Michigan Office of Administrative Hearings and Rules  
Administrative Rules Division (ARD)  
MOAHR-Rules@michigan.gov  
REGULATORY IMPACT STATEMENT  
and COST-BENEFIT ANALYSIS (RIS)  
AGENCY INFORMATION:  
Department name:  
State  
Bureau name:  
Elections & Campaign Finance  
Name of person filling out RIS:  
Alessa Boes  
Phone number of person filling out RIS:  
517-599-3410  
Email of person filling out RIS:  
BoesA@michigan.gov  
RULE SET INFORMATION:  
ARD assigned rule set number:  
2025-50 ST  
Title of proposed rule set:  
Campaign Finance Committees  
COMPARISON OF RULE(S) TO FEDERAL/STATE/ASSOCIATION STANDARDS  
1. Compare the proposed rules to parallel federal rules or standards set by a state or national licensing agency  
or accreditation association, if any exist.  
There are no parallel federal rules or standards set by a state or national licensing agency or accreditation  
association.  
A. Are these rules required by state law or federal mandate?  
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 169.224(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.  
B. If these rules exceed a federal standard, please identify the federal standard or citation, describe why it  
is necessary that the proposed rules exceed the federal standard or law, and specify the costs and  
benefits arising out of the deviation.  
The rules do not exceed a federal standard.  
2. Compare the proposed rules to standards in similarly situated states, based on geographic location,  
topography, natural resources, commonalities, or economic similarities.  
While there are some differences in certain areas, the proposed rules are generally in line with the standards in place  
in similarly situated states and on the whole impose similar standards. For example:  
Wisconsin: Requires judicial candidates to form a committee and file reports even if claiming an exemption from  
reporting. Wisconsin’s standard is the same as proposed rule 4. Wis Stat 11.0102; See also Campaign Finance  
Checklist – Judicial Offices accessed on https://ethics.wi.gov/Pages/Resources/ResourcesOverview.aspx  
Wisconsin: Requires “conduits” defined as “a person other than an individual that receives a contribution of money  
MCL 24.245(3)  
RIS-Page 2  
from an individual, deposits the contribution in an account held by the person, and releases the contribution to a  
committee at the direction of the contributor” to send to each candidate or committee at the time funds are transferred  
a letter identifying the name and address of the transferee, a list of the name and address of each contributor, and the  
date and amount of each contribution, and the occupation if any of each contributor whose cumulative contributions  
are in excess of $200 for the calendar year. Wis statutes 11.0101(7) (defining conduit); Wis admin rule ETH 1.85 and  
ETH 1.855. Proposed rule 19 addresses third party contribution platforms, which appear to fall into Wisconsin’s  
definition of “conduit” and similarly requires reporting the identity of the individual who sent the money to the third  
party platform and the amount contributed. The proposed rule does not require registration of the third party  
contribution platform itself, unlike Wisconsin’s rules which require registration of the conduit in addition to requiring the  
reporting of identity information. Accordingly, while the proposed rule is similar, it arguably requires less than  
Wisconsin’s regulation.  
Wisconsin: requires all campaign finance filings to be made electronically where the proposed rules merely permit  
electronic filing and only require it where it is required by state law (MCL 169.218). See Wis Stat 11.1304;  
https://campaignfinance.wi.gov/. Despite this difference, the proposed rules and Wisconsin’s standards both provide  
the opportunity for electronic filing.  
