Atlas Worldwide AO
The FEC approved Advisory Opinion 2011-25, requested by Atlas Air Worldwide Holdings, Inc. (Atlas Worldwide). In its request, Atlas Worldwide asked whether the Atlas Worldwide PAC could solicit contributions from certain senior managers (former pilots) who are "inactive" members of the union that represents pilots at two subsidiary companies of Atlas Worldwide. While these managers retain their seniority rights should they rejoin the union and receive newsletters and union communications, they do not pay dues or have voting rights. The FEC determined that such managers are "executive or administrative personnel" of Atlas Worldwide that may be solicited as part of the restricted class. FEC regulations exclude employees represented by a labor union from the restricted class of a corporation. Because the Atlas Worldwide pilots are salaried employees and exercise substantial responsibility in assisting the management and running of the business, they qualify as executive or administrative personnel of the corporation, and are thus solicitable.
Western Representation PAC AO
The FEC approved Advisory Opinion 2011-28, which denies a request by Western Representation PAC to waive campaign finance reporting obligations for online political advertising through Facebook. The FEC held that such online ads, funded by unlimited contributions to the Super PAC, would be subject to the 24 and 48-hour independent expenditure reports.
President Obama has not nominated any individuals to serve as FEC Commissioners, despite five of the six Commissioners serving expired terms and a general partisan stalemate. The League of Women Voters spearheaded a petition from campaign reform groups asking Obama to appoint new Commissioners. Because this petition gathered more than 25,000 signatures, the president is expected to issue a formal response.
Update to Party Expenditure Limits and Bundling Threshold
On February 21, the FEC published in the Federal Register a notice of adjustments to expenditure limitations and the lobbyist bundling disclosure threshold for 2012. The expenditure limitation for national and state party committees for each general election held to fill a seat in the House of Representatives in states with more than one congressional district is $45,600. For Senate races and states with only one congressional district, the expenditure limitation for the congressional district is $91,200, while the limit for Senate races is based on a formula that takes into account the voting age population, but is no less than $91,200. The national party committee expenditure limitation for the presidential election is $21,684,200. Finally, the threshold for certain political committees to disclose contributions bundled by lobbyists and lobbyist registrant PACs is $16,700.
FEC Filing Deadlines
The following lists key filing deadlines for 2012 PAC reports:
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Political committees that make independent expenditures during 2012 are required to disclose this activity at any time up to and including the 20th day before an election each time the expenditures aggregate $10,000 or more. This disclosure is required within 48 hours. Committees that make independent expenditures aggregating $1,000 or more during the last 20 days of, and up to 24 hours before, an election must disclose this activity with 24 hours. Entities that make disbursements for electioneering communications in 2012 that aggregate $10,000 or more must disclose this activity within 24 hours of public distribution of the communications. Future FEC Meeting Dates The following lists upcoming dates for FEC open meetings and closed executive sessions through June 2012:
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