Sarah Palin this week launched Sarah Pac‘s new website, an indication that she may be seriously considering a run for the GOP candidacy for president in 2012. While the former vice presidential candidate does have quite a following, she does not have one key thing she needs to begin organizing for a 2012 election: contact info for these supporters. The page also serves as a landing ground for would-be donors to contribute to Sarah Palin’s campaign efforts, stating that Sarah PAC can accept up to $5,000 annually from individuals. According to FEC guidance, this is still considered a solicitation, despite the fact that the PAC is not directly asking for contributions.
The bundling rules for lobbyist contributions to PACs (including leadership PACs, of which Sarah PAC is one) state that the PAC must reveal the name of lobbyists who bundle two or more contributions totaling more than $16,000 during a reporting period. While it does not impose any specific obligation on the lobbyist, it is important to note that the PACs may expect lobbyists who bundle contributions to cooperate with their efforts to report contributions.
Forwarded contributions are defined as any contribution delivered physically or electronically to the candidate by the lobbyist (or non-lobbyist employee of a registered lobbying entity). Credited contributions are less concrete, and presuppose that committees know who is raising funds for the committee. Contributions must be credited and received by the campaign committee to be subject to disclosure. Written records, designated titles, event invitations, and mementos can all determine “credit,” and they do not have to be documented to be applied.