Ohio: Requires registration of a campaign committee before receiving any contribution or making an expenditure and  
requires registration to include name of the treasurer and any “deputy treasurer” including their signatures. Also  
requires this statement be updated if the treasurer changes, any contact info changes, etc. All of these standards  
mirror the standards in the proposed rules – the deputy treasurer is similar to the proposed rules’ “record keeper” and  
just like Ohio’s standards, the proposed rules require collection of the same information, signatures, and a continuing  
duty to amend the statement of organization if any information changes. See Ohio Campaign Finance Handbook,  
revised September 2025, Chapter 2, available online: https://www.ohiosos.gov/campaign-finance/campaign-finance-  
handbook/  
Ohio: Ohio’s standards around “termination” of a committee are similar to proposed rule 14 – both require the  
committee to have a zero dollar balance and no outstanding loans or debts before it can terminate (or “dissolve” as  
the proposed rules term it). Both Ohio and Michigan require filing a termination/dissolution statement. See Ohio  
Campaign Finance Handbook, revised September 2025, Chapter 2, available online:  
https://www.ohiosos.gov/campaign-finance/campaign-finance-handbook/  
Ohio: Requires independent expenditures to be reported by the entity that makes them, not by the benefited  
committee. See Ohio Campaign Finance Handbook, revised September 2025, Chapter 2, available online:  
https://www.ohiosos.gov/campaign-finance/campaign-finance-handbook/ Proposed rule 13 also requires independent  
expenditure reports be filed by entities making independent expenditures and these entities may or may not be  
committees themselves. Thus Ohio’s standard and the proposed rules are in line with how they regulate independent  
expenditures.  
Ohio: Finally, proposed rule 12 addressing the death of a treasurer who is also the candidate for a candidate  
committee is similar to Ohio’s approach to this situation. In a 1997 advisory opinion, the Ohio Elections Commission  
opined that when the death of a treasurer occurs for a committee that owes reports, the board of elections must  
address the situation on a case by case basis and may, if necessary, determine a campaign committee closed for  
purposes of filing reports. Ohio Election Commission Advisory Opinion, 97ELC-04. Proposed rule 12 also adopts a  
case by case approach and allows for the filing official to identify appropriate individuals to work with to dissolve the  
committee.  
Illinois: The Illinois administrative code contains more extensive standards surrounding committee naming  
conventions than the proposed rules. The proposed rules, in rule 8, require only that the full name of the committee be  
included on the statement or organization (not initials) and that the committee have a unique name that is different  
than an existing committee. The Illinois standards, in their administrative rules, require:  
“Candidates who exercise the option of forming a political action committee may not include the names of any of the  
candidates in the name of the political action committee. A political action committee must, however, include the name  
of the office that the candidates are seeking and the name of the political subdivision or unit of local government to  
which the office pertains.” IL Administrative Code, Section 100.10(b)(5)(D).  
“If an entity forming a political action committee under Code Section 9-2(d) is not a clearly identifiable trust,  
partnership, committee, association, corporation or other organization, but rather a group of persons lacking any  
formal organizational structure, the name of the political committee shall include the name (first and last) of the person  
MCL 24.245(3)  
RIS-Page 3  
or persons responsible for its formation or its continuing operation.” Section 100.10(b)(5)(E).  
“The name of a ballot initiative committee must include a brief description of the question or questions and whether  
the committee is organized to support or oppose the question or questions. The name shall not exceed 70 characters  
(based on U.S. Post Office restrictions applicable to mailing labels) and shall include keywords that would provide a  
reasonable person with a general understanding of the subject matter of the question or questions and whether the  
committee was formed to support or oppose the question or questions.” Section 100.10(b)(5)(F).  
Accordingly, the proposed rules provide for less regulation around committee naming than the Illinois rules.  
A. If the rules exceed standards in those states, please explain why and specify the costs and benefits  
arising out of the deviation.  
The rules do not exceed the standards in other states.  
3. Identify any laws, rules, and other legal requirements that may duplicate, overlap, or conflict with the  
proposed rules.  
The rules do not conflict with or duplicate any laws, rules, or other legal requirements. The proposed rules may  
overlap with existing state, federal, and local laws to the extent that there are existing state, federal, and local laws  
that also address campaign finance. However, to the extent that the proposed rules overlap, they are coordinated to  
avoid any actual duplication, as discussed in answer 3(A). The proposed rules would codify existing manuals and  
appendices from the Secretary of State.  
A. Explain how the rules have been coordinated, to the extent practicable, with other federal, state, and  
local laws applicable to the same activity or subject matter. This section should include a discussion of  
the efforts undertaken by the agency to avoid or minimize duplication.  
