Political Action Committee & Personal Political Contributions Become the Next Reputational Challenge for Law Firms & Their Clients

Aesop perhaps said it best: “You are known by the company you keep.” It appears many organizations are learning the true meaning of that phrase in the wake of the Republican vote against certification of the Electoral College results and the January 6 U.S. Capitol riots.

In a mere week’s time, corporate giants including Marriott International, Dow, JPMorgan, American Express, Nike, Google, Facebook and Microsoft have publicly declared they are pausing contributions from their political action committees (PACS). They are joined by a growing chorus that contains some of the world’s most well-known brands. While most of these organizations have targeted the members of Congress who voted against certification, many are making larger declarations, including Charles Schwab, which announced it is shutting down its PAC and donating the money to charity and to historically Black colleges and universities.

Since the first PAC was established in 1943 by the Congress of Industrial Organizations after Congress prohibited unions from donating directly to political candidates, PACs have been a strategic tool to help law firms, corporations, banks, unions, trade associations and others achieve strategic business objectives affected by the laws and regulations that govern – or hinder – their growth. Corporate PACs, at companies like those listed above, rely on voluntary contributions from employees – and that is likely one of the reasons the decisions announced this past week came so swiftly. It is challenging to keep employees motivated – or to keep them at all – if they suddenly find that their own values are diametrically opposed to those held by the organization they work for.

For an example of how employee values can shape corporate decision making, read this piece we wrote when household goods retailer Wayfair ran into an employee buzz saw after it was discovered the company was supplying bedroom furniture to a federal detention center in Texas. Note too, this story describing the pullback by law firms including Porter Wright and Jones Day after colleagues in the firms raised concerns about their work on the 2020 election challenges.

Aside from employee pushback, the values of other stakeholders that organizations prize no doubt factored into the decisions regarding PAC contributions as well. Those important audiences include customers and clients, investors, suppliers and even the communities in which these organizations operate. Here, social media’s power to harness and broadcast stakeholder outrage are important factors for the PAC distribution committee to consider.

No doubt some of the PAC decisions also were colored by the fact that PAC contributions are now relatively easy to uncover. The Center for Responsive Politics, for instance, hosts a website that makes it easy to discover, by year, how much individual organizations have donated to which parties and to which House and Senate candidates or incumbents. Access to comparable information at the state level varies, but likely will move toward more transparency given recent events. All the above is true, as well, for individuals making political contributions, apart from their PAC contributions. A quick visit to www.fec.gov/data/ opens a page with a simple enter-a-name-here search box and within seconds, one can see campaign donations made by co-workers, friends, competitors, spouses, children, extended relatives and celebrities. Similar easy-to-search databases are available at the state level and most counties across the country.

Combine this access to information with social media’s role as the global town crier and it’s naïve at best to assume no one will notice an individual or PAC’s significant contribution to a recipient of note – especially one with a highly controversial position on high profile issues or a questionable voting record.

While there are many reasons why an individual or organization might decide to support a specific lawmaker, those reasons may not be as readily apparent to stakeholders (including employees), the media or the public.  If yours is not one of the many organizations that have publicly announced that they are withdrawing some or all of their PAC support, now would be a good time to get ready to explain why you’ve supported the individuals you have, and what your path going forward may be. Here are some messages to consider:

  • How does this recipient’s voting record and position align with your organization’s mission and values? How have your contributions helped your organization grow and thrive so it can better serve its stakeholders?
  • If your organization has a strong commitment to corporate social responsibility, how do these contributions support that work?
  • If there are other reasons you support this individual, what are they?
  • If there are reasons why you no longer support this individual, what prompted you to end your support?

In a similar manner, if your organization took a public position in support of hot-button issues like Black Lives Matter and #MeToo, but your political contributions speak otherwise, how will you address that discrepancy (which is likely to be defined by others as hypocrisy)?

