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  • FEC Record: Advisory opinions

AO 2022-13: Conversion of leadership PAC to authorized committee of candidate

August 22, 2022

A leadership PAC that had been its sponsor’s 2020 Senate campaign committee and has not raised any funds outside the limits applicable to authorized committees may convert to an authorized committee for the candidate’s current House campaign. Alternatively, the PAC may revert to its previous designation as his 2020 Senate campaign committee.


Dr. Al Gross was a candidate for the United States Senate in Alaska in 2020, and his principal campaign committee was Dr. Al Gross for U.S. Senate. Following his unsuccessful candidacy, his principal campaign committee filed an amended Statement of Organization to convert the authorized committee to a nonconnected committee called the Northern Leadership PAC (the Committee).

The Committee “has operated at all times in a manner consistent with an authorized committee, despite its brief conversion on paper,” and has not raised any funds outside the limits applicable to authorized committees. The Committee wishes to be able to transfer its remaining funds to Al Gross for Congress, Dr. Gross’s principal campaign committee for his current campaign for the United States House of Representatives. Al Gross for Congress would use these funds to wind down its campaign operations and to satisfy remaining debts in connection with Dr. Gross’s congressional campaign, or for a future campaign for federal office.


According to the Committee it “has not supported more than one candidate with contributions of more than $2,000 per election,” which is the limit applicable to authorized committees. Additionally, the Committee states that it has not “raised a single dollar after conversion and never accepted any funds in excess of the limits and restrictions on authorized committees.” The Commission determined that under these circumstances, the Committee may convert to an authorized committee of Dr. Gross in his current House campaign. Alternatively, the Committee may revert to its previous designation as Dr. Gross for U.S. Senate.

Date issued: August 11, 2022; Length: 5 pages


11 C.F.R. § 100.5
Political committee

11 C.F.R. § 102.12
Designation of principal campaign committee

11 C.F.R. § 102.13
Authorization of political committees

11 C.F.R. § 110.2
Contributions by multicandidate political committees

11 C.F.R. § 113.1

11 C.F.R. § 113.2
Permissible non-campaign use of funds


  • Author 
    • David Garr
    • Communications Specialist