federal Election Campaign 

Act (the Act) and Commission 

regulations prohibit foreign nationals, including foreign principals 

such as partnerships, associations, 

corporations, organizations or other 

combination of persons, from making a contribution or donation of 

money or other things in connection 

with a federal, state or local election. 2 U.S.C. §441e(a)(1)(A) and 22 

U.S.C §611(b)(3); see also 11 CFR 

110.20(b). The Act also prohibits 

corporations from making contributions in connection with any federal 

election. 2 U.S.C. §441b(a).

Any gift, subscription, loan, 

advance or deposit of money or 

“anything of value” made by any 

person for the purpose of influencing a federal election is a “contribution.” 2 U.S.C. §431(8)(A)(i) and 

11 CFR 100.52(a); see also 2 U.S.C. 

§441b(b)(2) and 11 CFR 114.2(b)

(1). “Anything of value” includes 

goods or services provided without 

charge or at less than the “usual and 

normal charge.” 11 CFR 100.52(d)

(1). “Usual and normal charge” 

means the price of 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 100.52(d)(2). 

Based on the information provided by Starchannel, the Commission 

concluded that it does not appear 

that Televisa would be providing 

any goods or services at less than 

the usual and normal charge. Under 

Televisa’s contract with Starchannel, Televisa establishes a minimum 

price for advertising time that does 

not depend upon the identity of the 

buyer. Because Televisa’s role in the 

sale of advertising time remains the 

same and conforms to its usual and 

normal business practices regardless of the buyer’s identity, Televisa 

would not be making a contribution 

under the plan.

With respect to Starchannel, the 

Commission noted that Starchannel plans to offer advertising time 

to federal candidates using the 

same business practices in which it 

customarily engages when offering 

advertising time to other customers, 

except that it plans to offer federal 

candidates the LUC even if it is not 

required to do so under 47 U.S.C. 

§315(b) and 47 CFR 73.1942.

The Commission concluded that 

Starchannel may sell advertising 

time on Televisa stations to federal 

candidates at the LUC, consistent 

with the Act and Commission 

regulations, under the specific facts 

present here. Because Starchannel 

plans to offer the LUC only to federal candidates who comply with all 

relevant requirements of the Communications Act, these federal candidates would be entitled to receive 

the LUC from a U.S. broadcaster 

for advertisements airing in the U.S. 

border market, even if Starchannel is 

not required to offer them the LUC. 

Thus, the LUC reflects the usual and 

normal charge for Communications 

Act-compliant candidate advertising 

in the U.S. border market. 11 CFR 

100.52(d). Further, the LUC represents the commercially reasonable 

1 The Communications Act sets certain 

requirements for U.S. broadcasters 

providing advertising time to federal 

candidates. See 47 U.S.C. §315 and 47 

CFR 73.1942.
July 2010 Federal Election Commission RECORD

3

Advisory Opinions

(continued from page 2)

(continued on page 4)

FEC Record to Become a News Site

 In an effort to provide more timely and user-friendly information, the FEC 

Record will transition this summer from a print-based online publication to 

a wholly web-based format that better utilizes the medium. We’re excited to 

improve this already useful resource in a way that will help our readers keep up 

with FEC-related news even better than before.

 Converting the Record into a continuously updated news site will allow us to 

provide campaign finance information in a more timely and responsive manner, 

adding stories as regulations are approved, advisory opinions are issued and 

court cases are decided. We will be able to add links within articles that point to 

related resources, including audio of Commission meetings, advisory opinion 

documents, Federal Register notices and helpful web-based training materials 

devoted to new or complex areas of the law.

 The new Record will be more searchable than the old PDF version, with a 

custom search bar for the site providing more useful results. The categories 

and tags we’ve added will make browsing and navigating the Record faster 

and more convenient than before, and you will be able to subscribe to the RSS 

feed to receive automatic updates as stories are posted. We look forward to our 

transition this summer and hope you’ll let us know how we can continue to 

improve and better serve our readers.

rate prevailing for ads complying 

with the Communications Act at the 

time the ads are broadcast. 11 CFR 

100.52(d)(2). Thus, Starchannel also 

would not be making a contribution 

under the plan by charging the LUC.

Accordingly, the Commission 

ruled that no contribution would 

result from the sale of advertising 

time to federal candidates on behalf 

of Televisa at the LUC rate for ads 

that comply with the Communications Act.

Date issued: May 27, 2010;

Length: 6 pages.

—Stephanie Caccomo

AO 2010-06

Political Affinity Accounts 

for Revenue-Generating Web 

Platform 

Famos LLC, a for-profit limited 

liability company marketing a webbased platform (Famos Platform) 

that allows users to receive compensation from personal endorsements 

of products and services, may allow 

political committees to obtain a 

political affinity account and receive 

contributions from other individual 

platform users without making a 

prohibited corporate contribution.

Background

The Famos Platform will allow 

users to receive compensation from 

personal endorsements of products. 

For example, if a Famos account 

holder sends an e-mail to a friend 

recommending a movie, the Famos 

Platform may direct the friend to 

a website selling tickets for that 

movie. When Famos receives a 

commission from that website for 

directing the account holder’s friend 

to purchase a movie ticket, Famos 

will share some of that revenue with 

the account holder. 
Federal Election Commission RECORD July 2010

4

Advisory Opinions

(continued from page 3)

(continued on page 5)

FEC Accepts Credit 

Cards

 The Federal Election 

Commission now accepts 

American Express, Diners Club 

and Discover Cards in addition 

to Via and MasterCard. While 

most FEC materials are available 

free of charge, some campaign 

finance reports and statements, 

statistical compilations, indexes 

and directories require payment.

 Walk-in visitors and those 

placing requests by telephone may 

use any of the above-listed credit 

cards, cash or checks. Individuals 

and organizations may also place 

funds on deposit with the office 

to purchase these items. Since prepayment is required, using a credit 

card or funds placed on deposit 

can speed the process and delivery 

of orders. For further information, 

contact the Public Records Office 

at 800/424-9530 or 202/694-1120.

