CLC Comments on Rulemaking Petition to Require “List Swap” Disclosure


Campaign Legal Center (CLC) filed a comment urging the Federal Election Commission (FEC) to prioritize REG 2019-03 (Mailing List Exchange), a rulemaking petition CLC filed in 2019 regarding the need for disclosure of “list swaps” between political committees. As the comment points out, news reports indicate that 2024 presidential candidate Ron DeSantis and his super PAC, Never Back Down, are planning to “swap” mailing lists, part of a growing trend in which super PACs are playing a more active role in directly supporting candidates. CLC urges the FEC to implement a rule requiring list swaps of purportedly equal value be disclosed to avoid undermining transparency and voters’ right to know who is spending money on elections.