The proposed rules are coordinated with state law in that they seek to mirror the definitions and provisions in  
the Michigan Campaign Finance Act, 1976 PA 388, MCL 169.201 to 169.282, and existing instructions from the  
agency. No other state laws are applicable to the same activity or subject matter. The proposed rules are not  
coordinated with federal law even though there are federal campaign finance laws because the federal laws,  
rules, or other legal requirements apply to different filers: federal filers are governed by federal law and state  
law governs state filers. As such, no federal laws, rules, or other legal requirements completely overlap with or  
duplicate the proposed rules. However, in writing the proposed rules, the Department reviewed Federal Election  
Commission rules for federal filers to determine if similar provisions should apply to state filers. The Department  
endeavored to incorporate federal standards to the extent they are consistent with the Michigan Campaign  
Finance Act. The rules are coordinated with local laws to avoid any duplication or confusion because the  
proposed rules clearly indicate that local procedures must be followed where applicable, for example, proposed  
rule 168.310(5). No federal, state, or local laws, rules, or other legal requirements conflict with the proposed  
rules.  
PURPOSE AND OBJECTIVES OF THE RULE(S)  
4. Identify the behavior and frequency of behavior that the proposed rules are designed to alter.  
The rules will not alter the behavior of frequency or behavior for filing officials, staff, or filers. However, they will codify  
existing instructions in the campaign finance manuals and appendices and will lend credence to those instructions.  
A. Estimate the change in the frequency of the targeted behavior expected from the proposed rules.  
It is not anticipated there would be a change given that the frequency of filings is regulated by the Michigan  
Campaign Finance Act and will not change based on the proposed rules.  
B. Describe the difference between current behavior/practice and desired behavior/practice.  
There would be no difference between current behavior/practice and desired behavior/practice. However, while  
behavior/practice is currently guided by manuals and appendices, going forward they would also be guided by  
the Department’s administrative rules.  
C. What is the desired outcome?  
The desired outcome is for the proposed rules to provide greater understanding and knowledge of existing  
behavior/practice.  
MCL 24.245(3)  
RIS-Page 4  
5. Identify the harm resulting from the behavior that the proposed rules are designed to alter and the likelihood  
that the harm will occur in the absence of the rule.  
Currently, campaign finance rules are outdated and may be confusing to filers and the 83 county clerks who accept  
campaign finance filings, as well as Department staff. Updated rules are intended to prevent adverse outcomes such  
as campaign finance violations caused by misunderstanding the rules, and the attendant late filing fees and other  
monetary penalties.  
A. What is the rationale for changing the rules instead of leaving them as currently written?  
The existing rules range from 25-46 years old and do not account for statutory changes in the Michigan  
Campaign Finance Act, as well as case law and changes in interpretation over time. The proposed rules intend  
to modernize the rules so they mirror current practice.  
6. Describe how the proposed rules protect the health, safety, and welfare of Michigan citizens while promoting  
a regulatory environment in Michigan that is the least burdensome alternative for those required to comply.  
The proposed rules would reflect current practice, provide clarity to filing officials responsible for working with filers,  
and alleviate the possibility of confusion and conflict regarding campaign finance reporting.  
7. Describe any rules in the affected rule set that are obsolete or unnecessary and can be rescinded.  
There are no obsolete or unnecessary rules in the rule set that can be rescinded because these rules create a new  
rule set and there is no existing rule set.  
FISCAL IMPACT ON THE AGENCY  
Fiscal impact is an increase or decrease in expenditures from the current level of expenditures, i.e., hiring  
additional staff, higher contract costs, programming costs, changes in reimbursements rates, etc. over and  
above what is currently expended for that function. It does not include more intangible costs for benefits, such  
as opportunity costs, the value of time saved or lost, etc., unless those issues result in a measurable impact on  
expenditures.  
8. Please provide the fiscal impact on the agency (an estimate of the cost of rule imposition or potential savings  
for the agency promulgating the rule).  
It is not expected that the promulgation of rules will have a fiscal impact on the agency promulgating the rules.  
9. Describe whether or not an agency appropriation has been made or a funding source provided for any  
expenditures associated with the proposed rules.  
No agency appropriation has been made, and no funding source has been provided, as it is not anticipated that the  
Department of State will have any expenditures associated with the proposed rules.  
