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New Federal Coordination Regulations

April 09, 2006

On Friday, April 7, 2006, the Federal Election Commission ("FEC") adopted new final regulations on what communications will be considered impermissibly "coordinated" between federal candidates and organizations engaged in independent political activities. In sum, the new rules are less restrictive and will benefit the sponsors of public communications involving federal candidates. Moreover, by reducing the scope of regulated activities, the revised federal regulations are likely to improve an organization’s ability to comment on public issues and effectively lobby Congress.

Most significantly, the new federal regulations:

  • reduce the time period from 120 to 90 days during which a public communication that identifies a House or Senate candidate will satisfy the federal "content" standard in determining whether a communication has been impermissibly coordinated (the time period for presidential candidates remains 120 days);
  • clarify that the common vendor and former employee restrictions apply only to those individuals and organizations that have worked with a candidate or political party committee during the previous 120 days, not an entire election-cycle; and,
  • create three "safe harbors" involving certain practices:
  • firewalls or other screening policies – the FEC sanctions the concept of a "firewall" within an organization to protect against the inappropriate sharing of information and coordination with candidates while allowing the organization to engage in independent political activities;
  • endorsements and solicitations by federal candidates – the FEC recognizes an exception for positive public communications that involve a federal candidate endorsing another candidate or soliciting funds for another candidate or organization; and,
  • publicly available information – the FEC recognizes an exception for public communications that use "publicly available information" such as information obtained from a candidate’s website, press releases or the media.

Given the reduced regulatory scope of these new rules on coordination and the history of this particular rulemaking, a legal challenge by the "reform" community would be expected. We will, of course, continue to monitor these proceedings and let you know of any significant developments. In the meantime, please let us know if you have questions or need any additional information on the updated federal coordination standard.

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