FEC Announces Bundling Disclosure Threshold and Coordinated Expenditure Limits for 2022

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In February, the Federal Election Commission (FEC) announced the new coordinated expenditure limits and the lobbyist bundling disclosure threshold for 2022. By law, the FEC must adjust these amounts annually for inflation based on the price index provided by the U.S. Department of Labor.

Bundling Disclosure

Federal campaign committees, federal leadership PACs, and federal political party committees are required to file FEC Form 3L if they receive two or more contributions bundled by federally registered lobbyists, registrants under the federal lobbying laws, or PACs controlled by either in excess of the indexed disclosure threshold within a reporting period. The indexed disclosure threshold for 2022 is $20,200.

Coordinated Party Expenditures

Federal law allows national party committees to make coordinated expenditures up to certain limits for candidates for House, Senate, and President. State political party committees may make coordinated expenditures up to their own separate limits for House and Senate candidates in their state, but they do not have a separate limit for coordinated expenditures on behalf of presidential candidates.

Coordinated expenditure limits for Senate candidates are based on the price index as well as the voting-age population in each state. Coordinated expenditure limits for Senate candidates in 2022 vary from $109,900 to $3,348,500, depending on the state.

Coordinated expenditure limits for House candidates are based on the price index. For 2022, the coordinated expenditure limit for House candidates in states with more than one congressional district is $55,000, while the limit for candidates in states with one congressional district is $109,900.

The Federal Register notice listing the 2022 coordinated expenditure limits and lobbyist bundling disclosure threshold is available here.

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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