FEC Issues Two Advisory Opinions and Approves Audit Findings

WASHINGTON — The Federal Election Commission today issued two advisory opinions and approved findings in an Audit Division Recommendation Memorandum.

Advisory Opinion 2016-11 (Plains Cotton Growers) 

The Commission approved an advisory opinion in response to a request from Plains Cotton Growers, Inc. (PCG), a membership organization, and Plains Cotton Growers Political Action Committee (PCGPAC). The Commission concluded that the requestors’ proposal to solicit contributions from individual PCG members and to authorize other members to collect and transmit those contributions to PCGPAC is permissible under the Federal Election Campaign Act and Commission regulations. During the discussion, the Commission heard from the requestors’ representative.

Advisory Opinion 2016-14 (11 Libertarian State Committees) 

The Commission approved an advisory opinion in response to a request from 11 Libertarian State Committees (Alabama, Arkansas, Arizona, Hawaii, Idaho, Maryland, Mississippi, Missouri, New Mexico, North Dakota and Texas). The Commission concluded that the Committees qualify as state committees of a national political party. During the discussion, the Commission heard from the requestors’ counsel.

Advisory Opinion Request 2016-12 (Citizen Super PAC) 

The Commission discussed and held over for further consideration two drafts in response to an advisory opinion request from Citizen Super PAC, an independent expenditure-only political committee. The requestor asks several questions regarding the regulatory consequences of its proposal to send emails to a candidate with a link to Citizen Super PAC’s advertisement projects, including an ad expressly advocating for that candidate, and the consequences of other potential actions taken by the requestor and that candidate. During the discussion, the Commission heard from the requestor’s counsel.

Proposed Amendments to Directive 52 

The Commission held over discussion on amendments to Directive 52, which governs the agency’s circulation vote procedures.

Audit Division Recommendation Memorandum on Conservative Campaign Committee 

Prior to the meeting, the Commission approved the Audit Division Recommendation Memorandum on the Conservative Campaign Committee. The Commission approved findings related to reporting of apparent independent expenditures and failure to file 24/48-hour reports for independent expenditures, and recordkeeping for communications.