LobbyComply Blog

The second regular session of the 132nd Legislature adjourned sine die after a veto session on April 29. Lawmakers passed two campaign finance bills, Legislative Documents 517 and 2000. Legislative Document 517 requires public communications that use synthetic media to include a disclaimer, and Legislative Document 2000 increased the monetary minimums for filing 24-hour PAC and independent expenditure reports. The general effective date for laws passed without an emergency designation is July 29. This does affect lobbying reporting; a registered lobbyist who anticipates no further lobbying for a client may file a request for a non-session waiver with their final monthly report for the session.

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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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Lawmakers passed a bill prohibiting a political action committee from accepting a contribution or expenditure from a foreign national, as defined by federal law. House Bill 1467 also amends reporting requirements by requiring affirmations of compliance. The bill also prohibits a foreign national from soliciting or directing a contribution or expenditure by another person to influence an election on a public question. The bill becomes effective July 1.

The Virginia Legislature officially passed and adopted Gov. Glenn Youngkin’s recommendation concerning Senate Bill 1427, which relates to campaign finance laws, political action committees (PACs), and certain large pre-election expenditures.

The bill changes some of the reporting dates while also adding an additional report.

The reports previously due on July 15 and October 15 will be due on June 1 and September 15 with an additional report due on October 15.

PACs must also report any single contribution received or expenditure made of $1,000 or more between the dates of May 26 and the third Tuesday in June, and between October 8 and the date of the November general election.

The bill will take effect on July 1.

The Ohio office of Secretary of State has published increased contribution limits.

The contribution limits for PACs, PCEs and individuals may contribute to statewide candidates, candidates for General Assembly, county parties, PACs, and PCEs increased from $13,704.41 to $15,499.69 per election; and from $41,113.24 to $46,499.08  per calendar year to state parties; and from $20,556.62 to $23,249.54 per calendar year to legislative campaign funds.

The amount of gifts corporations and labor unions may provide per year to a state political party, county political party, or legislative campaign fund, for certain specified purposes, such as facilities; equipment, and supplies, increased from $11,274.23 to $12,751.16.

The Wyoming State Legislature adjourned sine die March 3, after passing 196 bills during the 37-day session.

Among the passed bills, the legislature ratified Senate Bill 40. Senate Bill 40 closed an exemption for federal political action committees (PACs) active in Wyoming elections.

Under the new law, federal PACs must file state campaign finance reports unless they are solely making contributions or expenditures to federal candidates or issues.

Other major bills passed during the quick session include universal tax-relief and an omnibus bill focusing on rehabilitating the state’s water infrastructure.

Gov. Mark Gordon has signed a bill removing an exemption from state campaign finance reporting for federal political action committees (PACs) active in Wyoming elections.

Senate Bill 40 requires federal PACs to report in Wyoming unless they are making contributions or expenditures only to federal candidates or federal issues.

The law takes effect July 1.

The Vermont state’s Elections Division increased contribution limits.

Under the revised limits, contributions of up to $1,120 per election cycle may be made to state representative candidates, and contributions of up to $1,680 per election cycle may be made to state senate candidates.

Individuals and PACs may contribute up to $4,480 to statewide candidates and PACs per election cycle.

The adjusted limits represent a 6.4% increase for the entire 2024 election cycle.

The Arizona Secretary of State’s Office has increased campaign contribution limits for the 2023-2024 election cycle.

An individual may now contribute $5,400 per election cycle to a candidate committee for statewide office and legislative office.

Additionally, an individual may contribute $6,650 per election cycle to a candidate committee for district, county, town, and city office.

Contribution limits for PACs have also increased. A PAC without Mega PAC status may contribute $5,400 per election cycle to a candidate for statewide office.

In contrast, a PAC with Mega PAC status may contribute $10,800 per election cycle to candidates for statewide and legislative office, and $13,300 per election cycle to candidates for district, county, town, and city office.

These increases are implemented by the secretary of state in January of odd-numbered years.

The Tennessee Bureau of Ethics and Campaign Finance (BECF) published revised contribution limits for 2023 and 2024.

The per person limit to candidates for statewide office increased from $4,300 to $4,900 per election.

