The comments are here. One issue in the WRTL rulemaking is whether the as applied exemption required by the Supreme Court’s opinion in WRTL applies only to the corporate and union PAC requirement or whether it also applies to disclosure of electioneering communications (over a certain dollar threshold). You wouldn’t know it by reading the comments, because the issue of disclosure never comes up, but in advocating “Alternative 2” (comments, pages 9-10), the Center is arguing for no disclosure of the funders of issue ads that are entitled to an as applied exemption.
The adoption of Alternative 2 would be a very big deal. I’ll have more on this soon.