FEC open meeting, January 30, 2025

14 min · English (US) · 5 speakers · Recorded January 30, 2025

Source. Federal Election Commission, recorded January 30, 2025. Licence. US federal government recording (17 U.S.C. § 105).

What this is. A machine transcript and summary, made by txscribe on September 26, 2026 with the same recognition and summaries as any upload, and not corrected by anyone since. Speakers are numbered in the order they first speak; which number is which person is not checked. Press play, or click any paragraph, to hear that moment from the publisher's own file. Unlike your own transcripts, this page does not light up each word as it is spoken.

Summary · Meeting

Federal Election Commission Open Meeting - January 30, 2025

The Federal Election Commission convened for its first open meeting of 2025, beginning with welcoming remarks and staff acknowledgments from the Chair. The Commission unanimously agreed to procedural motions regarding agenda timing and Directive 74 before moving to discuss and consider approval of a sample donor response form for LLC contributions.

Discussion

Speaker 1 opened the meeting, acknowledged a plane crash that occurred near the agency the previous night, commended the agency's staff, and noted the agency's upcoming 40th anniversary in April.
Speaker 2 moved to consider the sample donor response form for LLC contributions and the two-year renewal of Directive 74 under 11 CFR section 2.71, as well as to suspend the rule on the submission time of agenda documents to allow consideration of late submission agenda document 25-01-8.
Speaker 1 announced that the first agenda item was held over, proceeding to the second agenda item regarding the sample donor response form for LLC contributions.
Speaker 2 stated that the LLC form emerged from bipartisan discussions involving four commissioners—himself, Commissioner Broussard, Commissioner Lindenbaum, and Commissioner Trainor—to help the regulated community navigate LLC disclosures and contributor identification.
Speaker 1 cautioned filers to examine the form's footnotes, emphasizing that candidate and party committees cannot accept corporate contributions and lack a 'best efforts' defense if an LLC donation is identified as corporate.
Speaker 1 questioned whether the best efforts defense mechanism should be handled through formal rulemaking, a policy statement, or publication in the Federal Register instead of a sample form.
Speaker 2 addressed the matter and formally moved for the Commission to approve agenda document number 25-53-A.

Decisions

The Commission unanimously approved the preliminary motion to consider the sample donor response form for LLC contributions, renew Directive 74 for two years, and suspend document submission rules for agenda document 25-01-8.

Open questions

Whether the best efforts defense related to LLC contributions requires administrative handling via rulemaking, a policy statement, or publication in the Federal Register rather than a sample form alone.

Transcript

Good morning and welcome to the open meeting for the Federal Election Commission of January 30th, 2025. Meeting will now come to order.

It is traditional for the chair to deliver welcoming remarks at the first open meeting of the calendaring year.

So, I'm just going to take the moment to say a few words.

Um, first I want to acknowledge the terrible plane crash that took place last night very close to the agency.

I know we all on behalf of the entire family of the agency and all the persons involved.

And I just wanted to take a moment there.

I've spent most of my career in public life.

It sounds trite to say, but uh it is an honor and a privilege to serve, but it really is

and it is particularly true because when serves alongside a work standing professional staff in the federal workforce, who are the backbone of the government, who do their jobs each day with one goal in mind, providing the best service to the American people.

And I know best of course, are the professional staff here at the agency.

The agency is a very small agency, and we are frankly under resourced.

That means that the staff here work very, very hard.

It's been an inspiration to me to be able to serve with more consistent whole hearted devotion to the important mission of the agency, providing transparency to the American people about money in politics.

I always feel that I do my job better because of you and the good work that you do.

So, I can think of no better way to start off the year than by publicly thanking the great staff of the agency for all that you do for the commission and the American people.

This year the agency will be celebrating a big birthday in April.

The agency turns 40. And I look forward to marking that occasion with my colleagues and our key staff.

And do note maybe delve into the footnotes.

And with that, I will turn to the agenda.

Uh, before we begin, I believe we have uh a few preliminary matters to bring up, Mr. Chairman.

Thank you, Madam Chair.

I move that the Commission consider sample donor form, sample donor response form for contributions by LLC, and two-year renewal of directive 74, and that the Commission determine that 10 to 11 CFR section 2.71 that business so requires no earlier public notice of the up for I further move to suspend the rule on the time of the submission of agenda documents in order that the Commission may consider

the late submission of agenda document number 25-01-8.

Thank you very much.

Any questions or comments from the Vice Chairman or the Commission?

If not, I will call the question.

All in favor say aye.

Aye.

Motion passes unanimously.

Um, the first item on our uh agenda has been held over, so uh we are going to move to the second item on the agenda, sample donor response form for contributions by LLC.

This was a Commission-generated document, so I will turn to my colleagues and see if they would like to speak.

Mr.

Thank you, Madam Chair.

Uh, as the cover memorandum memorandum notes, this was requested by bipartisan discussion among four of us, um, myself, Commissioner Boursard, Lindbaum, and Trainor.

Um, we hope that it'll be a help to the regulated need to the navigate uh tricky issue of disclosure by LLCs and the matter of the uh naming of the contributors in our regulations.

And I'm happy to make a motion to approve the

Mr.

I'll touch on this.

Um, I just want to share a couple of thoughts.

I want to encourage people to read the footnotes.

Um, this is uh excuse me, this is a tricky issue.

And for LLCs and for um, Super PACs, it's a reporting issue.

And there's a best efforts defense to um, uh look allegations of reporting violations.

But for some committees, um, are notably candidate committees and and party committees, they're not allowed to accept corporate contributions.

So, if as a result of filling out the form, they learn that they have corporate contributions, there's a second step there and they need to get rid of those corporate contributions and there is no best efforts defense to pardon me,

contributions.

So, we lawyers love to delve into the footnotes and we know that's where the good stuff is often hiding.

But uh for the uh non-lawyers out there who may be uh uh acting on the form, so that you want to encourage you to uh read the fine print.

I will One question for my colleagues.

This, because it involves a best best efforts defense, this is the sort of thing that might normally be done through a rule making, a policy statement, an interpretive rule, but we intend to publish in the Federal Register the um,

uh benefit of the ability to add very um, funding of the agency to solve the problem.

Madam Chair.

Mr. That's right.

Uh, only one member of the Commission other than the Chair has engaged in any discussion of section law.

Um, the CA form and now is our judgment will not be followed up.

Very well.

Um, Mr. did you did you make the motion or did you indicate an intention to

I moved

I think I got the decent

Thank you, Madam Chair.

And sample donor response form for contributions by LLCs, I move that the Commission approve the agenda document number 25-53-A which is check.

Thank you, Mr.