10. Describe how the proposed rules are necessary and suitable to accomplish their purpose, in relationship to  
the burden(s) the rules place on individuals. Burdens may include fiscal or administrative burdens, or  
duplicative acts.  
The proposed rules will largely codify current practice and are not expected to place any additional fiscal or  
administrative burdens on individuals.  
A. Despite the identified burden(s), identify how the requirements in the rules are still needed and  
reasonable compared to the burdens.  
There are no identified burdens.  
IMPACT ON OTHER STATE OR LOCAL GOVERNMENTAL UNITS  
11. Estimate any increase or decrease in revenues to other state or local governmental units (i.e., cities,  
counties, school districts) as a result of the rule. Estimate the cost increases or reductions for other state or  
local governmental units (i.e., cities, counties, school districts) as a result of the rule. Include the cost of  
equipment, supplies, labor, and increased administrative costs in both the initial imposition of the rule and  
any ongoing monitoring.  
There are no estimated increases or decreases in revenue to other state or local governmental units. There are no  
estimated increases or reductions in cost to other state or local governmental units.  
MCL 24.245(3)  
RIS-Page 5  
12. Discuss any program, service, duty, or responsibility imposed upon any city, county, town, village, or school  
district by the rules.  
The proposed rules do not change any duty or responsibility imposed upon any city, county, town, village, or school  
district.  
A. Describe any actions that governmental units must take to be in compliance with the rules. This section  
should include items such as record keeping and reporting requirements or changing operational  
practices.  
It is not anticipated that governmental units would need to take any additional actions under the proposed rules.  
13. Describe whether or not an appropriation to state or local governmental units has been made or a funding  
source provided for any additional expenditures associated with the proposed rules.  
An appropriation has not been made because additional expenditures associated with the rules are not anticipated.  
RURAL IMPACT  
14. In general, what impact will the rules have on rural areas?  
The proposed rules are not expected to impact rural areas.  
A. Describe the types of public or private interests in rural areas that will be affected by the rules.  
The proposed rules are not expected to have any impact on public or private interests in rural areas.  
ENVIRONMENTAL IMPACT  
15. Do the proposed rules have any impact on the environment? If yes, please explain.  
The proposed rules will not have an impact on the environment.  
SMALL BUSINESS IMPACT STATEMENT  
16. Describe whether and how the agency considered exempting small businesses from the proposed rules.  
Small businesses will not be governed or impacted by the proposed rules so the agency did not consider small  
businesses.  
17. If small businesses are not exempt, describe (a) the manner in which the agency reduced the economic  
impact of the proposed rules on small businesses, including a detailed recitation of the efforts of the agency  
to comply with the mandate to reduce the disproportionate impact of the rules upon small businesses as  
described below (in accordance with MCL 24.240(1)(a-d)), or (b) the reasons such a reduction was not lawful  
or feasible.  
The proposed rules do not apply to small businesses.  
A. Identify and estimate the number of small businesses affected by the proposed rules and the probable  
effect on small businesses.  
The proposed rules do not apply to small businesses.  
B. Describe how the agency established differing compliance or reporting requirements or timetables for  
small businesses under the rules after projecting the required reporting, record-keeping, and other  
administrative costs.  
The proposed rules do not apply to small businesses and will not have an impact on their reporting  
requirements.  
C. Describe how the agency consolidated or simplified the compliance and reporting requirements for  
small businesses and identify the skills necessary to comply with the reporting requirements.  
The agency did not consolidate or simplify the compliance and reporting requirements for small businesses as  
the proposed rules do not apply to small businesses.  
D. Describe how the agency established performance standards to replace design or operation standards  
required by the proposed rules.  
The proposed rules do not apply to performance, design, or operation standards in relation to small businesses.  
MCL 24.245(3)  
RIS-Page 6  
18. Identify any disproportionate impact the proposed rules may have on small businesses because of their size  
or geographic location.  
The proposed rules will have no impact on small businesses.  
19. Identify the nature of any report and the estimated cost of its preparation by small businesses required to  
comply with the proposed rules.  
There are no estimated costs for small businesses as the proposed rules do not apply to small businesses.  
