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        Registering as an SSF
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      Partnerships and LLCs involved with corporations and SSFs

Partnerships and LLCs involved with corporations and SSFs Partnerships and limited liability companies (LLCs) that are treated as partnerships are generally prohibited from serving as the connected organization of an SSF. Instead, were such organizations to form a political committee, they would form a nonconnected PAC. A different result occurs, however, when a partnership or LLC is owned by a corporation, as explained. Partnership/LLC as connected organization A partnership or LLC that is owned entirely by corporations and affiliated with one of those corporations is permitted to pay the administrative and solicitation costs of its corporate owner’s SSF without the resulting costs being considered a contribution to the committee. The SSF must list one of the partnership or LLC’s affiliated corporate owners (not the partnership or LLC) as its connected organization on its Statement of Organization (Form 1). Joint venture partnerships/LLCs owned by corporations When a nonconnected PAC is sponsored by a joint venture partnership or LLC owned entirely by one or more corporations and affiliated with at least one of them, the nonconnected PAC becomes affiliated with the SSF of any corporation affiliated with the joint venture partnership or LLC. Even though nonconnected PACs sponsored by partnerships or LLCs do not normally carry the solicitation restrictions applicable to SSFs, the rules that apply to SSFs will apply to the nonconnected PAC of a partnership that is an affiliate of a corporation with an SSF. As a result, when a nonconnected PAC becomes affiliated with an SSF, the nonconnected PAC may solicit only that SSF’s restricted class and must follow the rules governing SSF solicitations.
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          Understanding the SSF and its connected organizationRegistering as an SSFRegistering affiliated SSFsPartnership and LLC contributionsFundraising for an SSF From the FEC Record AO 2016-02: PACs of LLC and one of its joint venture owners not affiliated
AO 2007-15: Payment for administration of SSF by LLC treated as partnership; name and abbreviation of SSF
 Need help? Get help from the FEC by phone or email
 Legal citations Advisory opinions AO 2016-02Affiliation of corporations and their SSFs AO 2014-17Trade association SSF soliciting contributions from executive and administrative personnel of an LLC member AO 2010-16Wholly corporate owned LLC as connected organization for SSF AO 2009-14Administration and naming of SSF by a domestic LLC that is affiliated with the SSF's connected corporation and has a foreign parent AO 2008-05Status of law firm as a corporation or as a partnership for purposes of administering and financially supporting a separate segregated fund AO 2004-42Limited liability company as connected organization for SSF AO 2003-28LLC's nonconnected PAC may become an SSF AO 2001-18Affiliation between LLC PAC and PACs of corporate owners in 60-40 joint venture AO 1997-13Relationship of limited liability company's nonconnected PAC to parent corporations' SSFs AO 1996-38Solicitable class of nonconnected PAC affiliated with SSF AO 1992-17Partnership PAC affiliated with SSFs of corporate partners AO 1989-08Solicitable class and name of PAC established by corporation affiliated with partnership AO 1982-63Check-off system used by law partnership to solicit PAC contributions


This information is not intended to replace the law or to change its meaning, nor does this information create or confer any rights for or on any person or bind the Federal Election Commission or the public. The reader is encouraged also to consult the Federal Election Campaign Act of 1971, as amended (52 U.S.C. 30101 et seq.), Commission regulations (Title 11 of the Code of Federal Regulations), Commission advisory opinions and applicable court decisions.


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