WMP Submits Comments to Federal Election Commission about Enhanced Reporting of Campaign Spending

The FEC is considering a new rule on how campaign committees report spending by contractors and consultants. WMP co-director Michael Franz submitted comments in support of the new regulation, arguing that existing rules make it hard to track ad spending on digital platforms. His full set of comments are linked here. The summary of the report is below:

“This analysis compares FEC expenditures by U.S. House candidates in the 2019-2020 cycle with Facebook Ad Library totals for candidates between January 2019 and Election Day 2020. We use the “Name” and “Purpose” fields in the FEC data to tag expenditures explicitly identified as Facebook-related. We total these explicitly labeled Facebook expenditures and compare them with the Ad Library totals. The results suggest that the FEC data systematically undercount Facebook ad spending, making it challenging to use the FEC databases to estimate spending on specific digital ad platforms. We support amending existing regulations to require committee filers to report how an agent or independent contractor spends money on their behalf. Our analysis suggests that the undercount of the Ad Library totals primarily comes from FEC expenditures to consultants that label expenditures without reference to specific sub-vendors (i.e., as “media buys” versus Facebook ads). More generally, a requirement for more detailed itemization of expenditures or disbursements made by an agent or independent contractor will facilitate more accurate assessments of how money in federal elections is spent.”

Other comments on the Rule are available at the Federal Election Commission’s Electronic Rulemaking Resource, by clicking on 2021 and looking for “REG 2021-02 Subvendor Reporting”.