FEC Updates Functionality of Form 99: Miscellaneous Report to the FEC

On March 6, the Federal Election Commission (FEC) announced in its press release digest it recently updated its electronic form for the submission of miscellaneous items by registered committees. The form, Form 99: Miscellaneous Report to the FEC, is now implemented with new functionality for the electronic filing of uncategorized items, such as letters and similar matters. Committees may upload PDF documents as part of their submissions. According to the FEC, the update form will allow committees to file Schedule C-1s (Loans and Lines of Credit from Lending Institutions), copies of loan agreements, loan forgiveness statements, and Form 8s (Debt Settlement Plans), electronically as attachments with electronic signatures, including required third-party signatures. Before the implementation of this new functionality, filers could be required to file documents with third-party signatures on paper.

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Today, the Federal Election Commission (FEC) published its price index adjustments for expenditure limitations and the federal lobbyist bundling disclosure threshold. The lobbyist bundling disclosure threshold has increased for 2026 from $23,300 to $24,000. This threshold amount is adjusted annually. Federal law requires authorized committees of federal candidates, leadership political action committees (PACs), and political party committees to disclose contributions bundled by lobbyists and lobbyists’ PACs. Additionally, the FEC published its adjusted Coordinated Party Expenditure Limits for political parties for 2026.

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On February 11, President Donald J. Trump nominated two members of the Republican Party, Ashley Stow and Andrew Woodson, to serve as commissioners on the Federal Election Commission (FEC).  Since April 30, 2025, the FEC has not had a quorum of four commissioners. Three of the six seats on the FEC became vacant when Commissioner Allen J. Dickerson resigned. Because all decisions must have four commissioners’ votes, no official action has been made by the FEC since then. Additionally, since October 3, 2025, when Commissioner James E. “Trey” Trainor III officially resigned, the FEC has had only two commissioners, Shana M. Broussard and Dara Lindenbaum, both members of the Democratic Party. No more than three commissioners of the six commission seats can be from the same party. The two newly announced nominees must be confirmed by the U.S. Senate. While a quorum will be restored if they are both confirmed, two seats on the commission will remain vacant. 

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Sometime before July 8, 2026, a by-election will be announced for the seat in the House of Commons representing University–Rosedale in the province of Ontario. On January 9, the Chief Electoral Officer of Canada, Stéphane Perrault, received official notice from the Speaker of the House of Commons that the seat for University–Rosedale (Ontario) became vacant on January 9, following the resignation of Chrystia Freeland. Freeland left her seat in order to become the Warden of Rhodes House and CEO of the Rhodes Trust, which is best known for granting the Rhodes Scholarship. Under the law, the by-election date must be announced by July 8 and will signal the start of the by-election period. According to Elections Canada, the earliest date the by-election can be held is March 2, 2026.

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Sometime before August 1, 2026, a by-election will be announced for the seat in the House of Commons representing Scarborough Southwest in the province of Ontario. On February 3, the Chief Electoral Officer of Canada, Stéphane Perrault, received official notice from the Speaker of the House of Commons that the seat for Scarborough Southwest (Ontario) became vacant on February 2, following the resignation of Bill Blair. Blair left  his seat in order to become the Canadian High Commissioner to the United Kingdom. Under the law, the by-election date must be announced between February 13 and August 1, 2026, and will signal the start of the by-election period. According to Elections Canada, the earliest date the by-election can be held is March 23, 2026.

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On February 9, Ontario’s Chief Electoral Officer Greg Essensa received an official warrant from the Speaker of the Legislative Assembly confirming the seat for the Scarborough Southwest electoral district was vacant. Doly Begum, who has held the seat since 2018, resigned on February 3  to run in the upcoming Scarborough Southwest federal by-election. As required by law, a by-election for the seat must be called by August 5, 2026, which is within six months of the Chief Electoral Officer’s notice. The earliest possible date for the election is March 12, and the latest possible date would be September 3.

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On February 23, a by-election will be held in the electoral division of Chicoutimi for a seat in the province’s National Assembly of Quebec. The seat became vacant on September 4 of last year following the resignation of Andrée Laforest, who left her position for an unsuccessful run to become the mayor of Saguenay. Under a decree issued by the Government of Québec on January 20, the Chief Electoral Officer, Mr. Jean-François Blanchet, will oversee the organization of the election. Advance polling for voting will begin on February 15.

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On January 19, the lobbyist registration threshold for organizations and corporations was lowered. Last year the Office of the Commissioner of Lobbying of Canada issued new interpretation bulletins concerning the significant part of the duties threshold for when organizations and corporations must be registered under the Lobbying Act. One bulletin lowered the lobbyist registration threshold from 32 hours per month to eight hours in a rolling four-week period. A second updated interpretation addresses the Lobbying Act’s revolving door provision and interprets a significant part of a designated public office holder’s work as eight hours or more in any given consecutive four-week period. This includes any time spent preparing for and participating in oral communications with public office holders, as well as drafting written communications to public office holders.