20. Analyze the costs of compliance for all small businesses affected by the proposed rules, including costs of  
equipment, supplies, labor, and increased administrative costs.  
The proposed rule set will have no impact on small businesses and require no compliance from small businesses.  
21. Identify the nature and estimated cost of any legal, consulting, or accounting services that small businesses  
would incur in complying with the proposed rules.  
The proposed rule set will have no impact on small businesses and require no legal, consulting, or accounting  
services on behalf of small businesses.  
22. Estimate the ability of small businesses to absorb the costs without suffering economic harm and without  
adversely affecting competition in the marketplace.  
There are no estimated costs for small businesses as the proposed rules do not apply to small businesses.  
23. Estimate the cost, if any, to the agency of administering or enforcing a rule that exempts or sets lesser  
standards for compliance by small businesses.  
There are no estimated costs to the agency for administration or enforcement against small businesses as the  
proposed rules do not apply to small businesses.  
24. Identify the impact on the public interest of exempting or setting lesser standards of compliance for small  
businesses.  
The proposed rules do not apply to small businesses so there will be no impact on the standards of compliance.  
25. Describe whether and how the agency has involved small businesses in the development of the proposed  
rules.  
The agency has not involved small businesses in the development because the proposed rules do not apply to small  
businesses.  
A. If small businesses were involved in the development of the rules, please identify the business(es).  
No small businesses were involved because the proposed rules do not apply to small businesses.  
COST-BENEFIT ANALYSIS OF RULES (INDEPENDENT OF STATUTORY IMPACT)  
26. Estimate the actual statewide compliance costs of the rule amendments on businesses or groups.  
It is not anticipated that there will be any statewide compliance costs.  
A. Identify the businesses or groups who will be directly affected by, bear the cost of, or directly benefit  
from the proposed rules.  
The new rules will update the current rules regarding campaign financing, most of which have not been  
amended since 1979. Filers, county clerks, and Michigan Department of State campaign finance staff will be  
affected by and benefit from the revisions, as they account for intervening updates to the Michigan Campaign  
Finance Act (MCFA), more efficient filing processes. Additionally, the rules will codify questions that have arisen  
and been dealt with informally in the Department’s manuals, appendices, declaratory rulings, and interpretive  
statements. No businesses or groups are anticipated to bear a cost associated with the rules.  
B. What additional costs will be imposed on businesses and other groups as a result of these proposed  
rules (i.e., new equipment, supplies, labor, accounting, or recordkeeping)? Please identify the types and  
number of businesses and groups. Be sure to quantify how each entity will be affected.  
There will be no costs imposed as a result of the proposed rules. It is anticipated that the rules can be followed  
with the current funding appropriated to county clerks and department staff.  
27. Estimate the actual statewide compliance costs of the proposed rules on individuals (regulated individuals or  
the public). Include the costs of education, training, application fees, examination fees, license fees, new  
equipment, supplies, labor, accounting, or recordkeeping.  
MCL 24.245(3)  
RIS-Page 7  
There will be no additional statewide compliance cost. The proposed rules largely codify current practice and would  
be incorporated into existing training. They are not anticipated to impose any additional training costs, and no  
additional costs are anticipated.  
A. How many and what category of individuals will be affected by the rules?  
Campaign finance filers will be minimally affected, as the proposed ruleset will make minor clarifications to  
existing rules. County clerks and department staff will also be affected, as they accept and review filings and will  
benefit from clearer rules. There are 3,941 active committees (campaign finance filers), there are 83 county  
clerks, and about 10 department staff who work with campaign finance.  
B. What qualitative and quantitative impact do the proposed changes in rules have on these individuals?  
The qualitative impact is that filers, county clerks, and MDOS staff rely on the rules to understand aspects of the  
campaign filing process that are not clearly defined in the MCFA. It is not anticipated that the rules would have a  
quantitative impact.  
28. Quantify any cost reductions to businesses, individuals, groups of individuals, or governmental units as a  
result of the proposed rules.  
It is not anticipated that there would be any cost reductions to businesses, individuals, groups of individuals, or  
governmental units as a result of the proposed rules.  