The Famos Platform, like nearly 

all contemporary web-based marketing platforms, will be offered free 

of charge to prospective account 

holders. Famos and its account 

holders may earn and share revenue 

from three types of transactions: 

web searches, web shopping and 

online referrals. Famos plans to 

keep twenty percent of any revenue 

generated in the three types of transactions, with the remaining eighty 

percent shared by the rest of the 

“referral path.” 

Famos plans to offer the Famos 

Platform to political committees, 

including authorized committees, 

nonconnected committees and 

party committees, but excluding 

separate segregated funds. Famos 

will offer its platform to political 

affinity account holders on much 

the same terms as to other account 

holders: free of charge, with a $200 

per hour customization rate for 

non-standard customizations to their 

Famos Platform. Political affinity 

account holders will need to make 

certain non-standard customizations 

to comply with the Federal Election 

Campaign Act (the Act). 

Famos account holders will be 

able to keep their share of revenue 

or direct it (or any portion of it) to 

a charity or non-profit organization 

that also holds a Famos account. 

Famos will not distribute revenue 

shares to account holders or designated non-profit entities until their 

account balance is above ten dollars. 

Political affinity account holders 

will be removed from the revenue 

generating chain, with any revenue 

generated being passed down to the 

next account holder or entity in the 

referral path. 

Famos account holders may have 

their share directed to political affinity account holders, just as they can 

to other non-profit or charity account 

holders. 

Famos account holders will have 

to make the following certifications 

as described in AO 1995-09: that 

they are making the contribution 

from their own funds and not those 

of another; that the contributions are 

not from the general treasury funds 

of a corporation, labor organization 

or national bank; and that contributors are not federal government 

contractors or foreign nationals who 

lack permanent resident status in the 

United States.

Famos account holders will be 

informed that federal law requires 

the political affinity account holders 

to use their best efforts to collect and 

report the name, mailing address, 

occupation and name of employer of 

each individual whose contributions 

exceed $200 in a calendar year.

Famos asks if it may enter into 

the proposed program with political 

committees without making prohibited corporate contributions.

Analysis

Famos may enter into the proposed program because it would not 

violate the prohibition against corporate contributions. In prior advisory 

opinions, the Commission has examined a number of business arrangements between political committees 

and service providers that were 

either affinity programs or similar to 

affinity programs. In these advisory 

opinions, the Commission indicated 

that the Act permits corporations 

to offer affinity programs and enter 

into affinity-type business arrangements so long as the corporation and 

political committee enter into a commercially reasonable transaction in 

which the political committee pays 

the usual and normal charge for any 

services provided, and the amounts 

contributed to political committees via rebates or rewards are from 

individual customers’ funds and 

not corporate funds. AOs 2006-34, 

2003-16 and 2002-07.

Because nearly all web-based 

platforms now offered in the marketplace are made available free of 

charge, Famos may provide its basic 

platform free of charge to political 

affinity account holders as part of 

its standard practice. In exchange, 

Famos would receive the value of 

the political affinity account holders’ marketing services. Because 

each additional user of the Famos 

Platform may potentially produce 

revenue for Famos as well as generate possible future contributions for 

the political affinity account holder, 

the provision of the Famos Platform 

in exchange for the political affinity 

account holder’s promotion of the 

Famos Platform would represent a 

commercially reasonable transaction made in the ordinary course of 

business. AOs 2007-04, 2004-19, 

1995-34 and 1994-33. 

Political affinity account holders 

would be required to pay the usual 

and normal charge for any customization of the platform, an “industry 

rate” charged to other Famos account holders of $200 per hour for 

customization beyond the basic options provided as part of the political 
July 2010 Federal Election Commission RECORD

5

Advisory Opinions

(continued from page 4)

(continued on page 6)

AO 2010-07

Members of Congress May 

Solicit Funds for State Ballot 

Measure

Members of Congress may solicit 

funds on behalf of a state ballot measure in the state of California outside 

the amount limitations and source 

prohibitions of the Federal Election 

Campaign Act (the Act) during the 

period before the initiative qualifies 

for the ballot. After the initiative 

qualifies for the ballot, Members of 

Congress may solicit funds within 

the amount limitations and source 

prohibitions of the Act and may also 

solicit up to $20,000 from individuals on behalf of the state ballot 

measure. The Commission was unable to agree on whether, during the 

post-qualification period, Members 

of Congress may solicit donations of 

more than $20,000 and from persons 

other than individuals.

affinity account holders’ setup and 

administrative page. Because Famos 

will not provide necessary customizations for free or at a reduced rate, 

the provision of those services will 

not result in a prohibited in-kind 

contribution. 11 CFR 100.52(d)(1).

The Commission has concluded 

in previous advisory opinions that 

any contributions from rebates or 

rewards must be made by individuals from their own funds and not 

by the corporate service provider. 

In general, the Commission has 

concluded that affinity programs in 

which a corporation transfers to a 

political committee a portion of the 

revenue collected result in a prohibited corporate contribution. AOs 

2008-18 and 2003-16. However, the 

Commission has concluded that it 

is permissible for affinity programs 

to generate revenue in the form of 

rebates or rewards to individuals, 

who may then choose to pass their 

earned revenue to political committees who are affinity partners. AOs 

2006-34 and 2003-16. Because the 

revenue in these programs was offered to individuals in the ordinary 

course of business, the revenue was 

the property of the customer or individual who controlled the direction 

of the revenue.

The remittances at issue in this 

instance would be offered in the 

ordinary course of business, with 

individual Famos account holders 

directing the disposition of their 

revenue shares. Famos will inform 

account holders of the appropriate 

requirements of the Act, requiring 

the certifications described in AO 

1995-09. Additionally, Famos’s plan 

to credit account holder-confirmed 

contributions to political committees 

through an automated clearinghouse 

transaction on the last day of each 

month in which the remittance is 

earned complies with the requirement that any person who receives 

a contribution of $50 or less for a 

political committee must forward the 

contribution to the political committee within thirty days of receipt. 

