AO 2025-05: Commercial vendor may offer contribution processing services and candidate meeting information to users and subscribers
Politicalmeetings.com (PM.com) may allow its subscribers to make small monthly contributions to candidates and national political party committees via its web-based platform and provide subscribers access to non-public information about political meetings and events with candidates. The Commission concluded that PM.com’s proposed activities would not result in the making of contributions from PM.com or from its sole member to candidates or national political party committees.
Background
A single member LLC, PM.com has developed an online platform that allows paying subscribers to make small monthly contributions to candidates and political party committees and provides non-public information about political meetings and events with candidates and committees.
Candidates, political party committees, and other political committees may also participate in PM.com’s platform, either without charge or through two tiers of paid profiles that include additional services.
PM.com will use a pay gateway company to process contributions and administrative fees paid by the subscriber.
Analysis
In previous advisory opinions (cited within the opinion), the Commission has determined that the provision of contribution-processing services to a political committee by a commercial vendor does not constitute a contribution to the political committee if:
- The vendor renders services in the ordinary course of business and at the usual and normal charge;
- The vendor forwards contributions through a segregated account to candidates and political committees, and;
- The vendor employs adequate screening procedures to ensure that they are not forwarding illegal contributions.
The Commission concluded that PM.com’s proposed business model meets all three criteria.
Accordingly, PM.com’s proposal to allow its subscribers to make small, monthly contributions to candidates and national political party committees and to provide them with non-public information about political meetings and events with candidates and committees is permissible under the Federal Election Campaign Act and Commission regulations.
Date issued: April 30, 2025; Length: 8 pages
Citations
Regulations
11 CFR §100.52
Gift, subscription, loan, advance or deposit of money.
Advisory opinions
AO 2021-07
PACMS
AO 2019-04
Prytany LLC
AO 2018-05
CaringCent, LLC
AO 2017-06
Stein and Gottlieb
AO 2016-08
eBundler.com
AO 2015-15
WeSupportThat.com
AO 2014-07
Crowdpac
AO 2012-22
skimmerhat
AO 2011-19
GivingSphere
AO 2011-06
Democracy Engine
AO 2007-04
Atlatl