Commission issues notice of disposition on REG 2019-03 (Mailing Lists)
The Commission has decided not to initiate a rulemaking in response to Campaign Legal Center’s petition that sought to require reporting of equal-value mailing list exchanges.
The Commission noted that it had previously considered this issue in REG 2003-03 (Mailing Lists). Absent compelling evidence of a need to reopen the matter, the Commission concluded that initiating a new rulemaking would not be a good use of agency resources. Additionally, the Commission is not aware of any widespread misuse of mailing list exchanges to thwart the purpose of the Federal Election Campaign Act (the Act) and warrant Commission rulemaking action. Lastly, the context in which the terms “all receipts” and “all disbursements” appear in the Act validates the Commission’s longstanding conclusion that equal-value exchanges of mailing lists are “non-reportable events.”