AO 2024-07: Campaign may engage in joint fundraising with a Super PAC

A candidate's principal campaign committee may participate in a joint fundraiserwith a Super PAC, so long as the committee and other entities affiliated with or acting on behalf of the candidate neither solicit, receive, direct, transfer or spend federally-impermissible funds nor engage in coordinated communicationswith the Super PAC.

Background

Team Graham, the principal campaign committeeof Senator Lindsey Graham, currently participates in the Graham Majority Fund (Joint Fundraising Committee), a joint fundraising representative registered with the Commission. The other participating members of the Joint Fundraising Committee are Fund for America's Future, Graham's Leadership PAC, and the National Republican Senatorial Committee (NRSC).

Team Graham asks if it may amend the joint fundraising agreement to add a Super PAC as a participant. The expanded Joint Fundraising Committee will adhere to the applicable source prohibitions, contributionlimits and the agreed upon allocation formula. Team Graham further states that although solicitations, invitations, and other fundraising related communications may be coordinated among the participating committees, the campaign will not discuss its nonpublic plans, projects, activities or needs with the Super PAC.

Analysis

The Commission concluded that Team Graham may amend the joint fundraising agreement to include a Super PAC as proposed for two reasons. First, neither Team Graham nor any other entity established, financed, maintained, or controlled by Senator Graham or acting on his behalf will solicit, receive, direct, transfer or spend funds that do not comply with the contribution limits, source prohibitions, and reporting requirements of the Federal Election Campaign Act. Second, neither Team Graham, Senator Graham, nor their agents will engage in coordinated communications with the Super PAC.

Date issued: August 29, 2024; Length: 9 pages

Citations

Regulations

11 C.F.R. § 102.17
Joint fundraising by committees other than separate segregated funds

11 C.F.R. § 109.21
What is a "coordinated communication"?

Statutes

52 USC § 30125
Soft money of political parties

Resources

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