CLC Urges FEC to Deny Request to Establish Leadership PAC “Non-Contribution” Accounts


On July 5, 2023, Campaign Legal Center (CLC) submitted a comment urging the Federal Election Commission (FEC) to deny Advisory Opinion Request 2023-05 (Alamo PAC), in which a leadership PAC sought to establish a separate “non-contribution” account with its own contribution limit, which it purports would be used solely to finance independence expenditures. CLC’s comment argues that this request is not supported by either judicial or FEC precedent and would, moreover, establish a mechanism for leadership PACs to circumvent federal contribution limits, thus undermining crucial anticorruption interests. CLC’s comment also noted that approving the request would be bad policy in light of the well-documented history of candidates and officeholders misusing leadership PACs as slush funds for personal enrichment.