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  • FEC Record: Advisory opinions

AO 2021-12: Campaign may rent its email list to a publisher at fair market value

December 13, 2021

Schiff for Congress ("the Committee"), the authorized committee of Congressman Adam Schiff, may rent its email list to a publishing company under the circumstances proposed by the Committee and Congressman to promote a book written by the Congressman. The rental is permissible under either of two proposed alternatives.


On October 12, 2021, Random House published a non-fiction book written by Congressman Schiff. The House Ethics Committee approved the publishing agreement between the Congressman and Random House. Random House would like to rent the Committee's email list "solely to promote the book." The requestors, Congressman Schiff and the Committee, propose that either Random House pay the Committee directly for the fair market value of the list rental or that the Congressman do so using his personal funds, and Random House reimburse him.


The Commission concluded that, under the circumstances described in the request, both of the proposed rental arrangements are permissible under the Federal Election Campaign Act and Commission regulations. The Commission did not agree on a rationale for this conclusion by four affirmative votes. In reaching this conclusion, Commissioners relied on different rationales, some of which are reflected in Agenda Doc. No. 21-37-A (garnering a vote of 3-3) and Agenda Doc. No. 21-37-B (garnering a vote of 3-3), but neither of those agenda documents is a Commission advisory opinion. Additionally, Chair Broussard and Commissioners Walther and Weintraub issued a concurring statement.

Date Issued: November 22, 2021; Length: 3 pages


  • Author 
    • Christopher Berg
    • Communications Specialist