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  • FEC Record: Advisory opinions

AO 2013-09 – PAC must meet three criteria for multicandidate status

August 30, 2013

A political committee may not make contributions to a candidate in excess of $2,600 per election until it meets all three criteria for multicandidate status.


Special Operations Speaks PAC (“SOS”) is a nonconnected hybrid political committee that registered as a political committee on July 2, 2012. It states that it has made contributions to three federal candidates and has “thousands of grassroots contributors.”

SOS contributed $2,600 to the campaign of Col. Robert Maness — a 2014 candidate for the U.S. Senate from Louisiana. The committee wants to contribute an additional $2,400 to the campaign, and the campaign would like to accept the additional contribution.


Under the Federal Election Campaign Act (the Act) and Commission regulations, non-multicandidate committees may contribute up to $2,600 per election to a federal candidate during the 2013-14 election cycle. 2 U.S.C. § 441a(a)(1)(A); see also 11 CFR 110.1(b). A multicandidate committee may contribute up to $5,000 per candidate, per election. 2 U.S.C. § 441a(a)(2)(A); see also 11 CFR 110.2(b). Recipient candidates cannot knowingly accept any contribution that exceeds these limits. 2 U.S.C. § 441a(f); see also 11 CFR 110.9.

The Act defines a multicandidate committee as a political committee that has:

  • Been registered with the FEC for at least six months; 
  • Received contributions from more than 50 persons; and
  • Made contributions to five or more candidates for federal office. 2 U.S.C. §441a(a)(4); see also 11 CFR 100.5(e)(3) (defining “multicandidate committee”).

SOS  has been registered with the Commission as a political committee for more than six months and has received contributions from more than 50 persons, but it has made contributions to only three federal candidates. Nevertheless, SOS believes it should be given multicandidate status, because it has found only three candidates who fit the group’s mission.

Based on the statute and regulations, the Commission concluded that the committee must meet all three criteria for multicandidate status. As a result, SOS is subject to the contribution limits of section 441a(a)(1)(A), and may not make contributions to any candidate with respect to any election which, in the aggregate, exceed $2,600. Moreover, candidates such as Col. Robert Maness, may not knowingly accept contributions from SOS that exceed $2,600 per election.

Date issued: August 22, 2013; Length: 4 pages.


  • Author 
    • Alex Knott