AO 2009-22: National party committee may file lobbyist bundling reports quarterly

The Democratic Senatorial Campaign Committee (DSCC), a national committee of a political party, may file Lobbyist Bundling Reports on a quarterly basis instead of monthly. The applicable covered periods for these reports in election years would be semi-annually, quarterly and any applicable pre-and post-election reporting periods. In non-election years, the covered periods would be the semi-annual periods beginning on January 1 and July 1.

Background

As a national committee of a political party, the DSCC is required by the Federal Election Campaign Act (the Act) to file monthly campaign finance reports with the Commission. 2 U.S.C. §434(a)(4)(B) and 11 CFR 104.5(c)(4). It may also need to file Lobbyist Bundling reports periodically and has the option of filing those reports on a quarterly basis instead of monthly. 11 CFR 104.22(a)(5)(iii).

Analysis

The Act and Commission regulations require certain political committees (“reporting committees”)¹ to disclose information about any lobbyist/registrant or lobbyist/registrant PAC that forwards, or is credited with raising, two or more bundled contributions aggregating in excess of a certain amount within a specified period of time (“covered period”). 2 U.S.C. §434(i) and 11 CFR 104.22. The covered periods for lobbyist bundling reports generally correspond to the reporting periods for the reporting committee’s regular campaign finance reports. However, reporting committees that file monthly campaign finance reports may elect to file their lobbyist bundling reports “pursuant to the quarterly covered period…instead of the monthly covered period…” 11 CFR 104.22(a)(5)(iv). Overlapping semi-annual covered periods apply to all reporting committees.

A reporting committee required to file campaign finance reports quarterly with the Commission must file its lobbyist bundling reports for the quarters beginning January 1, April 1, July 1 and October 1 of each calendar year and the applicable pre-and post-election reporting periods in election years; in a nonelection year, reporting committees not authorized by a candidate [i.e. a political party committee] need only observe the semi-annual reporting period. 11 CFR 104.22(a)(5)(ii). This schedule applies both to reporting committees who file campaign finance reports quarterly and to those that file campaign finance reports monthly, but choose to file lobbyist bundling reports on a quarterly basis.

Thus, if the DSCC elects to file its lobbyist bundling report on a quarterly basis, the reporting schedule is as follows: in election years, semi-annually, quarterly and the applicable pre-and post-election reporting periods, as appropriate; in nonelection years, the DSCC need observe only the semi-annual covered periods beginning on January 1 and July 1, as appropriate. Additionally, the Committee must file Lobbyist Bundling Reports for any special election covered periods in which it receives bundled contributions above the threshold amount from lobbyists/ registrants and lobbyist/registrant PACs. 11 CFR 104.22(a)(5)(v).

AO 2009-22: Date Issued: October 9, 2009; Length: 3 pages.

¹ “Reporting committees” means political party committees, political committees authorized by candidates (i.e., candidate committees) and leadership PACs. 11 CFR 104.22(a)(1).