2 U.S.C. §432(b)(2)(A); 11 CFR 

102.8(b)(1). Because the account 

holder does not make a contribution 

until Famos sends a separate confirmation note to the account holder 

that Famos intends to distribute to 

the political affinity account holder, 

the plan complies with the requirement that contributions to authorized 

political committees be forwarded, 

along with any required information, 

no later than ten days after receiving 

the contribution. 2 U.S.C. §432(b)

(1); 11 CFR 102.8(a). Finally, 

Famos’s proposal to transmit the 

contributor’s name, address, occupation and employer to the receiving 

political committee within ten days 

of the transfer of funds conforms 

with 11 CFR 102.8(b)(2). Thus, the 

proposed program does not violate 

the Act’s prohibition against corporate contributions under the conditions set forth in this opinion.

Date Issued: May 27, 2010;

Length: 9 pages.

—Christopher Berg

Background

Yes on FAIR is a ballot measure 

committee in the state of California that has applied to the Internal 

Revenue Service for recognition as a 

section 501(c)(4) organization under 

Title 26 of the Internal Revenue 

Code. Karen Bass, who is currently 

a federal candidate (and state officeholder), is identified in Yes on 

FAIR’s official name.1 However, 

the requestor maintains that Yes on 

FAIR was not directly or indirectly 

established by, and is not financed, 

maintained or controlled by, any 

federal candidate or officeholder.

The requestor represents that Yes 

on FAIR’s sole purpose is to support 

the qualification and passage of the 

Financial Accountability In Redistricting Act (FAIR Act), a proposed 

ballot initiative, for the statewide 

November 2, 2010, general election 

ballot. 

Once the ballot initiative has 

qualified for the general election 

ballot in California, Yes on FAIR 

intends to engage in “an extensive 

campaign to promote the FAIR Act’s 

passage,” including, among other 

things, get-out-the vote programs 

specifically designed to get the 

measure’s supporters to the polls on 

election day. Yes on FAIR maintains 

1

 The requestor’s full name is Yes on 

FAIR, a coalition of entrepreneurs, 

working people, Karen Bass, and other 

community leaders devoted to eliminating bureaucratic waste of taxpayer 

dollars on the political game of redistricting committee (“Yes on FAIR”). 

The requestor represents that California 

state law requires that the official name 

of a ballot initiative committee identify 

state officeholders who have contributed 

$50,000 or more to the committee. Ms. 

Bass is a California State legislator, and 

state political committees associated 

with her have made two contributions to 

Yes on FAIR totaling $50,000. Subsequently, Ms. Bass decided to run for 

election to the U.S. House of Representatives from California.
Federal Election Commission RECORD July 2010

6

Advisory Opinions

(continued from page 5)

(continued on page 7)

that their campaign advertisements 

will not promote, support, attack or 

oppose any federal candidate or result in coordinated communications 

under Commission rules.

Analysis

Members of Congress may solicit 

funds outside the amount limitations and source prohibitions of the 

Act and Commission regulations on 

behalf of Yes on FAIR during the 

period before the initiative qualifies 

for the November ballot. The Act 

prohibits federal candidates and officeholders, their agents and entities 

directly or indirectly established, financed, maintained or controlled by 

them or acting on their behalf from 

raising and spending funds in connection with an election unless the 

funds are consistent with the limitations and prohibitions contained in 

the Act. 2 U.S.C. §441i(e)(1) and 11 

CFR 300.61 and 300.62. The Commission concludes under the facts of 

this advisory opinion that 2 U.S.C. 

§441i(e)(1) does not apply to solicitations on behalf of the initiative 

before it qualifies for the ballot.

Members of Congress may also 

solicit funds within the limitations 

and prohibitions of the Act on behalf 

of Yes on FAIR after the initiative 

qualifies for the ballot. However, the 

Commission is unable to agree on 

whether Members of Congress may 

solicit funds outside the Act’s limits 

and prohibitions.

Finally, the Commission concludes that Members of Congress 

may solicit up to $20,000 from 

individuals on behalf of Yes on FAIR 

after the initiative has qualified for 

2

 The Act contains an exception to the 

limitations of 2 U.S.C. §441i(e)(1) that 

applies to solicitations for specific types 

of federal election activity on behalf 

of certain tax exempt organizations, 

provided that the solicitations are made 

only to individuals and do not seek more 

than $20,000 per individual. 2 U.S.C. 

§441i(e)(4) and 11 CFR 300.65.

the ballot.2 However, as discussed 

above, the Commission is unable 

to agree on whether Members of 

Congress may solicit funds outside 

the Act’s limitations and prohibitions 

after the initiative qualifies for the 

ballot.

Date Issued: June 14, 2010;

Length: 4 pages.

—Myles Martin

FEC Updates 

Electronic Format 

and FECFile Filing 

Software

 As of June 1, 2010, FECFile 

Version 6.4.2.0 is available 

from the Commission’s website 

at http://www.fec.gov/elecfil/

updatelist.html. Installation of the 

updated software is mandatory. 

The new version of FECFile 

is compatible with Microsoft 

Windows 7, has an auto-update 

feature and has an overall new 

look. A list of the changes to the 

software is available at that link 

as well.

AO 2010-08

Film Production, 

Distribution Costs Qualify 

for Press Exemption

The funds a non-stock corporation spends to produce and distribute 

documentary films that mention 

federal candidates are covered by the 

press exemption from the Federal 

Election Campaign Act’s (the Act’s) 

definitions of expenditure and electioneering communication. 

Background

Citizens United is a Virginiabased non-stock corporation that 

describes its principal purpose as 

promoting “social welfare through 

informing and educating the public 

on conservative ideas and positions on issues, including national 

defense, the free enterprise system, 

belief in God, and the family as the 

basic unit of society.” Its activities 

include issue advocacy, direct e-mail 

communications, disseminating 

publications and advertising and 

litigation. It also conducts political 

activities, such as making contributions, through a separate segregated 

fund. Citizens United is not owned 

or controlled by any political party, 

political committee or candidate.

