<x-charset UTF-8>Allison is right, as always.
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-----Original Message-----
From: owner-election-law_gl@majordomo.lls.edu <owner-election-law_gl@majordomo.lls.edu>
To: BSvoboda@perkinscoie.com <BSvoboda@perkinscoie.com>; Holman@aol.com <Holman@aol.com>; david.billings@gmail.com <david.billings@gmail.com>; election-law@majordomo.lls.edu <election-law@majordomo.lls.edu>
Sent: Fri Jun 09 17:22:22 2006
Subject: Re: bundling question

Ack!  Preempted by Brian!  Sorry.

But - while we're on the topic, let me check my understanding of something.  Which is - when does an intermediary have an obligation to file a conduit report?  Craig's test seems to revolve around "touching the check."  I have no idea what the authority is for that.  My understanding is the demarcation between when someone is an intermediary (and thus required to file conduit reports) and not depended upon whether they were authorized by the campaign to solicit funds.  So, easy case, if you are a campaign staffer or consultant/fundraiser by profession, you aren't a "conduit."  If you are a volunteer fundraiser, you aren't a conduit.  If you are a "Majordomo" or a "pioneer" or whatever - that title and official designation takes you out of the role of "conduit" and makes you part of the campaign.  Touch or no touch.

But, if you just decide to solicit money from colleagues and friends on your own, and "bundle" the checks, you need to report yourself as the intermediary both to the campaign and to the FEC.

Right?  Wrong?  Nuts?  You tell me.

Allison Hayward

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