Persuasive evidence that circumvention of federal contribution limits has occurred since McCutcheon struck down the aggregate limits.

A fundraising committee operated jointly by the Trump campaign and the Republican National Committee in 2016 served as a vehicle for state parties to pass more than $27 million to the national party in possible violation of contribution limits, the Federal Election Commission’s general counsel found almost three years ago.

The general counsel’s report, available since 2019, was newly released Friday in an updated and unredacted form because of a development in an associated case. It mirrors findings from the FEC general counsel’s office about similar activity by a joint fundraising committee benefiting Hillary Clinton in 2016. The alleged sum funneled through state party committees in that case was even larger: $112 million. . . .

“The facts of this case appear to present the scenario that troubled numerous Justices in McCutcheon: a pre-arranged plan to circumvent the contribution limits via joint fundraising,” the general counsel’s report found in both cases. It determined there was reason to believe the national committees accepted excessive contributions and recommended the FEC reach a similar conclusion.