CLC Comments on Advisory Opinion Request Regarding Coordinated Canvassing


On September 22, 2023, Campaign Legal Center (CLC) filed a comment with the Federal Election Commission (FEC) on Advisory Opinion Request 2023-06 (Texas Majority PAC). Texas Majority PAC (TMP), a nonfederal committee, requested an opinion stating that its proposed “paid canvassing” activity on behalf of federal candidates, which TMP would consult with the candidates about, would not result in TMP making in-kind contributions to the candidates because the activity at issue would not satisfy the FEC’s “coordinated communications” standard at 11 C.F.R. § 109.21. CLC’s comment noted that to be allowed, TMP’s “paid canvassing” would have to fall outside of not only the “coordinated communication” standard at Section 109.21, but also the broader “coordinated expenditure” standard at 11 C.F.R. § 109.20, and that the activity described in TMP’s request appeared to at least meet the standard at Section 109.20 because TMP represented that it would cooperate or consult—i.e., “coordinate”—with federal candidates.