LobbyComply Blog

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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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 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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On September 2, the Federal Election Commission (FEC) will release version 8.5 of its FECFile electronic filing software.

This update applies whether a committee uses FECFile or a third-party commercial product. Both will require an update to the software for filings on or after September 2.

Changes of electronic filing specifications required with the software update include the following: filers will be required to provide the FEC with the committee name, committee identification, and committee type when listing joint fundraising participants on form 1 or form 1-S; when filing a form 99 , committees will be required to categorize their submission; if a committee selects filing frequency change notice or form 3-L filing frequency change notice on a form 99, they will be required to denote whether their new filing frequency is monthly or quarterly; and when filing a loan agreement/loan forgiveness on a form 99, committees will now have the option to attach a pdf file of up to 150 pages.

The Federal Election Commission (FEC) announced a new sample donor response form for contributions made by limited liability companies (LLCs).

Committees are required to report certain attribution information for contributions from LLCs. To assist committees and encourage compliance the FEC adopted the new sample donor response form, which was announced on April 16.

The form will help satisfy a committee requirement to show its “best efforts” to obtain, maintain, and submit information mandated by law. By requesting completion of the sample form by the donor following the receipt of the contribution, a committee is in a stronger position to be in compliance.

Current regulations require LLCs provide accurate and complete attribution information to the recipient committee at the time that a contribution is made. The LLC must also affirm to the recipient committee that the LLC is eligible to make the contribution.

On January 3, 2025, the U.S. Federal Register is scheduled to publish the Federal Election Commission’s announcement of its civil monetary penalty amounts, adjusted for inflation, for 2025.

The potential fines for civil violations of federal campaign finance laws will increase to range from $ 7,445 to $87,056, from the previous range of $ 7,256 to $ 84,852.

The amounts are calculated through a statutory formula applying the most recent “cost-of-living adjustment multiplier,” issued by the Office of Management and Budget, to the current amounts.

The amended civil monetary penalties are expected to take effect as of January 3, 2025, the publication date in the Federal Register.

On December 19, the Federal Election Commission (FEC) published a Notice of Proposed Rulemaking in the Federal Register seeking public comment on proposed regulations giving political contributors more privacy from public scrutiny.

The proposals would establish procedures for contributors or their agents to request the FEC to modify or redact, in whole or in part, certain contributor information from disclosure reports or statements filed with the agency.

Examples of information to be removed include mailing addresses, donors’ occupation and names of employment.

The procedures would apply only in certain limited circumstances when there is a reasonable probability the contributor may face threats, harassment, or reprisal.

Comments must be received on or before February 18, 2025. All comments will be made available to the public. Comments sent using the FEC’s online form or through e-mail will be posted to the FEC’s website. Comments sent via paper will be converted to PDF and then posted on the FEC’s website.

On December 12, the Federal Election Commission (FEC) elected Vice Chair Ellen L. Weintraub as chair for 2025.

Weintraub will replace current Chairman Sean J. Cooksey. The chair is a rotating, one-year position.

Also, Commissioner James E. “Trey” Trainor, III was elected to the position of vice chair.

Vice Chair Weintraub has served on the FEC since 2002.

On November 25, the Federal Election Commission (FEC) Office of the Inspector General (OIG) released its Semiannual Report to Congress.

The report summarizes the activity of the FEC OIG from April 1, 2024, through September 30, 2024.

In the report, the OIG discussed the audit of FEC’s Equal Employment Opportunity & Diversity, Equity, Inclusion, and Accessibility programs; its audit of the FEC’s Security Patches and Vulnerability Management program, and the postponement of an evaluation of the FEC’s Internal Control and Enterprise Risk Management programs.

Additionally, the OIG evaluated the 18 open recommendations stemming from inspections, investigations, special reviews, and previous or other audits.

On September 8,  the Federal Election Commission (FEC) announced it was seeking public input on ways to improve its report filing processes and public website.

The FEC is interested in recommendations and comments regarding potential opportunities for improving the process for filing required disclosure reports and for improving the organization, substance, and how to best provide the public with easily accessible information on its website.

Comments must be in writing and submitted by email to publiccomment2023-14@fec.gov. The comment window will close 60 days after publication of the Notification of Request for Public Comment in the Federal Register.

On May 2, U.S. Rep. Yvette D. Clarke introduced legislation into the U.S. House of Representatives to require disclosure of political campaign content created by artificial intelligence.

House Bill 3044 amends the Federal Election Campaign Act of 1971 (FECA) to provide transparency and accountability for the use of content generated by artificial intelligence (generative AI) in political advertisements.  It requires such advertisements to include a statement within the contents of the advertisements if generative AI was used to generate any image or video footage in the advertisements. The bill also expands FECA’s definitions of online platform.

If passed, the Federal Election Commission (FEC) would be required to make regulations within 120 days of the day of the enactment of the bill. Additionally, the bill explicitly states the legislation would come into effect on or after January 1, 2024, even if the FEC has not yet promulgated regulations to carry out the new law.

The bill, entitled the Require the Exposure of AI–Led Political Advertisements Act (REAL Political Advertisements Act) has been referred to the House Committee on House Administration.