FEC: Comments Filed by CLC & Democracy 21 on Notice 2013-01: Request for Comment on Enforcement Process
Comments submitted jointly by the Campaign Legal Center and Democracy 21 in response to the Commission’s Notice 2013-01, requesting comment on the Commission’s enforcement process, published at 78 Fed. Reg. 4081 (January 18, 2013). The Campaign Legal Center and Democracy 21 urge the Commission to continue its practices of basing RTB findings on, and taking into account, all publicly available information and valid legal theories in all enforcement matters, regardless of whether the matter was complaint-generated or internally-generated. We further urge the Commission to more fully and efficiently exercise its broad enforcement authority—and to recognize that doing so is the Commission’s principal responsibility.