The per person limit for the Senate, House, and all other state and local offices increased from $1,600 to $1,800.

PAC limits to candidates for statewide office and for the House increased from $12,700 to $14,400 per election.

PAC limits to candidates for Senate increased from $25,400 to $28,800.

All other state and local office candidates receiving contributions from a PAC increased from $8,300 to $9,400 per election.

BECF adjusts contribution limits in January of each odd-numbered year based on the consumer price index.

The State Board of Elections published the new contribution limits summary sheet, which increases limits on January 1 of every odd-numbered year to reflect increases in inflation.

The amount corporations and labor organizations may contribute in each election cycle increased from $12,000 to $13,700 to any candidate committee; from $24,000 to $27,400 to any political party or legislative caucus committee; and from $24,000 to $27,400 to any PAC.

The amount an individual may contribute in each election cycle increased from $6,000 to $6,900 to any candidate committee; from $12,000 to $13,700 to any political party or legislative caucus committee; and from $12,000 to $13,700 to any PAC.

The amount PACs are limited to contributing to any candidate committee, political party committee, legislative caucus committee, or PAC each election cycle increased from $59,900 to $68,500.

“Going forward,” the Federal Election Commission (FEC) will require disclosure requirements for contributions received from limited liability companies (LLCs) be applied to independent expenditure-only political committees (i.e., Super PACs) in the same manner in which they are applied to all other political committees.

On April 15, four of the six commissioners issued a “Statement of Reasons” for their conclusion of a closeout of a complaint. In the statement, which refers to Matters Under Review (MUR) 7454, Chairman Allen Dickerson, Vice Chair Steven T. Walther, Commissioner Shana M. Broussard, and Commissioner Ellen L. Weintraub assert, “contributions from LLCs to committees must be attributed pursuant to Commission regulations, and those regulations apply to all committees, including [Super PACs]. The Commission will apply that understanding going forward, and may seek civil penalties in appropriate future cases.”

In MUR 7454, the Super PAC in question had not obtained the required attribution information for two contributions made by LLCs. The Super PAC attributed the contributions only to the LLCs. Regulations require committees to report certain attribution information for contributions from LLCs.

An LLC that has a single natural-person member and is not taxed as a corporation must be attributed only to the natural person member, and not the LLC. A contribution by an LLC that is disregarded for tax purposes and does not have a single natural-person member is treated as a partnership contribution; and, a partnership contribution must be attributed to both the partnership and each partner, either in proportion to his or her share of the partnership profits or by agreement among the partners.

In prior cases premised on similar facts, the FEC could not agree whether, following the Citizens United and SpeechNow.org v. FEC court decisions, LLC reporting rules and conduit contribution rules applied to contributions made to the newly formed Super PACs authorized by those judicial rulings. The commissioners determined that “with the passage of time, [Super PACs] have become a regular part of the campaign finance landscape, and…there is no longer a lack of clarity concerning the application of LLC reporting rules and conduit contribution rules in these circumstances.”

Because the FEC has not previously made this conclusion under similar cases, they did not seek a civil penalty against the Super PAC.

A bill has been introduced in the Senate setting new limits on political contributions.

Senate Bill 566 would reduce current limits on contributions to candidates from $2,800 to $1,000 per election.

Additionally, contributions to a PAC related to a particular election reduce from $5,000 to $1,000.

The bill would also reduce contributions limits to state party executive committees from $10,000 to $1,000 per calendar year.

The Seattle City Council is considering legislation limiting the ability of Super PACs to spend unlimited amounts of money in Seattle elections.

Council Member Lorena González introduced the Clean Campaigns Act to reduce the amount of money Super PACs funnel into elections.

The proposed legislation would limit Super PACs from receiving more than $5,000 per year from any single individual or corporation.

The act would also block multinational corporations, defined as companies with more than one percent ownership from a single foreign national or more than five percent ownership from multiple foreign nationals, from spending money on local elections.

Another proposed change would require all political advertising outside of election years to follow similar reporting requirements to current rules for election advertisements.

The Clean Campaigns Act is currently being considered in council chambers and could see a full council vote as early as next week.