Hartford, Ct. –  On today’s FEC monthly filing deadline, Connecticut Democrats are raising questions about the Connecticut GOP’s recent decision to switch their filing status from monthly to semi-yearly to avoid disclosure. This explicitly prohibits them from engaging in “federal election activity”.

“Something doesn’t add up,” said Connecticut Democratic Party Executive Director Michael Mandell. “This is typical of Connecticut Republicans. They’re clearly recruiting candidates, raising money, and preparing to support Marco Rubio and his failed policies in the 2016 primary. Yet they’re trying to say that they aren’t engaging in federal election activity… hmm. What are they hiding that they can’t put in a monthly report?”

State parties are responsible for recruiting candidates to run in federal elections, as well as promoting federal candidates. It is hard to believe that the state party has not spent time on candidate recruitment, particularly because Jerry Labriola openly said that they were actively recruiting candidates to challenge Senator Richard Blumenthal. With the GOP presidential primary underway – and with their recent endorsement of Marco Rubio – state GOP staff is most certainly spending time trying to find a role in the 2016 presidential election.

Point in fact – the very act of fundraising for a federal account could be considered federal election activity. And as they highlight the Chairman’s endorsed candidate for President, Marco Rubio, at the Prescott Bush dinner – they are most certainly working to build that annual federal fundraising dinner.

Finally, the Democratic Party has always followed the letter of the law on disclosure, and files state reports every quarter (and more often during municipal elections) and federal reports every month. Yet there has been no Republican FEC report since filing their 2014 year end report on January 29. We know only that Linda and Vince McMahon are bankrolling the Republican party’s state account, but that doesn’t add up to the money being spent on running the party and their relentless misleading attacks on Governor Dan Malloy.

“We just want to know where the money is at the CT GOP. By avoiding reporting on their donations and expenditures, they are circumventing what has always been a hallmark of our state parties – and that is the campaign finance disclosures – and we are wondering why,” added Mandell.

Background

• Federal election activity is generally considered to take place only within a 120 day window of a federal election. However, there are two important exceptions to the 120 day window: (1) Employees who spend 25% or more of their time on activities in connection with a federal election; and (2) public communications which “promote, support, oppose or attack” (“PSAO”) a federal candidate. These activities are considered federal election activity regardless of timing.

  The following is found in section (b)(4) of the code for Federal Election Activity:

Services provided during any month by an employee of a State, district, or local committee of a political party who spends more than 25 percent of that individual’s compensated time during that month on activities in connection with a Federal election.

The federal code can be found here: http://www.gpo.gov/fdsys/pkg/CFR-2011-title11-vol1/xml/CFR-2011-title11-vol1-sec100-24.xml

• Regarding public communications: press releases, paid social media, and blast emails promoting, supporting, attacking or opposing federal candidates could all constitute federal election activities.
  • They have engaged in communications activity promoting candidates, including their press release when Rand Paul announced his presidential candidacy (http://www.ctgop.org/2015/04/chairman-labriola-reacts-to-sen-rand-paul-announcement/) and their promotion of Marco Rubio’s visit to the Prescott Bush Dinner (http://www.ctgop.org/2015/04/senator-marco-rubio-to-headline-2015-prescott-bush-awards-dinner/)
  • Even if none of these things technically fell under the definition of “public communications,” these things take time and effort. It is clear that they are spending significant staff time researching and preparing for communications related to federal candidate. Many of their staff members went to New  Hampshire last month for a summit on electing a Republican president.
• Obviously, the CT GOP has hired staff. But it is clear from SEEC filings that they aren’t paying employees from their state account. Unless they are paid in tri-monthly increments, their paychecks are coming from the federal account, meaning they must be raising significant money for their federal account.