FEC: Comments Filed by CLC & Democracy 21 on Advisory Opinion Request 2010-20 (NDPAC)

These comments are filed on behalf of the Campaign Legal Center and Democracy 21 in regard to AOR 2010-20, an advisory opinion request submitted on behalf of National Defense PAC (NDPAC), a federal non-connected multicandidate political committee1 that seeks the Commission’s opinion as to whether it may lawfully: a. “accept[] unlimited contributions . . . for the express purpose of making independent expenditures (IEs), including paying any or all of its own administrative & operating expenses,” and b. “accept[] contributions . . . subject to the limits at 2 USC §§441a(a)(l)(C) and (2)(C), to expend as campaign contributions to candidates, pursuant to 2 USC §441a(a)(2)[.]”