In signing the omnibus appropriations bill into law on December 16, 2014, the President created new vehicles for making increased contributions to national political party committees. The Federal Election Commission, which is responsible for implementing and administering the federal campaign law, has issued a statement that it is reviewing the changes and will provide its own “guidance as soon as practicable”.
Under the prior law an individual donor could contribute up to $32,400 per year and a multi-candidate Political Action Committee (PAC) could contribute up to $15,000 per year to each national political party committee. The Republican National Committee (RNC) and the Democratic National Committee (DNC) are covered by the new provisions, as are the respective Republican and Democratic Senate Campaign Committees (NRSC & DSCC) and the Congressional Campaign Committees (NRCC & DRCC).
Going forward each of the aforementioned national party committees will still be eligible for funding under the prior law but they may now also establish special “separate, segregated accounts,” each of which can accept up to $97,200 per year from an individual and up to $45,000 per year from a multi-candidate PAC. Therefore, an individual will be able to contribute up to $777,600 per year to support the national party committees.
The RNC and DNC alone may establish party convention accounts which are meant to replace the eliminated government funding of national party nominating conventions, and have a spending cap of $20 million with respect to any single convention.
All national party committees may also establish a building headquarters account, which allows funds to defray expenses incurred with respect to the ownership, leasing, operation, and furnishing of one or more headquarters buildings.
Finally, all of the national party committees may establish a recount fund to defray expenses incurred with respect to the preparation and conduct of election recounts, contests, and other legal proceedings.
The below chart reflects the new limits for each of the national committees, including the newly permitted segregated funds. Major donors should anticipate being asked for these significantly larger contributions in 2015, while the party committees await guidance from the FEC on issues such as what if any restrictions will be imposed on the “other legal proceedings” portion of the new recount fund.