29. Estimate the primary and direct benefits and any secondary or indirect benefits of the proposed rules. Please  
provide both quantitative and qualitative information, as well as any assumptions.  
The primary and direct benefits of the proposed rules are qualitative and are to provide clarity and direction on the  
rules regarding campaign finance committees. A secondary or indirect benefit is both qualitative and quantitative:  
there will be less confusion about the applicability of the MCFA to a certain fact pattern, and fewer individuals will  
request guidance from the Department in the form of interpretive statements or declaratory rulings. The assumption  
being made is that better clarity and direction improves quality and that if there is greater understanding there will be  
less requests for guidance.  
30. Explain how the proposed rules will impact business growth and job creation (or elimination) in Michigan.  
The proposed rules will not impact business growth and job creation (or elimination) in Michigan.  
31. Identify any individuals or businesses who will be disproportionately affected by the rules as a result of their  
industrial sector, segment of the public, business size, or geographic location.  
It is not anticipated that individuals or businesses will be disproportionately affected by the rules as a result of their  
industrial sector, segment of the public, business size, or geographic location.  
32. Identify the sources the agency relied upon in compiling the regulatory impact statement, including the  
methodology utilized in determining the existence and extent of the impact of the proposed rules and a cost-  
benefit analysis of the proposed rules.  
The agency relied upon the Department of State's current practice and on agency staff and its regulatory experience  
to formulate estimates and assumptions and determine the need for the proposed rules.  
A. How were estimates made, and what assumptions were made? Include internal and external sources,  
published reports, information provided by associations or organizations, etc., that demonstrate a need  
for the proposed rules.  
The agency relied upon agency staff and its regulatory and administrative experience to determine the impact of  
the proposed rules. The agency also sent the rules to the Michigan Association of County Clerks and relied on  
their feedback and expertise. Because the proposed rules largely codify current practice, the agency can  
reasonably assume their implementation will not cause any major change to the processes associated with  
campaign finance reporting. The agency assumes that having the administrative rules reflect current law and  
practice will be beneficial and eliminate any confusion that currently exists.  
ALTERNATIVE TO REGULATION  
33. Identify any reasonable alternatives to the proposed rules that would achieve the same or similar goals.  
The only reasonable alternative to the proposed rule to achieve the same or similar goals would be to amend the  
Michigan Campaign Finance Act to provide for the procedures set out in the proposed rules. However, the  
Department cannot amend the law, so this is not a reasonable alternative that is within the Department’s control.  
A. Please include any statutory amendments that may be necessary to achieve such alternatives.  
MCL 24.245(3)  
RIS-Page 8  
The rules are not inconsistent with the MCFA but incorporating them into the MCFA would require a series of  
amendments, ranging from amendments to the definitions sections in the act, MCL 169.202 to 169.212, MCL  
169.224b (regarding independent expenditure committees, which in the rules are linked to their better-known  
name, SuperPACs) to MCL 169.224 (regarding dissolution, though this section explicitly requires the  
Department to promulgate rules regarding dissolution), and addition of some sections to address topics not  
currently explicitly contemplated by the act such as third party contribution platforms.  
34. Discuss the feasibility of establishing a regulatory program similar to that proposed in the rules that would  
operate through private market-based mechanisms. Please include a discussion of private market-based  
systems utilized by other states.  
There are no private market-based mechanisms available to address the needs covered by the proposed rules. The  
department could not find any other state that utilizes a private market-based system. Because no such systems exist,  
a private market-based system is not feasible.  
35. Discuss all significant alternatives the agency considered during rule development and why they were not  
incorporated into the rules. This section should include ideas considered both during internal discussions  
and discussions with stakeholders, affected parties, or advisory groups.  
Due to the nature of regulating campaign finance, no significant alternatives to reasonable regulation were considered  
during the development of the proposed rules. The proposed rules are intended to codify the current legal  
requirements and practices.  
ADDITIONAL INFORMATION  
36. As required by MCL 24.245b(1)(c), please describe any instructions regarding the method of complying with  
the rules, if applicable.  
The rules explicitly inform persons of requirements and methods of compliance.  
MCL 24.245(3)  
;