Lobbyist Bundling Rules

This week, our campaign finance update is a refresher on Lobbyist Bundling rules.

The disclosure of bundled contributions to federal candidates, leadership PACs and party committees was a provision in HLOGA, but it is a reporting requirement imposed on the recipient committees, not the lobbyists or lobbyists PACs that engage in fundraising and bundling of contributions.

The FEC finalized the bundling regulations in 2009, which include certain requirements for reporting bundled contributions.

  • Any PAC controlled by an individual lobbyist or an association registered to lobby should have amended its PAC statement of organization by March 29, 2009 disclosing that the PAC is a “Lobbyist/Registrant PAC”. All new PACs established or controlled by a registered lobbyist or organization must now indicate the lobbying relationship when filing the initial statement of organization.
  • Candidate committees, leadership PACs and national party committees are now required to disclose the names of lobbyists who bundle two or more contributions totaling more than $16,0005 during a reporting period.

The regulations define two categories for “bundled” contributions:

  1. Contributions forwarded by a lobbyist or a PAC controlled by a lobbyist or registrant
  2. Contributions credited to a lobbyist or a PAC controlled by a lobbyist or registrant

Next week, we’ll look at the definitions of “forwarded” and “credited,” as  detailed by the FEC’s final regulations published in February 2009.

This post is condensed from the Lobbying Compliance Handbook.

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