All money candidates spend on campaign activities must be raised under the contribution limits set by the Federal Election Campaign Act — currently $2,800 per person per election. Candidates may attempt to circumvent the law by outsourcing some campaign activities to super PACs and dark money groups, which can accept unlimited contributions from individuals, labor unions, and corporations.
The Act Now on Climate super PAC ran hundreds of thousands of dollars’ worth of ads on social media in 2019 that urged people to support the presidential campaign of Gov. Jay Inslee (D-WA) — and linked directly to Inslee’s campaign website, where they could donate directly to his campaign. As the New York Times wrote, this tactic served as “an almost sleight-of-hand way to convert big money checks into the small donors needed to qualify for the debates.” Just seven wealthy residents of Washington primarily bankrolled the Act Now on Climate super PAC’s efforts.
Correct the Record — a super PAC founded by Hillary Clinton ally David Brock, the founder of the media watchdog group Media Matters for America — helped Clinton’s 2016 presidential campaign with its online rapid-response operation.
Correct the Record argued it could “coordinate directly and strategically” with Clinton’s campaign because the materials it produced were published strictly online and were not paid ads.
Ahead of the 2016 election, when voters walked into events for Republican presidential candidate Carly Fiorina, they were frequently greeted by employees of a super PAC supporting her called Conservative, Authentic, Responsive Leadership for You and for America (i.e., CARLY for America) — not by her campaign staff.
The CARLY for America super PAC was able to take over much of the advance work for Fiorina’s campaign because she shared all the necessary information about her campaign events on a public Google calendar.
Ahead of the 2016 Iowa caucuses, the Believe Again super PAC sponsored a series of more than 50 town halls in Iowa and invited GOP presidential candidate Bobby Jindal to appear there, saving his campaign the costs of running these events.
Multiple complaints have been filed with the FEC against groups that appear to be conducting integral campaign activities — including Correct the Record — but the agency has deadlocked on them all (e.g., here, here, here, here, and here).
The bipartisan Political Accountability and Transparency Act would explicitly define these types of outsourcing as illegal coordination. Read more here.
Here are 5 other ways to spot coordination:
