FEC Releases Documents on Compliance and Enforcement Procedures, Changes Policy on Email Addresses

The Federal Election Commission (FEC) recently released several documents related to compliance and enforcement and announced that political committees may now provide more than one email address for correspondence from the FEC.

In late May, the FEC released several documents related to its internal compliance and enforcement procedures.  These documents were not previously publicly available.  The documents include:

• The FEC's 1997 enforcement manual and related enforcement materials;
• Reports Analysis Division Procedures; and
• Audit Division Materials.

Certain portions of the documents, such as the monetary thresholds that will trigger correspondence from the FEC's Reports Analysis Division, have been redacted.  However, some documents shed light on elements of the FEC's enforcement procedures that were previously confidential.  For example, the Reports Analysis Division Procedures document outlines the process that the FEC uses to initiate an audit of a committee.

The documents were released in response to requests made in a November 2011 oversight hearing before the Subcommittee on Elections of the House of Representatives Committee.

Separately, in response to requests from the regulated community, the FEC updated its Form 1, Statement of Organization, to allow filers to include two email addresses so that committees can receive email communications at two different points of contact.  The FEC sends several notices via email, including reporting reminders and Requests for Additional Information, and there was a sense that having two individuals receive the notifications would help ensure that no electronic communications were missed.

Both the FEC's paper and electronic Form 1 have been updated to include a second line for committees to include a second email address.  To account for this change with the Form 1, the FEC's electronic filing software, FECfile, has been updated.  Any committee currently using FECfile should go to the FEC's website and update its software.  The updated version of FECfile is available here.

If a committee uses a private software vendor and the vendor has not yet updated its software, the committee should enter both email addresses in the only box, separated by a comma or semi-colon.

Committees that would like to receive emails to two email addresses should amend their Statements of Organization.