On July 13, the FEC announced a settlement with Americans for Common Sense Solutions. The group agreed to pay a penalty of $9,000 for failing to report $121,000 in electioneering commutations attacking Reps. Capps (D – Calif.) and Cicilline (D-R.I.) within 60 days of the November 2010 general election. FEC MUR 6443. The group’s defense: we did not know we had to file electioneering communications reports.
In its simplest form, electioneering communication reports are due once you spend $10,000 or more on broadcast ads that feature a federal candidate, within the jurisdiction that candidates is running, within 30 days of a primary or 60 days of a general election.
Two traps for the unwary.
(1) The rules also cover party conventions! For ads that feature President Obama or Governor Romney, the FEC lists the windows as follows:
|Broadcast Ads Featuring||Convention Disclosure Period||General Election Disclosure Period|
|President Obama||August 4 to September 6||September 7 to November 6|
|Governor Romney||July 28 to August 30||September 7 to November 6|
(2) The primary dates for presidential primaries are frequently different from those for House and Senate candidates. At least 18 states will hold primaries involving congressional candidates in August or later. The dates are here.