This organization also produces 

and distributes films, which frequently deal with political issues 

and mention political candidates, 

through its in-house production arm, 

Citizens United Productions, and 

sometimes through affiliated agencies. Citizens United distributes 

these films as DVDs and theatrical 

releases, and on broadcast, cable and 

satellite television. 

Citizens United asked whether 

the costs of producing and distributing its films, and related marketing 

activities, are covered by the press 

exemption from the Act’s definitions 

of “expenditure” and “electioneering 

communication.” 

Analysis

The Act contains an exemption 

from the term expenditure for “any 

news story, commentary, or editorial 

distributed through the facilities of 

any broadcasting station, newspaper, magazine, or other periodical 

publication, unless such facilities are 

owned or controlled by any political 

party, political committee, or candidate.” 2 U.S.C. §431(9)(B)(i). The 

Act and Commission regulations 

also include a similar exemption 
July 2010 Federal Election Commission RECORD

7

Advisory Opinions

(continued from page 6)

Advisory Opinion Requests

AOR 2010-09

Establishment and administration 

of, and solicitations by, a political committee that is connected to 

a 501(c)(4) corporation and only 

makes independent expenditures 

(Club for Growth, May 21, 2010) 

AOR 2010-10

Allocation of independent expenditures among federal candidates 

(National Right to Life PAC, June 

10, 2010)

AOR 2010-11

Nonconnected committee accepting corporate and union contributions to make independent 

expenditures (Commonsense Ten, 

June 11, 2010)

from the definition of electioneering 

communication for a communication that appears in a news story, 

commentary or editorial distributed 

through the facilities of any broadcast, cable or satellite television or 

radio station, unless such facilities 

are owned or controlled by any 

political party, political committee or 

candidate. 2 U.S.C. §434(f)(3)(B)(i) 

and 11 CFR 100.29(c)(2). Together, 

these exclusions are commonly 

referred to as the “press exemption” 

or “media exemption.”

In past advisory opinions, the 

Commission has applied the press 

exemption to a wide array of media, including cable television, the 

Internet, satellite broadcasts and 

other communications. The Commission conducts a two-step analysis 

to determine whether the media 

exemption applies. First, the entity 

engaging in the activity in question 

must be a press or media entity. AOs 

2005-16, 1996-16, 1980-90. Second, 

the Commission must establish that 

the entity is not owned or controlled 

by a political party, a political committee or a candidate and that the 

entity is acting in its legitimate press 

function. Reader’s Digest Ass’n 

v. FEC, 509 F. Supp. 1210, 1215 

(S.D.N.Y. 1981).

While the Act and Commission 

regulations do not define the term 

“press entity,” the Commission has 

examined whether the entity in question regularly produces news stories, 

commentary and/or editorials. In the 

Explanation and Justification for the 

Final Rules on Electioneering Communications, the Commission stated 

that it will interpret “news story, 

commentary, or editorial” to include 

documentaries and educational programming within the context of the 

media exemption to the “electioneering communication” definition in 11 

CFR 100.29(c)(2). Citizens United 

has made 14 films since 2004, and 

is currently producing several more. 

The organization also devotes a 

substantial amount of its budget to 

producing and distributing its documentary films. Based on these facts, 

the Commission determined that 

Citizens United is a press entity for 

the purposes of this opinion. 

Citizens United and its production 

affiliates are not controlled by any 

candidate, political party or political 

committee. 

When considering whether an 

entity is serving a legitimate press 

function, the Commission examines 

whether the communication materials in question are available to the 

general public and whether they 

are comparable to those ordinarily 

issued by the entity. In FEC v. Mass. 

Citizens for Life, 479 U.S. 238, 251 

(1986), the Supreme Court held that 

a “Special Edition” newsletter did 

not qualify for the media exemption 

because the communication was not 

published through the same facilities as the regular newsletter, and 

it was distributed to a much larger 

group than the regular newsletter. 

The Commission found that the 

films discussed in Citizens United’s 

AO request are available to the 

general public and comparable in 

form to those previously produced. 

In addition, Citizens United receives 

monetary compensation from broadcasters that air its documentaries.

Based on these factors, the Commission determined that Citizens 

United’s documentary films are 

eligible for the media exemption. 

Courts have held that where the 

underlying product is covered by the 

press exemption, so are advertisements to promote that product. See

FEC v. Phillips Publ’g, 517 F. Supp. 

1308, 1313 (D.D.C. 1981) (citing 

Reader’s Digest, 509 F. Supp. at 

1215). Thus, Citizens United’s ads 

would fall under the media exemption to the extent that they promote 

activities that are part of the organization’s legitimate press function. 

Ads that promote activities that are 

not part of Citizens United’s legitimate press function would not be 

covered by the media exemption.1

Date Issued: June 11, 2010;

Length: 12 pages.

—Isaac J. Baker

1 Having found that Citizens United’s 

films qualify for the press exemption, 

the Commission determined that the 

question of whether the production 

and distribution of its films and related 

marketing activity constitute bona fide 

commercial activity by a commercial 

entity was moot.
Federal Election Commission RECORD July 2010

8

(continued on page 9)

Campaign Guides 

Available

 For each type of committee, a 

Campaign Guide explains, in clear 

English, the complex regulations 

regarding the activity of political 

committees. It shows readers, 

for example, how to fill out FEC 

reports and illustrates how the law 

applies to practical situations.

 The FEC publishes four 

Campaign Guides, each for a 

different type of committee, 

and we are happy to mail your 

committee as many copies as 

you need, free of charge. We 

encourage you to view them on 

our web site (www.fec.gov).

 If you would like to place an 

order for paper copies of the 

Campaign Guides, please call the 

Information Division at 800/424-

9530.

committees of filing deadlines on its 

website, via its automated Faxline 

and through reporting reminders 

called prior notices. Prior notices are 

distributed exclusively by electronic 

mail. For that reason, it is important that every committee update 

its Statement of Organization (FEC 

Form 1) to disclose a current e-mail 

address. To amend Form 1, electronic filers must submit Form 1 filled 

out in its entirety. Paper filers should 

include only the committee’s name, 

address, FEC identification number 

and the updated or changed portions 

of the form. 

