FEC Form 3L due in July

Certain Leadership PACs, candidate committees and political party committees may be required to file FEC Form 3L in July, some for the first time. Under the new lobbyist bundling disclosure rules, "reporting committees" (authorized committees, Leadership PACs and political party committees) must disclose certain information about lobbyists/registrants and lobbyist/registrant PACs that forward, or are credited with raising, two or more bundled contributions aggregating in excess of $16,000 during a specific covered period. See 11 CFR 104.22(a)(6). Recordkeeping requirements went into effect on March 19, 2009, and compliance with the reporting requirements took effect on May 18, 2009. See https://www.fec.gov/updates/final-rules-on-reporting-contributions-bundled-by-lobbyists-registrants-and-their-pacs/ for more information.

Form 3L July deadlines by filing frequency

Committees file their FEC Form 3L, as necessary, on the same schedule as they file FEC Form 3, 3X or 3P. Committees that file Form 3X and 3P on a monthly basis may elect to file Form 3L quarterly, instead of monthly. 11 CFR 104.22(a)(5).

Candidate committees that file Form 3L quarterly are required to file by the July 15, 2009, quarterly filing deadline. Leadership PACs and party committees that would file Form 3L quarterly during an election year are required to file only semiannually during a non-election year and thus must file Form 3L by July 31, 2009, for the semi-annual covered period. A committee must file Form 3L if a lobbyist/registrant or lobbyist/registrant PAC forwards to that committee or is credited by that committee with raising two or more bundled contributions that total more than $16,000 during April 1 through June 30, 2009 (for lobbyist/registrant bundlers), or April 18 through June 30, 2009 (for lobbyist/registrant PAC bundlers).

Leadership PACs, parties and Presidential committees that file Form 3L monthly are required to disclose lobbyist bundling activity on Form 3L by July 20, 2009, if they receive two or more bundled contributions that aggregate more than $16,000 for the month of June.

In addition to the above requirements, all reporting committees must also file Form 3L in July if they received two or more bundled contributions that aggregate more than $16,000 during the six month semi-annual covered period. Note that, due to the March and April 2009 effective dates for these rules, the semi-annual covered period for the July 2009 report does not begin on January 1. Instead, it begins on March 19 (for individual bundlers) and April 18 (for PAC bundlers), and runs through June 30, 2009. In future years, the semi-annual covered period will span the full six-month period from January 1 through June 30.

Reporting committees that are monthly filers of FEC Form 3, 3X or 3P that wish to change their FEC Form 3L filing frequency from monthly to quarterly or from quarterly to monthly must first notify the Commission in writing and will receive a letter indicating the Commission's acknowledgment of the request. Electronic filers must file this request electronically. A reporting committee may change its Form 3L filing frequency only once in a calendar year. 11 CFR 104.22(a) (5)(iv). The committee will receive an acknowledgment letter from the Commission. All subsequent Form 3L reports should be filed on the new schedule.

Disclosure requirements for reporting committees

Reporting committees that trigger the lobbyist bundling disclosure requirement must use FEC Form 3L (Report of Contributions Bundled by Lobbyists/Registrants and Lobbyist/Registrant PACs). The information to be disclosed includes:

• Name of each lobbyist/registrant or lobbyist/registrant PAC;
• Address of each lobbyist/registrant or lobbyist/registrant PAC;
• Employer of each lobbyist/registrant (if lobbyist/registrant is an individual);
• The aggregate amount of bundled contributions forwarded by each lobbyist/registrant or lobbyist/registrant PAC or received from the contributor and credited to each lobbyist/registrant or lobbyist/registrant PAC by the reporting committee during the covered period. 11 CFR 104.22(b)(1); and
• The aggregate amount of refunds of bundled contributions returned to each lobbyist/registrant or lobbyist/registrant PAC by the reporting committee during the covered period. (See Explanation and Justification, 74 FR 7298 (February 17, 2009)).

For more information about these filing requirements, see the March 2009 issue of the Record, page 1. Electronic filers are required to file FEC Form 3L electronically. The Commission's electronic filing software, FECFile, is free and can be downloaded from the FEC's website. New FECFile Versions are available for download from the FEC website at https://www.fec.gov/help-candidates-and-committees/filing-reports/fecfile-software/. All reports filed after May 14, 2009, must be filed in Format Version 6.4.1.0 (the new version). Consult the electronic filing page at http://www.fec.gov/efiling for up-to-date information. A paper version of FEC Form 3L is available for download and printing on the FEC website at https://www.fec.gov/help-candidates-and-committees/forms.