Wading through SEC’s new pay to play rules?

The Federal Election Commission has a new “tip for treasurers” on the SEC’s new rules.  The tip?  Don’t call the FEC, call the SEC.

Covington’s got an overview of the new rules here.

The rules are available here.  Not sure they made the Federal Register, yet.

Footnote 154 speaks to inaugural and transition expenses.  The footnote also explains

that “contributions” are not intended to include independent “expenditures,” as that term is defined in 2 U.S.C. 431 & 441b (the federal statutory provisions limiting contributions and expenditures by national banks, corporations, or labor organizations invalidated by Citizens United v. Federal Election Commission, 130 S. Ct. 876 (2010) (holding that corporate funding of independent political broadcasts in candidate elections cannot be limited under the First Amendment)). Indeed, it is our intent that, under the rule, advisers and their covered associates “are not in any way restricted from engaging in the vast majority of political activities, including making direct expenditures for the expression of their views, giving speeches, soliciting votes, writing books, or appearing at fundraising events.” Blount, 61 F.3d at 948.

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