Treasurer’s Responsibilities

The Commission provides 

reminders of upcoming filing dates 

as a courtesy to help committees 

comply with the filing deadlines set 

forth in the Federal Election Campaign Act (the Act) and Commission 

regulations. Committee treasurers 

must comply with all applicable 

filing deadlines established by law, 

and the lack of prior notice does 

not constitute an excuse for failing 

to comply with any filing deadline. 

Accordingly, reports filed by methods other than electronically, or 

other than Registered, Certified or 

Overnight Mail must be received by 

the Commission’s (or the Secretary 

of the Senate’s) close of business 

on the last business day before the 

deadline.

Filing Electronically

Under the Commission’s mandatory electronic filing regulations, 

individuals and organizations that 

receive contributions or make expenditures, including independent 

expenditures, in excess of $50,000 in 

a calendar year—or have reason to 

expect to do so—must file all reports 

and statements with the FEC electronically.1

 Reports filed electronically must be received and validated 

by the Commission by 11:59 p.m. 

Eastern Standard/Daylight Time 

on the applicable filing deadline. 

Electronic filers who instead file on 

paper or submit an electronic report 

that does not pass the Commission’s 

validation program by the filing 

deadline will be considered nonfilers 

and may be subject to enforcement 

actions, including administrative 

fines. 11 CFR 104.18(e).

Senate committees and other 

committees that file with the Secretary of the Senate are not subject 

to the mandatory electronic filing 

rules, but may file an unofficial copy 

of their reports with the Commission in order to speed disclosure. 

The Commission’s electronic filing 

software, FECFile, is free and can be 

downloaded from the FEC’s website. New FECFile Version 6.4.2.0 

is available for download from the 

FEC website at http://www.fec.gov/

elecfil/updatelist.html. All reports 

filed after June 1, 2010, must be 

filed in Format Version 6.4.2.0 (the 

new version). Reports filed in previous formats will not be accepted. 

Filers may also use commercial or 

privately developed software as long 

as the software meets the Commission’s format specifications, which 

are available on the Commission’s 

website. Committees using commercial software should contact their 

vendors for more information about 

the Commission’s latest software 

release. 

Timely Filing for Paper Filers

Registered and Certified Mail.

Reports sent by registered or certified mail must be postmarked on or 

before the mailing deadline to be 

considered timely filed. A committee sending its reports by certified 

or registered mail should keep its 

mailing receipt with the U.S. Postal 

Service (USPS) postmark as proof 

of filing because the USPS does 

not keep complete records of items 

sent by certified mail. See 2 U.S.C. 

§434(a)(5) and 11 CFR 104.5(e).

1

 The regulation covers individuals and 

organizations required to file reports of 

contributions and/or expenditures with 

the Commission, including any person 

making an independent expenditure. 

Disbursements for “electioneering 

communications” do not count toward 

the $50,000 threshold for mandatory 

electronic filing. 11 CFR 104.18(a).

Reports

(continued from page 1)
July 2010 Federal Election Commission RECORD

9

Reports

(continued from page 8)

Overnight Mail. Reports filed via 

overnight mail2 will be considered 

timely filed if the report is received 

by the delivery service on or before 

the mailing deadline. A committee 

sending its reports by Express or 

Priority Mail, or by an overnight delivery service, should keep its proof 

of mailing or other means of transmittal of its reports. See 2 U.S.C. 

§434(a)(5) and 11 CFR 104.5(e).

Other Means of Filing. Reports 

sent by other means—including first 

class mail and courier—must be 

received by the FEC (or the Secretary of the Senate) before close of 

business on the filing deadline. See 

11 CFR 100.19 and 104.5(e).

Paper forms are available for 

downloading at the FEC’s website 

(http://www.fec.gov/info/forms.

shtml) and from FEC Faxline, the 

agency’s automated fax system 

(202/501-3413). The 2010 Reporting Schedule is also available on the 

FEC’s website (http://www.fec.gov/

info/report_dates_2010.shtml), and 

from Faxline. For more information on reporting, call the FEC at 

800/424-9530 or 202/694-1100. 

State, District and Local Party 

Committees

State, district and local party 

committees that engage in certain 

levels of “federal election activity” 

must file on a monthly schedule. 

See 11 CFR 300.36(b) and (c)(1). 

Committees that do not engage in 

reportable “federal election activity” 

may file on a quarterly basis in 2010. 

See 11 CFR 104.5(c)(1)(i).

FEC Form 3L Due in July

Certain Leadership PACs, candidate committees and political party 

committees may be required to file 

FEC Form 3L in July. Under the 

lobbyist bundling disclosure rules, 

“reporting committees” (authorized 

committees, Leadership PACs and 

political party committees) must 

disclose certain information about 

lobbyists/registrants and lobbyist/

registrant PACs that forward, or are 

credited with raising, two or more 

bundled contributions aggregating in excess of $16,000 during a 

specific covered period. See 11 CFR 

104.22(a)(6).

Committees file their FEC Form 

3L, as necessary, on the same schedule as they file FEC Form 3, 3X or 

3P. Committees that file Form 3X 

and 3P on a monthly basis may elect 

to file Form 3L quarterly, instead 

of monthly. 11 CFR 104.22(a)(5). 

Candidate committees, Leadership 

PACs and party committees that file 

Form 3L quarterly are required to 

file by the July 15, 2010, quarterly 

filing deadline. A committee must 

file Form 3L if a lobbyist/registrant 

or lobbyist/registrant PAC forwards 

to that committee or is credited by 

that committee with raising two or 

more bundled contributions that total 

more than $16,000 during April 1 

through June 30, 2010.

