[EL] question on Super PAC staff

[Smith, Brad]

11 CFR 109.21. 120 days.

Or perhaps zero. The regulation applies when "The communication is paid for by a person, or by the employer of a person, who was an employee or independent contractor of the candidate." Doesn't on its face prohibit a person from moving from a Super PAC to the campaign.

By the way, this really is not new. The regulations have long been written to prohibit the candidate from providing information or making a request of the spender, but not necessarily to prevent the spender from providing info to the candidate.

But it does get dicier. If the staffer goes from the Super PAC to the campaign with knowledge of the Super PAC and taking valuable information (say recent polling data) some might consider that a contribution.


Bradley A. Smith

Josiah H. Blackmore II/Shirley M. Nault

   Professor of Law

Capital University Law School

303 E. Broad St.

Columbus, OH 43215

614.236.6317

http://law.capital.edu/faculty/bios/bsmith.aspx

________________________________
From: law-election-bounces at department-lists.uci.edu [law-election-bounces at department-lists.uci.edu] on behalf of Sean Parnell [sean at impactpolicymanagement.com]
Sent: Monday, February 29, 2016 5:42 PM
To: law-election at department-lists.uci.edu
Subject: [EL] question on Super PAC staff

Had a question come up recently about what the regs are on how long a super-PAC staffer must wait after leaving the super-PAC before doing work for a campaign – I thought I read somewhere it was 60 days, but I’m not sure I ever saw a cite for that. Anybody know where I might find this info?

Sean Parnell
President, Impact Policy Management LLC
Alexandria, Virginia
571-289-1374
sean at impactpolicymanagement.com

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