AO 2025-05: Commercial vendor may offer contribution processing services and candidate meeting information to users and subscribers

Politicalmeetings.com (PM.com) may allow its subscribers to make small monthly contributionsto candidates and national political party committeesvia its web-based platform and provide subscribers access to non-public information about political meetings and events with candidates. The Commission concluded that PM.com's proposed activities would not result in the making of contributions from PM.com or from its sole member to candidates or national political party committees.

Background

A single member LLC, PM.com has developed an online platform that allows paying subscribers to make small monthly contributions to candidates and political party committees and provides non-public information about political meetings and events with candidates and committees.

Candidates, political party committees, and other political committeesmay also participate in PM.com's platform, either without charge or through two tiers of paid profiles that include additional services.

PM.com will use a pay gateway company to process contributions and administrative fees paid by the subscriber.

Analysis

In previous advisory opinions (cited within the opinion), the Commission has determined that the provision of contribution-processing services to a political committee by a commercial vendor does not constitute a contribution to the political committee if:

1. The vendor renders services in the ordinary course of business and at the usual and normal charge;
2. The vendor forwards contributions through a segregated account to candidates and political committees, and;
3. The vendor employs adequate screening procedures to ensure that they are not forwarding illegal contributions.

The Commission concluded that PM.com's proposed business model meets all three criteria.

Accordingly, PM.com's proposal to allow its subscribers to make small, monthly contributions to candidates and national political party committees and to provide them with non-public information about political meetings and events with candidates and committees is permissible under the Federal Election Campaign Act and Commission regulations.

Date issued: April 30, 2025; Length: 8 pages

Citations

Regulations

11 CFR §100.52
Gift, subscription, loan, advance or deposit of money.

Advisory opinions

AO 2021-07
PACMS

AO 2019-04
Prytany LLC

AO 2018-05
CaringCent, LLC

AO 2017-06
Stein and Gottlieb

AO 2016-08
eBundler.com

AO 2015-15
WeSupportThat.com

AO 2014-07
Crowdpac

AO 2012-22
skimmerhat

AO 2011-19
GivingSphere

AO 2011-06
Democracy Engine

AO 2007-04
Atlatl

Resources