Should the Tea Party Leadership Fund be granted an exemption from campaign finance reporting?

On September 16th, the Tea Party Leadership Fund asked the FEC to be allowed to hide the identity of their contributors, saying that (like the Socialist Workers Party or the NAACP) they are at risk of retribution for contributing and therefore deserve an exemption to normal reporting requirements. (See their exhibits pt 1, pt 2; see also their ongoing litigation vs the FEC.)

The Campaign Legal Center and Democracy 21 filed a comment opposing the TPLF's request.

On November 15th, the FEC issued two draft advisory opinions (draft A saying that they may have a blanket exemption, draft B saying they may not have any).

On November 17th, we filed a comment to highlight three considerations that we feel should be addressed in any request for a reporting exemption: the elements of the Buckley exemption, a distinction between contributor and expenditure exemption, and the transitivity of exemptions.

Several others submitted comments: Carol Ann Ogdin, C.M. Baker, Daniel Torre, Donald Brake, Campaign Legal Center & Democracy 21, Robert E. Rutkowski, and CREEDO Action.. The TPLF submitted further exhibits.

On November 21st, the FEC did not pass the request (voting 2-3, audio).