February 3, 2015

FEC Increases Contribution Limits for 2015-2016 Election Cycle

Holland & Knight Political Law Blog
Andrew H. Emerson

Today, the Federal Election Commission announced that pursuant to the Federal Election Campaign Act (FECA), as amended, it was adjusting contribution and expenditure thresholds and the lobbyist bundling threshold for federal elections. This biannual process, which occurs in odd-numbered years, is intended to ensure that the contribution limits originally adopted in the Act rise with inflation. 

The contribution limits applicable to political action committees (PACs), including both corporate separate segregated funds and non-connected committees, are not adjusted for inflation and remain at $5,000 per candidate per election and $5,000 to committees per year. 

Candidate Contributions

The Commission determined that the individual candidate contribution limit should be increased from $2,600 per candidate election, to $2,700.1 This new limit is retroactively effective as of November 5, 2014 through November 8, 2016.

Contributions to National Party Committees

The Commission determined that the limit on individual contributions to the six national party committees should be increased from $32,400 per year to $33,400 per year. This new limit is retroactively effective as of January 1, 2015 through December 31, 2016.

This increase in the limit to national party committees also results in increased limits for the newly established party accounts for presidential nominating conventions, building funds, and legal/recount expenses, which this blog discussed extensively in December. Those independent accounts may now accept up to $100,200 per year, up from $97,200 when they were created late last year.

National Party Contributions to Senate Candidates

The Commission determined that the special limit on national party committees, which formerly allowed the party committees to give up to $45,400 to candidates for U.S. Senate, notwithstanding the lower candidate limits, should be increased to $46,800 per candidate per campaign. This new limit is retroactively effective as of January 1, 2015 through December 31, 2016.

Coordinated Expenditure Limits

FECA also requires the FEC to adjust the overall limit on how much money national and state party committees can spend in coordination with candidates for U.S. House and Senate during general elections. The FEC has determined that the maximum amount to be spent on House races in states with multiple House districts will be $48,000 for this election cycle. This amount is derived by multiplying the statutory limit of $10,000 by the difference in the average consumer price index published by the Bureau of Labor and Statistics over the preceding year compared with that index in 1974 (the "FECA Base Year"), which was 4.8 this year. 

The formula used to determine the coordinated expenditure limits for Senate races, or states with a single House district (currently Alaska, Delaware, Montana, North Dakota, South Dakota, Vermont and Wyoming), is somewhat more complicated because it considers both the Price Index and the Voting Age Population (VAP) of the state.  As a result, for the 2015-2016 election cycles, the Coordinate Expenditure Limit for Senate and single-district states range from $96,000 in seven states (the floor set by the formula) to over $2.8 million in California. 

Lobbyist Bundling Disclosure Threshold

The Honest Leadership and Open Government Act of 2007 (HLOGA) requires authorized committees of federal candidates, leadership PACs and political party committees to disclose the receipt of "bundled contributions" received from registered lobbyists and lobbyist-controlled PACs that are in excess of an annually adjusted limit. 

This amount is derived by multiplying the statutory limit of $15,000 by the Price Index in the preceding year and in 2006 (the "HLOGA Base Year"), which was 1.17 this year. The resulting lobbyist bundling disclosure threshold for calendar year 2015 is $17,600.

1 See 80 Fed. Reg. 5752

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