<x-charset utf-8>Didn't the 527 rulemaking process ("Political Committee Status" on the FEC web site) lead to the adoption of at least some new rules?  Specifically, new allocation rules and a new definition of "contribution" at 11 CFR 100.57.  

I realize, of course, that we may differ in our evaluation of the significance of those rules, but they are, as I recall, what came out of that process.  

Beth

Elizabeth Kingsley
Harmon, Curran, Spielberg & Eisenberg, LLP
1726 M St., NW
Suite 600
Washington, DC 20036
202-328-3500

-----Original Message-----
From: owner-election-law_gl@majordomo.lls.edu
[mailto:owner-election-law_gl@majordomo.lls.edu]On Behalf Of Trevor
Potter
Sent: Thursday, March 30, 2006 1:28 PM
To: Rick Hasen; election-law
Subject: RE: correcton



In fact, the FEC voted in 2004 to terminate the 527 
rulemaking, having failed to reach consensus on any of the 
regulatory proposals. Thus, it would have to put out a new 
Notice if it goes that route.
trevor Potter

	-----Original Message----- 
	From: owner-election-law_gl@majordomo.lls.edu on behalf 
of Rick Hasen 
	Sent: Thu 3/30/2006 12:10 PM 
	To: election-law 
	Cc: 
	Subject: correcton
	
	
	Regarding my post:
	
	

	"Judge Grants Partial Motion for Summary Judgment in 
Shays II Case"...

	  
	UPDATE: A few readers (who have much greater knowledge 
of the day-to-day business of the FEC than I do) wrote to ask 
about my statement above that I believe the FEC is working on 
527 rules. My memory on this point was faulty. Here 
<http://www.fec.gov/law/law_rulemakings.shtml>  is the FEC 
rulemaking page, and there is not any rulemaking listed there 
for when 527s should be considered as political committees. I 
had seemed to recall that when the FEC failed to enact rules 
for 527s in the summer of 2004, it put this on the agenda to 
consider after the 2004 elections. But that appears to be wrong.
	
	-- 
	Rick Hasen 
	William H. Hannon Distinguished Professor of Law
	Loyola Law School 
	919 Albany Street 
	Los Angeles, CA  90015-1211 
	(213)736-1466 - voice 
	(213)380-3769 - fax 
	rick.hasen@lls.edu 
	http://www.lls.edu/academics/faculty/hasen.html 
	http://electionlawblog.org


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