Leadership PACs, parties and 

Presidential committees that file 

Form 3L monthly are required to 

disclose lobbyist bundling activity 

by July 20, 2010, if they receive two 

or more bundled contributions that 

aggregate more than $16,000 for the 

month of June. In addition to the 

above requirements, all reporting 

committees must also file Form 3L 

in July if they received two or more 

bundled contributions that aggregate 

more than $16,000 during the six 

month semi-annual covered period. 

Reporting committees that are 

monthly filers of FEC Form 3, 3X 

National Party Committees

National committees of political 

parties must file on a monthly schedule in all years. 2 U.S.C. §434(a)(4)

(B) and 11 CFR 104.5(c)(4).

Political Action Committees

PACs (separate segregated funds 

and nonconnected committees) 

that filed on a semi-annual basis 

in 2009 file on a quarterly basis in 

2010. Monthly filers continue on 

the 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, after giving 

notice of change in filing frequency 

to the Commission. The committee 

will receive a letter indicating the 

Commission’s acknowledgment of 

the request. All future reports must 

follow the new filing frequency. 11 

CFR 104.5(c).

Additional Information

For more information on 2010 

reporting dates:

•	 See the reporting tables in the

January 2010 Record;

•	 Call and request the reporting

tables from the FEC at 800/424-

9530 or 202/694-1100;

•	 Fax the reporting tables to

yourself using the FEC’s Faxline 

(202/501-3413, document 586); 

or

•	 Visit the FEC’s web page at

http://www.fec.gov/info/report_

dates_2010.shtml to view the 

reporting tables online.

—Elizabeth Kurland

2 “Overnight mail” 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 service’s on-line tracking system. (continued on page 10)
Federal Election Commission RECORD July 2010

10

or 3P that wish to change their FEC 

Form 3L filing frequency from 

monthly to quarterly or from quarterly to monthly must first notify 

the Commission in writing and will 

receive a letter indicating the Commission’s acknowledgment of the 

request. Electronic filers must file 

this request electronically. A reporting committee may change its Form 

3L filing frequency only once in a 

calendar year. 11 CFR 104.22(a)

(5)(iv). The committee will receive 

an acknowledgment letter from the 

Commission. All subsequent Form 

3L reports should be filed on the 

new schedule.

For more information about these 

filing requirements, see the March 

2009 issue of the Record, page 1.

—Elizabeth Kurland 

Reports

(continued from page 9)

Court Cases

The Real Truth About 

Obama, Inc., v. FEC and U.S. 

Department of Justice

On June 8, 2010, the U.S. Court 

of Appeals for the Fourth Circuit 

reissued its opinion in part, and 

remanded the case to the district 

court for further consideration in 

light of the Supreme Court’s holding 

in Citizens United and the Solicitor 

General’s suggestion of mootness. 

On July 30, 2008, The Real Truth 

About Obama, Inc. (RTAO), filed a 

complaint in the U.S. District Court 

for the Eastern District of Virginia 

challenging the constitutionality 

of three FEC regulations and an 

FEC enforcement analysis. At the 

same time, RTAO filed a Motion for 

Preliminary Injunction which sought 

to enjoin the FEC and DOJ from enforcing the challenged analysis and 

regulations. In September 2008, the 

district court denied RTAO’s motion, 

concluding that RTAO was unlikely 

to succeed on the merits of its claims 

that the challenged provisions were 

unconstitutional. The court also 

concluded that granting the injunction would cause greater harm to the 

government than to RTAO. RTAO 

appealed the district court’s decision 

to the U.S. Court of Appeals for the 

Fourth Circuit, and in August 2009, 

that court also denied RTAO’s motion for an injunction.

In December 2009, RTAO filed 

a Petition for a Writ of Certiorari 

with the U.S. Supreme Court stating, 

among other things, that the appellate court applied an incorrect legal 

standard in denying its request for 

a preliminary injunction. The FEC 

argued that the Court of Appeals 

applied the correct standard in denying RTAO’s motion and that certain 

issues are moot as a result of subsequent litigation. The FEC requested 

that the Court grant the Petition for 

Writ of Certiorari and vacate the appellate court’s judgment with respect 

to some of the challenged regulations, and requested that the Court 

remand the case with instructions to 

declare those claims moot. On April 

26, 2010, the U.S. Supreme Court 

granted RTAO’s Petition for Writ 

of Certiorari, vacated the appellate 

court’s judgment and remanded the 

case to the Court of Appeals for 

further consideration in light of the 

Supreme Court’s holding in Citizens 

United and the Solicitor General’s 

suggestion of mootness. In its per 

curium Order on Remand, the Court 

of Appeals reissued its opinion 

on the facts and legal standard for 

issuing a preliminary injunction.

The Court of Appeals remanded the 

remaining issues to the district court 

for further consideration.

The text of the court’s order is 

available at http://www.fec.gov/law/

litigation/rtao_ac_order_percuriam.

pdf.

—Zainab Smith

PACronyms, Other 

PAC Publications 

Available

 The Commission annually 

publishes an alphabetical listing 

of acronyms, abbreviations and 

common names of political action 

committees (PACs).

 For each PAC listed, the 

index provides the full name 

of the PAC, its city, state, FEC 

identification number and, if not 

identifiable from the full name, its 

connected, sponsoring or affiliated 

organization.

 This index is helpful in 

identifying PACs that are not 

readily identified in their reports 

and statements on file with the 

FEC.

 To order a free copy of 

PACronyms, call the FEC’s 

Disclosure Division at 800/424-

9530 or 202/694-1120.

 PACronyms is also available 

on diskette for $1 and can be 

accessed free on the FEC web site 

at www.fec.gov.

 Other PAC indexes, described 

below, may be ordered from the 

Disclosure Division. Prepayment 

is required.

•	 An alphabetical list of all

registered PACs showing each 

PAC’s identification number, 

address, treasurer and connected 

organization ($13.25).

•	 A list of registered PACs

arranged by state providing 

the same information as above 

($13.25).

•	 An alphabetical list of

organizations sponsoring PACs 

showing the name of the PAC 

and its identification number 

($7.50).

