[EL] Federal SSF question

[David Mason]

In the corporate context all lawyers are part of the restricted class.  The
likely reason you are unable to find AOs on the law firm context is that
most states still prohibit law firms from incorporating (as traditional
corporations, anyway) and partnerships are not permitted to sponsor SSFs.
Most law firm PACs are, consequently, technically non-connected.  There are
several AOs on how law firms in this situation must be reimbursed by the
PAC for administrative expenses, such as the cost of payroll deduction
programs.

One result of law firms operating non-connected PACs is that as a legal
matter, anyone may be solicited, including. for instance, non-attorneys in
clerical positions.  In practice I don't think this occurs much, but there
is no legal barrier.

The FEC has just published a notice of proposed rulemaking considering
treating certain typrs of LLPs as corporations for election law purposes:
http://www.fec.gov/agenda/2012/mtgdoc_1280.pdf

Dave Mason

On Thu, Dec 27, 2012 at 6:10 PM, Adam Bonin <adam at boninlaw.com> wrote:

> Does the inclusion of “individuals following the recognized professions,
> such as lawyers and engineers” as executive/administrative personnel (11
> CFR 114.1(c)(1)(ii))mean that when a law firm is itself operating a SSF,
> all of its attorneys are considered executive/admin personnel and subject
> to full, year-round solicitations regardless of whether they may be lowly
> associates with no “policymaking, managerial, professional, or
> supervisory responsibilities”?  Or does the “recognized professions”
> definition only cover such professionals when they are in-house at other
> types of corporations?  I can’t find any AOs on point.****
>
> ** **
>
> Adam C. Bonin
> The Law Office of Adam C. Bonin
> 1900 Market Street, 4th Floor
> Philadelphia, PA 19103
> (215) 864-8002 (w)
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> (267) 242-5014 (c)****
>
> adam at boninlaw.com****
>
> http://www.boninlaw.com****
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