Don't Sweat the Details...Unless You're Filing at the FEC


Few federal agencies have rules as picky, or as confusing, as the Federal Election Commission. But surely minor transgressions in reports won’t have any significant repercussions, right? Well, maybe.

Bacardi USA PAC recently filed an amended statement of organization that failed to include addresses for its treasurer and for the PAC’s bank. This prompted the FEC to seek clarification through a request for additional information, known in the campaign finance world as a “RFAI.” To get square with the FEC, the PAC filed an amended report with the omitted information. Simple enough.

RFAIs are quite common and rarely newsworthy. In this case, however, the RFAI came to the attention of the Washington Post’s Al Kamen, author of the In the Loop column. Mr. Kamen was “inspired” to provide an analysis of the PAC’s spending in 2013 and 2014, and the company’s lobbying expenditures during the same period. You can find the article at this link. Most PACs do not welcome this type of publicity, and surely Bacardi must have been curious as to the source of Mr. Kamen’s inspiration.

This minor campaign finance vignette offers some important take-aways. Review your FEC filings carefully – even seemingly mundane reports, such as a statement of organization. Remember that plenty of folks are watching what you do – business competitors, watch dog groups, the media, and others. And never forget that Murphy’s law is always at play. The odds are small that a missing address will result in an article in a national paper. But it happens.


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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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