Michigan Bureau of Elections: Comments Filed by CLC regarding Michigan Bar Declaratory Ruling Request


The Campaign Legal Center submits comments to explain that multiple recent Supreme Court decisions clearly permit the application of MCFA disclosure requirements to all “expenditures” as defined in the MCFA, including payments for advertisements that the Department of State has previously characterized as “issue ads” due to the absence of “express advocacy” in the advertisement and, on that basis, incorrectly exempted from “expenditure” disclosure requirements.