FEC: Comments Filed by CLC & Democracy 21 on Advisory Opinion Request 2012-19 (America Future Fund)

Comments filed on behalf of the Campaign Legal Center and Democracy 21 with regard to Advisory Opinion Request (AOR) 2012-19, a request submitted on behalf of America Future Fund (AFF), which asks the Commission whether “any of eight proposed television advertisements include one or more references to a clearly identified candidate for Federal election, as that phrase is used in the definition of ‘electioneering communication.’” AOR 2012-19 at 1. AFF does not want to “subject itself to the burden of filing electioneering communications reports for these advertisements” and does not want to disclose its donors whose funds pay to produce and air the ads.