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On January 7, Kenyan McDuffie resigned from his seat with the Council of the District of Columbia. McDuffie, an independent with an at-large seat who served more than 13 years on the D.C. Council, resigned in order to consider running for mayor. According to the District’s Home Rule Act, when a councilmember with no party affiliation leaves office, the council must make an appointment until the vacancy can be filled in a special election. DC Council Chairperson Phil Mendelson is expected to select a nominee within the next few weeks. The full council will then vote on the nomination, with at least seven votes required for confirmation. A special election must be held no later than 174 days after a vacancy.

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Campaign contribution limits increased in British Columbia for 2026 to $1,513.29 for contributions to registered political parties, including their candidates, nomination contestants and registered constituency associations. Additionally, individuals can also contribute up to $1,513.29 to independent candidates and leadership contestants, if a leadership contest is called in 2025. The previous limits from 2025 were $1,484.38 and $1,450.82 in 2024. Also increased to $430 is the limit of a fee paid to attend a leadership convention or other convention of a political party without counting toward the $1,513.29 contribution limit. These contribution amounts are adjusted at the start of each calendar year.

Campaign contribution limits increased for municipalities in British Columbia for 2026 to $1,429.70 for local elections candidate or elector organization per campaign. For a local by-election held in 2026, unendorsed candidates may contribute an additional $1,429.70 to their own campaign, and a group of endorsed candidates may contribute an additional $1,429.70 in total to the campaign of the elector organization.

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On December 9, the U.S. Supreme Court heard arguments concerning certain campaign finance restrictions and whether they should be struck down. The issue specifically addressed before the court was the constitutionality of legal restraints on how much political parties can spend on their own campaign advertising if it is done in cooperation or coordination with the candidates the party wants to get elected. In National Republican Senatorial Committee v. Federal Election Commission, plaintiffs argued the limits on coordinated party expenditures violate the First Amendment, either on their face or as applied to party spending in connection with party coordinated communications.

This case is an appeal from a decision by a 10-judge majority of the en banc Sixth Circuit Court of Appeals, which had previously upheld the limitations as constitutional. In doing so, the lower court acknowledged that while the U.S. Supreme Court had addressed the free-speech restrictions on campaign finance regulation in recent years, but any new assessment of the validity of the limits would need to be addressed by the U.S. Supreme Court.

A decision is expected in July of 2026.

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The Federal Election Commission (FEC) is requesting public input on a draft of a new five-year Strategic Plan for the commission. The stated objectives of the plan are to focus on engaging and informing the public about campaign finance data, interpreting the Federal Election Campaign Act and related statutes while simultaneously promoting compliance with those laws, and fostering a culture of high individual and organizational performance.

The FEC’s Draft Strategic Plan, FY 2026-2030 is available at https://www.fec.gov/resources/cms-content/documents/Draft_FEC_Strategic_Plan_2026-2030.pdf.

Comments may be submitted via email at StrategicPlanComments@fec.gov through November 30, 2025.

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On October 27,  Attorney General Doug Downey announced comprehensive proposals to change Ontario’s dates of elections, increase its political contribution limits, eliminate pre-writ spending limits for third parties, and alter other provincial campaign finance laws.

The reforms, announced in a news release by the government of Ontario, would eliminate “American-style fixed election dates” in favor of provincial elections taking place on a date determined by the lieutenant governor on the advice of the premier, but within the five-year maximum limit mandated by the province’s constitution.

Beginning in 2026, individuals’ contribution limits to a political party would be raised from $3,400 to $5,000. Future increases would be indexed to the rate of inflation.

In addition to eliminating third party and political party pre-writ spending limits, the government proposes establishing new financial penalties for those not in compliance with the Election Finances Act.

The amendments to the law would also provide new investigative powers to the Chief Electoral Officer to request information from third parties to ensure they are in compliance with political advertising rules. The proposed changes to the law also include requiring third parties to provide proof of registration status to broadcasters and publishers before placing political advertisements during an election period. 

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On October 3, Federal Election Commission (FEC) Commissioner James E. “Trey” Trainor III plans to officially resign from his position.

The FEC will then have only two commissioners, Shana M. Broussard and Dara Lindenbaum, both members of the Democratic Party. The FEC requires at least four commissioners to agree on any official action. No more than three commissioners can be from the same party. As it stands, because all decisions must have four commissioners’ vote, no official action can be made by the FEC until the president nominates and the Senate confirms another two commissioners.

According to the Washington Examiner, Trainor is considering a run for the U.S. House of Representatives seat being vacated by Rep. Chip Roy, who has entered the Texas republican party primary to run for attorney general.

While Commissioner Broussard will continue to serve as Chair of the Commission for the remainder of 2025, Trainor’s resignation also means the position as Vice-Chairman will be vacant unless filled by the remaining commissioner, Lindenbaum.

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