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ARTICLE · 16 OCTOBER 2026

Compliance Notes - Vol. 7, Issue 20

Federal and state campaign finance regulators continue to scrutinize disclosure requirements and recurring donation practices, while courts weigh the constitutional boundaries of transparency laws. Recent developments include FEC inquiries into software-driven reporting errors, a Ninth Circuit ruling upholding Arizona's donor disclosure law, and California's new quarterly reporting framework for behested payments.

United StatesCorporate/Commercial Law

RECENT LOBBYING, ETHICS & CAMPAIGN FINANCE UPDATES

Campaign Finance & Lobbying Compliance

The Federal Election Commission sent three letters to Senator Eric Schmitt’s campaign between March and August 2026 after reviewing campaign finance reports, seeking clarification of possible reporting errors and contributions above federal limits. Thirteen out-of-state donors appeared nearly 5,700 times in Schmitt’s reports. The reports attributed $85,672 in contributions to those donors after deducting negative entries in amended filings, with individual totals ranging from amounts slightly exceeding the $3,500 per-election contribution limit to more than $10,500. Schmitt’s campaign treasurer attributed the discrepancies to a software error and said amended reports corrected donor information and addressed any excess contributions. The letters do not establish a violation, but they highlight broader questions about recurring online fundraising and the safeguards used to identify excessive

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