The Federal Election Commission (“FEC”) released two draft advisory opinions providing guidance concerning the operations of independent expenditure PACs (“IE PACs”) established pursuant to the SpeechNow.org and Citizens Unitedfederal court decisions. Comments on the draft AOs are due no later than 5:00 pm on July 21, 2010.
Draft AO 2010-11, provides that an IE PAC may solicit and accept funds from corporations and labor unions in unlimited amounts so long as the IE PAC does not coordinate its activities and communications with a federal candidate or political party committee and does not make any contributions to other political committees.
Draft AO 2010-09, provides that an incorporated 501(c)(4) membership organization may establish an IE PAC so long as specific conditions are satisfied.
UPDATE: Commissioner Walther has offered an alternative draft opinion for AOR 2010-09.