Tim,
Thank you -- this is very useful information. I didn't know such a document existed that covered regulations applicable to all levels of the LP (national, state, local) in one place. I suppose that is good, if it means nobody has to read the "508 pages of fine print in the Code of Federal Regulations Title 11 - Federal Elections" that you mention exist separately.
And yet my guess is no more than a few LNC members, if that many (probably the number is closer to zero), have read through the 177 doubtlessly dry and boring pages of legalese and bureaucratese of the Federal Election Commission's Campaign Guide for Political Party Committees and have a solid grasp of its regulations. (As a sample, here are the contents of page 100, which I picked more or less randomly as a large round number sort of near the middle of the document):
Line 5. Coverage Dates
The period covered by the report begins the day after the close of books of the last report filed by the committee. If the report is the first one filed by a committee, then the reporting period begins with the date of the committee’s first activity.
Line 6. Cash on Hand
What Is Cash on Hand
Cash on hand includes funds held in checking and savings accounts, certificates of deposit, petty cash funds, traveler’s checks, treasury bills and other investments valued at cost. 104.3(a)(1).
Line 6(a) Cash on hand January 1
On this line, enter cash on hand as of January 1st of the reporting year.
Line 6(b) Cash on hand at Beginning of reporting Period
The amount entered on this line should be the same as your cash on hand at the close of books of your last report.First report
Beginning cash on hand—i.e., money that the committee had in its possession at the time of reg- istration—is subject to the contribution limits, pro- hibitions and disclosure requirements of federal law. (The committee must exclude any contributions that are not permissible under federal law and re- move such contributions from its federal account.) The committee may have to itemize contributions and other receipts included in the beginning cash- on-hand balance. See “When to Itemize Receipts” on page 80. 104.12.Treasurer’s name and Signature
The treasurer must sign and date Form 3X at the bottom of the page 1. Only a treasurer or assistant treasurer designated on Form 1 (Statement of Organization) may sign the report (see page 6. 104.14(a). See Chapter 1 for more information on a treasurer’s responsibilities. See also “Electronic Filing” on page 75.
15. FILING AMENDMENTS
15. FILInG AmEnDmEntS
The committee must file an amended report if it:
• Discovers that an earlier report contained erroneous information; or
• Does not obtain required reporting information concerning a particular transaction until after the transaction has been reported.3 104.7(b)(4).Paper Filers
When filing an amendment to an original report, complete the Summary Page (including the treasurer’s signature), indicating on Line 3 that the document is an amended report. In addition to the Summary Page, submit a corrected version of the schedule that contained the incomplete or incorrect itemized information in the earlier report, along with a revised Detailed Summary Page, if appropriate.Transactions originally reported correctly do not have to be itemized again.The Commission recommends that the treasurer attach a cover let- ter explaining the changes.Electronic Filers
Electronic filers must resubmit the entire report as amended.3 With respect to contributor information received after a report has been filed, paper filers may, as an alternative, submit the information on a memo Schedule A attached to the next paper report filed after the necessary information has been received. See “File Amendments if Necessary” on page 70.
To get a sense of this document from a slightly different perspective, check out the table of contents. How many state chairs or state treasurers have read this monstrosity and understand what it requires, let alone county LP leaders? My guess is very few. Should we all be expected to know what's in this steaming pile of donkey and elephant droppings?* What is reasonable to expect of ourselves? To repeat Geoff's question, "Is it unreasonable to expect the board of a political party to understand the regulations we are required by law to operate under?" If national, state, and local LP officials were to vote between (a) requiring themselves to be familiar with the CGPPC or (b) having the LP officially say "To hell with this!", how do you think they would vote?
Maybe no one will ever seek such a vote. But perhaps we as a party should anticipate at some point possibly having to determine that trying to understand and comply with these regulations is not reasonable? That it just takes too many resources away from the fight for liberty, and is no longer justifiable in cost-benefit-analysis terms? I'm not saying that point has been reached, but we should be aware that such a point surely exists, and mindful that it not slip by unnoticed because we are too set in our ways.
Frederick Douglass wisely observed that "The limits of tyrants are prescribed by the endurance of those whom they oppress." This suggests that we as a political party may eventually be regulated to whatever maximum extent we are willing to put up with, and that it therefore makes sense as a long term strategic matter to assume that if government growth continues, we may at some point want to reevaluate our whole approach to regulatory compliance.
In the meantime, so long as we are trying to be familiar with and comply with this crap, I think linking the Campaign Guide for Political Party Committees on our website would be a good idea. Preferably along with commentary summarizing the document and describing its main impacts on us, and encouraging readers to call or write FEC officials and lobby them to reduce the agency's regulatory burden.
I notice the document lists some of those FEC officials on the first page of the 7-page introduction that appears before the start of the document's main numbered section begins:
Federal Election Commission
Washington, DC 20463Commissioners: Ellen L.Weintraub, Chair
Donald F. McGahn II,Vice Chairman
Caroline C. Hunter
Matthew S. Petersen
Steven T.WaltherStaff Director:
Alec PalmerPrepared by the
Information Division of the Office of Communications
Greg J. Scott, Director
Zainab S. Smith, Editor
Unfortunately they don't list their phone numbers or email addresses. Perhaps they feel that they aren't Congress, but just some small committee, so people don't need to be able to contact them directly. This probably contributes to a situation where they rarely hear from people affected by their decisions and regulations, and operate in a kind of bubble where they primarily talk to and hear the perspectives of fellow regulators and other insiders. Hence the 177 pages of excrement.
Love & Liberty,
((( starchild )))
At-Large Representative, Libertarian National Committee
*A pile this big probably still has some steam coming off it from its last "update" in August 2013. I told Lee I was going to use his "elephant droppings" phrase.
P.S. - I'm copying a couple state chairs on this message so that one of them can forward it to the state chairs' list.