As discussed in our November 29, 2018 mailing, the Federal Election Commission (FEC) rolled out changes to its Electronic Filing Password Assignment System, requiring PACs and other committees’ passwords to have two-factor authentication. The FEC has further updated the system to send new password approval emails only to those listed on the Statement of Organization (Form 1).
Committees that have not already updated their electronic filing password with the FEC should confirm the email on the most recent Form 1 is correct prior to requesting a new password. For committees that are filing on a semi-annual cycle in 2019, the July 31 report may be the first report that requires the new password.
Committees are encouraged to test their electronic filing passwords prior to the due date as failure to have a valid password could prevent a committee from filing timely reports with the FEC. The agency has stated that they anticipate that it may take up to two business days to process password requests.
This memorandum is provided by Skadden, Arps, Slate, Meagher & Flom LLP and its affiliates for educational and informational purposes only and is not intended and should not be construed as legal advice. This memorandum is considered advertising under applicable state laws.