North Dakota Secretary of State Issues New Guidance for FED PACs

The Office of the Secretary of State is requesting federal PACs continue to report as they have in the past until the impact of a recent opinion by the Attorney General is clarified. North Dakota Attorney General Letter Opinion 2025-L-01 required federal PACs to report as a state PAC, in addition to the specified statutory provisions simply requiring federal PACs to file a copy of their FEC reports disclosing the state activity. In consultation with the Office of Attorney General, the Office of Secretary of State is implementing a hold on changes to reporting for federally formed PACs until greater clarity can be provided. The opinion has raised a number of questions because federal PACs have a statutory exemption from registration as a state PAC when complying with the FEC copy requirements. 

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