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Requests for Legal Consideration by Commission


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Requests for Legal Consideration by Commission

(Shown in reverse chronological order)

Election Cycle
Subject Matter Citations
Original Request
OGC Memorandum with Recommendation [PDF]
Vote Certification [PDF]
Other Documents [PDF]
Mike Braun for Indiana
(FEC ID# C00653147)
2018 Whether the proceeds from the candidate’s personal lines of credit are defined as candidate personal loans; the $250,000 post-election loan-repayment limitation. 52 U.S.C. § 30116(j)

11 C.F.R. 116.11
5/23/2019 6/24/2019 n/a
Kelly for Congress Inc.
(FEC ID# C00573980)
2016 Attributions of contributions from LLCs among members of the LLCs and documentation of eligiblity to make a contribution 11 CFR 110.1(g)(5) n/a n/a OGC email (11/28/2017)
Friends of Mike Lee, Inc.
(FEC ID# C00473827)
2016 Whether committee may retain primary election contributions even though the candidate was nominated by party convention and there was no primary election.

52 U.S.C. § 30101(1)(A) and (B)

11 CFR 100.2;
11 CFR 102.9(e)

AO 2004-20

Kasich for America, Inc.
(FEC ID# C00581876)
2016 Date presidential candidate status ends for purposes of primary election contribution refunding requirements

52 U.S.C. §§ 30101(1)(A)-(D), 30101(2), and 30116(a)

11 CFR 100.3;
11 CFR 110.1;
11 CFR 110.2

David Vitter for U.S. Senate
(FEC ID# C00394593)
2016 Contribution refunding requirements for candidate accepting general election contributions during primary election period but not participating in general election

52 U.S.C. §§ 30116(a)(1)(A) and 30101(1)(A)

11 CFR 102.9(e);
11 CFR 100.2;
11 CFR 110.1(b);
11 CFR 110.1(j)(1)

Cantor for Congress
(FEC ID#C00355461)
2014 The requirement for a candidate, who lost in the primary, to refund general election contributions if the contributions were spent on advance payments to vendors in anticipation that the candidate would participate in the general election 52 U.S.C. §§ 30116(a)(1)(A) and 30101(1)(A)

11 CFR 102.9(e);
11 CFR 100.2;
11 CFR 110.1(b)(1);
11 CFR 110.1(j)(1)
Statement of Commissioner Lee E. Goodman (4/20/2015)
Colorado Republican Committee
(FEC ID# C00033134)
2012 Reporting of debts and obligations; legal expenses 52 U.S.C. § 30104(b)(8)

11 CFR 104.3(d)
Oakland County Democratic Party
(FEC ID# C00040857)
2012 Recordkeeping for small contributions 2 U.S.C. § 432(c)(1)-(2) (now 52 U.S.C. § 30102(c)(1)-(2));

11 CFR 102.9(a)
Kathy Hochul for Congress
(FEC ID# C00494013)

2011 Special

Date of nomination in 2011 NY/26 special election 11 CFR 100.2(c)
Elizabeth Crowley for Congress
(FEC ID# C00517359)


Redesignation of general election contributions accepted by a candidate who did not participate in the general election for a nonfederal campaign

11 CFR 102.9(e);
11 CFR 110.3(b)(3)(i);
11 CFR 110.1(b)(5)
Democratic Party of Illinois
(FEC ID# C00167015)
2010 Monthly time logs kept by state party committees of employee time spent on Federal Election Activity (FEA) 11 CFR 106.7(d)(1)  
Monthly time logs kept by state party committees of employee time spent on Federal Election Activity (FEA) 11 CFR 106.7(d)(1)  
Michael Williams for Congress
(FEC ID# C00457960)

2010 Special

Disposition of funds raised and spent in connection with an anticipated special election that did not ultimately occur 11 CFR 110.1(b)  
(FEC ID# C00386482)
Contract with changing weekly fee as extension of credit;
Reporting of solicitation expenses as independent expenditures

2 U.S.C. § 434(b) and § 434(g) (now 52 U.S.C. § 30104(b) and § 30104(g))

11 CFR 100.55;
11 CFR 104.4;
11 CFR 104.11;
11 CFR 116.3;
11 CFR 116.4



Policy Statements

Submit a Request

All requests, including any extension requests, must be received by the Commission within 15 business days of the determination of corrective action. All requests should be directed to the attention of the Commission Secretary.

Requestors are encouraged to submit comments electronically via email to to ensure timely receipt and consideration. Alternatively, requests may be submitted in paper form to the Federal Election Commission, Attn: Commission Secretary, 1050 First Street, NE, Washington, DC 20463.

To submit requests electronically:

1. Create the request in PDF or Word* document format.

2. Attach the request in an email to

* You can use Microsoft Word to save as PDF format.