RFR-Page 2
Yes, MCL 169.215 provides: The secretary of state shall do all of the following: (e) Promulgate
rules and issue declaratory rulings to implement this act in accordance with the administrative
procedures act of 1969, 1969 PA 306, MCL 24.201 to 24.328.
MCL 169.223 says in relevant part: " . . . the secretary of state shall promulgate rules for the
withdrawal of funds from a committee account for petty cash expenditures and for keeping
records of the withdrawals."
MCL 169.224(7) says: "Upon the dissolution of a committee, the committee shall file a
statement indicating dissolution with the filing officials with whom the committee's statement of
organization was filed. Dissolution of a committee must be accomplished pursuant to rules
promulgated by the secretary of state under the administrative procedures act of 1969, 1969
PA 306, MCL 24.201 to 24.328."
MCL 169.247(3) says in relevant part: "The size and placement of an identification or disclaimer
required by this section must be determined by rules promulgated by the secretary of state."
9. Please describe the extent to which the rules conflict with or duplicate similar rules,
compliance requirements, or other standards adopted at the state, regional, or federal level.
The rules do not conflict with or duplicate similar rules, compliance requirements, or other standards
adopted at the state, regional, or federal level.
10. Is the subject matter of the rules currently contained in any guideline, handbook, manual,
instructional bulletin, form with instructions, or operational memoranda?
The proposed rules address topics that are also covered in the Department’s Committee manuals
and appendices that currently serve as guidance from the Department, as well as declaratory rulings
and interpretive statements on questions of campaign finance.
11. Are the rules listed on the department’s annual regulatory plan as rules to be processed for
the current year?
No
12. Will the proposed rules be promulgated under Section 44 of the administrative procedures act
of 1969, 1969 PA 306, MCL 24.244, or under the full rulemaking process?
MCL 24.244 (1)
A. Explain why the rules are being promulgated under 24.244.
The purpose of this rulemaking transaction is to rescind part 2 and part 3 of the existing
campaign financing rules because those parts are being promulgated as new, standalone
rulesets in separate transactions. Part 2 and Part 3 need to be rescinded from this existing rule
set because the rules in Part 2 and Part 3 will be obsolete when the new, updated standalone
rule sets are promulgated.
Based on the information provided in this RFR, MOAHR concludes that there are sufficient policy and legal
bases for approving the RFR. The RFR satisfies the requirements of the administrative procedures act of
1969, 1969 PA 306, MCL 24.201 to 24.328, and Executive Reorganization Order No. 2019-1, MCL 324.99923.
MCL 24.239