 The Disclosure Division can 

also conduct database research to 

locate federal political committees 

when only part of the committee 

name is known. Call the telephone 

numbers above for assistance or 

visit the Public Records Office in 

Washington at 999 E St. NW.
July 2010 Federal Election Commission RECORD

11

Court Cases

(continued from page 10)

SpeechNow.org v. FEC

On May 27, 2010, the U.S. District Court for the District of Columbia entered final judgment on behalf 

of SpeechNow.org and declared 

that the contribution limitations in 2 

U.S.C. §§441a(a)(1)(C) and 441a(a)

(3) cannot be constitutionally applied against SpeechNow.org and 

others who wish to contribute to 

SpeechNow.org and ordered that the 

Commission is permanently enjoined from enforcing those contribution limits.

On March 26, 2010, the D.C. 

Circuit Court of Appeals held that 

the provisions of the Federal Election Campaign Act that limit the 

contributions that individuals may 

make to SpeechNow.org, and the 

contributions that SpeechNow.org 

may accept from them, violate the 

First Amendment. See the May 2010 

Record, page 1.

—Myles Martin

U.S. v. O’Donnell

On June 14, 2010, the U.S. 

Court of Appeals for the 9th Circuit 

reversed and remanded an earlier 

decision by the U.S. District Court 

for the Central District of California 

which found that 2 U.S.C. §441f, 

which states that “no person shall 

make a contribution in the name 

of another person,” applied only to 

direct contributions made under false 

names. The U.S. Court of Appeals 

found instead that the statute applies 

not only to so-called false name contributions, but also to indirect, straw 

donor contributions.

Background

The case revolves around alleged political contributions from 

Pierce O’Donnell to the Edwards 

for President campaign in 2003. 

Mr. O’Donnell solicited 13 individuals to donate contributions to 

the campaign in their own names 

under the arrangement that he would 

either advance them the funds for 

the contributions or reimburse them 

at a later date. He was charged with 

contributing in the names of others, 

which is a violation of §441f.

Analysis

The case came down to whether 

§441f applies only to direct, “false 

name” contributions or also to 

indirect contributions made through 

straw donors. False name contributions are those in which the actual 

contributor making the contribution 

does so directly but under either another individual’s name or a fictional 

name. Straw donor contributions are 

those in which the actual contributor making the contribution does so 

secretly and indirectly, through an 

undisclosed third party, either by 

advancing or reimbursing the third 

party the contribution funds. 

The court analyzed who in a 

straw donor situation would be considered to be the actual contributor 

who actually made the contribution. 

It found that the straw donor who 

actually delivers the money to the 

committee is only acting as a mechanism, and that the original source 

of the contribution is the individual 

who actually made the contribution. 

Therefore, because O’Donnell was 

the original source of the contribution, he was the individual who 

made the contribution to the committee and his name should have 

been provided as the source. 

The court clarified that in the context of reimbursements of straw donors, when the defendant and straw 

donor have a prior arrangement for 

the straw donor to make a contribution, coupled with a promise by the 

defendant to reimburse the straw 

donor at a later date, the violation of 

§441f would occur the moment the 

committee receives the contribution 

from the intermediary. 

The court determined that the purpose behind §441f is to “ensure the 

complete and accurate disclosure of 

the contributors who finance federal 

elections” and therefore, the statute 

applies to both indirect, straw donor 

contributions, as well as direct “false 

name” contributions. The appeals 

court reversed the district court’s 

dismissal of counts one and two—

which alleged violations of §441f—

and remanded the case to the district 

court for further action consistent 

with its decision.

U.S Court of Appeals for the 9th

Circuit, 09-50296.

—Katherine Wurzbach

Back Issues of the 

Record Available on 

the Internet

 This issue of the Record and all 

other issues of the Record starting 

with January 1989 are available 

on the FEC web site as PDF files. 

Visit the FEC web site at http://

www.fec.gov/pages/record.shtml

to find monthly Record issues. 

 The web site also provides 

copies of the Annual Record Index

for each completed year of the 

Record, dating back to 1989. The 

Annual Record Index list Record

articles for each year by topic, 

type of Commission action and, in 

the case of advisory opinions, the 

names of individuals requesting 

Commission action.

You will need Adobe® Acrobat® Reader software to view the 

publication. The FEC’s web site 

has a link that will take you to 

Adobe’s web site, where you can 

download the latest version of the 

software for free.
Federal Election Commission RECORD July 2010

12

Committees Fail to File PreElection Reports

The Commission cited several 

campaign committees for failing to 

file the 12-Day Pre-Election Reports 

required by the Federal Election 

Campaign Act (the Act).

California Pre-Primary Report

The Commission cited two campaign committees for failing to file 

the 12-Day Pre-Primary Election 

Report required by the Act for the 

California primary election held on 

June 8, 2010.

As of June 4, 2010, the required 

disclosure report had not been received from:

•	 Al Ramirez for US Senate; and

•	 Goodwin Exploratory Committee

(CA-19).

The reports were due on May 

27, 2010, and should have included 

financial activity for the period April 

1, 2010, through May 19, 2010. If 

sent by certified or registered mail, 

the reports should have been postmarked by May 24, 2010.

The FEC notified committees 

involved in the California primary 

election of their potential filing 

requirements on May 3, 2010. Those 

committees that did not file on the 

due date were sent notification on 

May 28, 2010, that their reports 

had not been received and that their 

names would be published if they 

did not respond within four business 

days.

South Carolina Pre-Primary 

Report

The Commission cited a campaign committee for failing to file 

the 12-Day Pre-Primary Election 

Report required by the Act for the 

South Carolina primary election held 

on June 8, 2010.

As of June 4, 2010, the required 

disclosure report had not been received from:

•	 Burton for Congress (SC-01).

The report was due on May 27, 

2010, and should have included 

financial activity for the period April 

1, 2010, through May 19, 2010. If 

sent by certified or registered mail, 

the report should have been postmarked by May 24, 2010.

