During the 2016 election cycle, the National Rife Assocation’s (NRA) political and lobbying arms spent over $25 million supporting Trump, mostly for television advertising, and distributed and placed those advertisements using the same network of consulting firms that placed the Trump campaign’s own advertisements.
In fact, in the final stretch of the 2016 election, the same four strategists at the media consulting firm National Media repeatedly placed ads on behalf of both the NRA and Trump campaign, in some cases on the same stations or programs, to advance a unified strategy.
On December 7, 2018 Campaign Legal Center (CLC) and Giffords Law Center filed a complaint with Federal Election Commission alleging illegal coordination between the Trump campaign and the NRA.
The FEC regulates the use of common vendors for media placement because the targeting of political ads is a critical element of a campaign effort. If the NRA knew about the Trump campaign’s strategy, it could time and target its pro-Trump ads to complement and reinforce the campaign’s own efforts.
If the NRA’s ads are coordinated, then the law treats the spending on those ads as an in-kind contribution to the candidate. The $25 million spent supporting Trump far exceeds the $2,700 contribution limits.
In October CLC first unearthed the NRA’s use of shell companies to coordinate media buys, and we filed a complaint against the NRA and then-U.S. Senate candidate Josh Hawley.
The Trace / Mother Jones identified that those same shell companies helped the NRA back Trump in 2016. The complaint cites dozens of Federal Communications Commission (FCC) records documenting the coordinated effort.
The NRA can legally make unlimited expenditures to support the Trump campaign only if the organizations are completely independent. But if the same people buying ads for the Trump campaign also placed the NRA’s pro-Trump ads, then the NRA’s spending was not at all independent.
CLC requests that the FEC seek appropriate sanctions for all violations to deter future violations. The FEC should also seek out additional remedies as appropriate to ensure compliance with campaign finance laws moving forward.