Reminder: FEC Issues New Bundling Disclosure Rules
March 23, 2009

As a reminder, the new rules issued by the Federal Election Commission are now in effect that establish the reporting regime for bundled contributions raised or forwarded by federal Lobbying Disclosure Act registered lobbyists and LDA registrants (whether a lobbying firm or an entity employing in-house lobbyists), as well as by political committees established or controlled by registered lobbyists and LDA registrants.

In short, the new rule requires that the recipient "reporting committees” (federal candidate, political party, and leadership committees) file bundling disclosure reports with the FEC if they receive two or more bundled contributions exceeding the "reporting threshold," from a "lobbyist/registrant" or "lobbyist/registrant political action committee" during a specified period. The new rule is required by section 204 of the Honest Leadership and Open Government Act of 2007. In addition, those PACs that meet the definition of a "lobbyist/registrant" PAC under a new definition provided under the rules, must amend their Statement of Organization (Form 1) by March 29, 2009, to reflect this status. A "lobbyist/registrant PAC" is any political committee that a 'lobbyist or registrant' establishes or controls."

To review the new rule’s requirements in further detail, please reference the client advisory our Campaign Finance & Political Law practice prepared in February 2009. The client advisory, titled FEC Issues New Bundling Disclosure Rules is available by clicking here.