The FEC notified committees 

involved in the South Carolina primary election of their potential filing 

requirements on May 3, 2010. Those 

committees that did not file on the 

due date were sent notification on 

May 28, 2010, that their reports 

had not been received and that their 

names would be published if they 

did not respond within four business 

days.

Additional Information

Some individuals and their committees have no obligation to file reports under federal campaign finance 

law, even though their names may 

appear on the ballot. If an individual 

raises or spends $5,000 or less, he or 

she is not considered a “candidate” 

subject to reporting under the Act.

Other political committees that 

support Senate and House candidates in elections, but are not authorized committees of a candidate’s 

campaign, are also required to file 

quarterly reports, unless they report 

monthly. Those committee names 

are not published by the FEC.

Further Commission action 

against non-filers and late filers is 

decided on a case-by-case basis. 

Federal law gives the FEC broad 

authority to initiate enforcement acNonfilers

Visit the FEC’s 

Redesigned Web Site

 FEC staff recently completed 

a significant upgrade of the 

Commission’s web site, www.fec.

gov. The redesigned site offers a 

wealth of information in a simple, 

clearly-organized format. Features 

include cascading menus that 

improve navigation and interactive 

pages that allow users to tailor 

content to their specific needs.

Noteworthy among the new 

features is a search engine. This 

tool allows visitors to immediately 

access all pages on the site 

that contain a desired word or 

phrase. Another new feature, 

the Commission Calendar, helps 

users keep track of reporting 

deadlines, upcoming conferences 

and workshops, Commission 

meetings, comment deadlines and 

more.

 The site also offers a robust new 

enforcement section that includes 

the Enforcement Query System, 

information on closed MURs, the 

Alternative Dispute Resolution 

and Administrative Fine programs 

and—for the first time—access to 

final audit reports issued by the 

Commission. 

 The Commission encourages 

the regulated community and 

the public to make use of this 

dynamic and interactive site by 

visiting www.fec.gov.

 

tions, and the FEC has implemented 

an Administrative Fine program with 

provisions for assessing monetary 

penalties.

—Myles Martin
July 2010 Federal Election Commission RECORD

13

The first number in each citation refers to the numeric month of 

the 2010 Record issue in which the 

article appeared. The second number, following the colon, indicates 

the page number in that issue. For 

example, “1:4” means that the article 

is in the January issue on page four.

Advisory Opinions

2009-29: Membership organization 

may establish SSF without vote of 

its membership, 2:4

2009-30: Trade association corporate 

members may use treasury funds to 

assist their SSFs, 3:9

2009-31: Employees may use credits 

to make contributions to SSF, 3:10

2009-32: Proposed sale of art on behalf of committees is not a contribution, 3:10

2010-01: State party activity on behalf of presumptive nominee, 4:10

2010-02: State party committee may 

use nonfederal funds to purchase 

office building, 4:11

2010-03: Members of Congress may 

solicit nonfederal funds for redistricting trust, 6:1

2010-04: Determining composition of 

corporation’s restricted class, 6:3

2010-05: Sale of ad time on a foreign-owned television station, 7:1

2010-06: Political affinity accounts 

for revenue-generating web platform, 7:3

2010-07: Members of Congress may 

solicit funds for state ballot measure, 7:5

2010-08: Film production, distribution costs qualify for press exemption, 7:6

Commission

Commission statement on Citizens 

United v. FEC, 3:1

FEC Elects Chairman and Vice 

Chair for 2010, 1:1

FEC Introduces new compliance 

map, 2:2

Message from the Chairman, 2:1

Compliance

Nonfilers, 3:12; 6:10; 7:12

Court Cases

______v. FEC

 - Cao, 3:1

 - Citizens United, 2:1

 - Fieger, 4:4

 -RNC, 5:3

 -SpeechNow.org, 5:1; 7:11

 - The Real Truth About Obama, 

Inc., 7:10

 - Unity08, 4:1

 -Utility Workers, et. al, 4:3

FEC v. ______

 - Novacek, 5:5

U.S. v. O’Donnell, 7:11

Inflation Adjustments

2010 Coordinated party expenditure 

limits, 3:5

Lobbyist bundling threshold unchanged for 2010, 3:6

Outreach

Conferences in 2010, 1:14; 2:5; 3:12-

13; 4:14; 5:7; 6:12

June Reporting Roundtable, 6:12

Nonconnected Committee Seminar, 

2:7; 3:13; 4:14-15

Roundtable on new travel rules, 1:15; 

2:6

Year-End reporting roundtable, 1:14

Regulations

Final Rules on campaign travel, 1:1

Final Rules on debt collection, 5:1

Final Rules on funds received in 

response to solicitations; allocation 

of expenses by PACs, 4:8

Final Rules on participation by federal candidates and officeholders at 

nonfederal fundraising events, 6:1

Hearings on coordinated communications rules, 6:7

Hearing on proposed federal election 

activity (FEA) rules, 3:8

NPRM on debt collection, 4:9

NPRM on federal candidates’ and 

officeholders’ participation in party 

fundraisers, 1:5

NPRM on funds received in response 

to solicitations; allocation of expenses by certain committees, 2:4

NPRM on standards of conduct, 6:6

Petition for rulemaking on Citizens 

United, 3:7

Public hearing rescheduled for March 

16, 3:7

Supplemental NPRM on Coordinated 

Communications, 3:7

Reports

FEC Form 3L Due in July, 7:9

Florida Special Election Reporting: 

19th District, 1:12

Georgia Special Election Reporting: 

9th District, 4:4

Hawaii Special Election Reporting: 

1st District, 4:7

Pennsylvania Special Election Reporting: 12th District, 4:6

Reports Due in 2010, 1:8; 4:1; 7:1

Statistics

House and Senate campaigns raise 

nearly $600 million in 2009, 4:12

PAC activity remains steady in 2009, 

5:7

Party committees report slight increase in 2009 receipts, 4:13

Website

Candidate Disbursements search 

feature available on website, 6:10

Index