The proposed regulations state that a coalition is :
The proposed regulations then state:
"A Coalition that expends or incurs more than $5,000 in annual Compensation and Expenses related to Lobbying Activity shall either:
(a) File a Lobbying report with the Commission identifying itself as a Lobbyist and/or a Client, provided the Coalition identifies a Responsible Party and it maintains an up-to-date written instrument with the Commission disclosing all Coalition members who exceed $5,000 in cumulative annual Lobbying compensation and expenses; or
(b) If the Coalition does not file its own Lobbying report, then each member who is required to file a Lobbying report (either through the Coalition activity and/or other Lobbying Activity engaged in by the member) must disclose in such report their own contribution to such Coalition, including the contribution amount and name of the Coalition to which it contributed."
With that definition in play here is the question
How does a coalition spend or receive funds?
Simple question lets see how McAuliffe and the rest of the mensa types answer it.
Here's a hint go to your local bank and try to open an account in the name of a coalition as it is defined above.
Unless JJOKE expects coalitions to use cash or bitcoin they will be unable to spend or receive funds.
And before you say you are just following the old lobby commission opinion allowing this activity I wrote that opinion BEFORE source of funding was required.
All a coalition is, is a fancy way to allow an alias to be used.
If you can spend or receive funds you actually exist and should register and report under your actual corporate or individual existence.
Maybe McAuliffe was on to something with his unincorporated 501c3 nonsense.
Try to contribute a campaign donation in the name of a coalition and see what happens.
I look forward to tomorrows JCOPE meeting and a lively discussion about coalitions.