If your organization stands behind its record of political support, be prepared to defend that record with transparency and honesty.  And, be prepared to do so before media and social media seize the advantage they have in galvanizing opinion quickly. While your PAC – or the personal checks you’ve written – may be only one small portion of your organization’s government affairs program, these days, it’s the one everyone seems to be talking about.


The views and opinions expressed in posting are those of the author and do not necessarily reflect the views or position of the National Law Review, the National Law Forum LLC  or any of its affiliates.  

© 2020 Hennes Communications. All rights reserved.


GOP Super PAC Men Seek to Overturn Donation Limits: Conservatives Set Sights on Repealing Election-Cycle Contribution Limits to Candidates

An article by Michael Beckel of the Center for Public Integrity was recently published in The National Law Review.  The article discussed Donation Limits from PAC’s:

GOP super PAC men want to make it easier to donate to dozens of candidates

Conservatives set sights on repealing election-cycle contribution limits to candidates

As unlimited contributions flow into super PACs this year, one man is at the center of a new effort to allow people to donate more money, to more candidates, at the national stage.

“I don’t believe government is there to limit us,” Shaun McCutcheon told iWatch News.

McCutcheon is a 44-year-old general contractor in Alabama. He’s the owner, founder and president of Coalmont Electrical Development. He’s a member of the Republican Party who admits he may have a bit of a libertarian streak. And he’s also the treasurer of a super PAC called the “Conservative Action Fund.”

That’s a group that spent more than $43,000 opposing House Financial Services Committee Chairman Spencer Bachus (R-Ala.) in Tuesday’s GOP primary in Alabama, although it has mostly targeted Democrats with its attacks.

In one advertisement it produced last fall, the super PAC accused President Barack Obama of implementing “draconian laws and regulations.” And it aired another adthat featured a “surfing rabbi” and computer-animated versions of Obama, along with New York Democrats Anthony Weiner and David Weprin, dancing in hot dog costumes — all while encouraging voters to support Republican Bob Turner in the special election to replace Weiner after his sexting scandal.

Now McCutcheon is requesting that the FEC repeal the existing biennial limit on how much money individuals can donate to federal candidates.

McCutcheon wants to donate at least $51,900 to multiple federal candidates ahead of the elections this November, spread across more than two dozen conservative politicians, according to documents released by the FEC on Wednesday.

Campaign finance laws, however, currently cap the amount of money individuals can donate to federal candidates at $46,200. (That amount is increased slightly for inflation during odd-numbered years. In 2010, the aggregate limit for donations to candidates during the two-year election cycle was $45,600.)

Federal rules prohibit a person from giving more than $2,500 per candidate per election, with the primary and general election being viewed as separate elections. McCutcheon says he doesn’t want to exceed that amount to any one candidate; he just wants to be able to donate to more candidates than the current cap allows.

Some simple algebra indicates a person would reach the current aggregate limit by giving $2,500 a piece to about 18.5 candidates, or by giving $5,000 a piece to about 9.25 candidates. McCutcheon, according to the request filed with the FEC, wants to donate to 27, all of whom are challengers, with the exceptions of incumbent Reps. Martha Roby (R-Ala.) and Michele Bachmann (R-Minn.), the founder of the House Tea Party Caucus who unsuccessfully ran for the 2012 GOP presidential nomination.

A question of corruption

In his request before the FEC, McCutcheon is represented by attorneys Steve Hoersting, and Dan Backer of the D.C.-based DB Capitol Strategies and Jerad Najvar of the Houston-based Najvar Law Firm.

Hoersting, who co-founded the First Amendment rights-focused Center for Competitive Politics, and Backer are experienced campaign finance litigators. Their successes include 2011’s Carey v. Federal Election Commission federal court ruling, which granted most political action committees the ability receive unlimited contributions to fund independent political advertisements in a segregated bank account, separate from the money they typically collect to dole out donations to candidates.

These men believe that the U.S. Supreme Court’s 2010 Citizens United v. Federal Election Commission decision, which allowed unlimited spending by corporations and unions on political advertisements, provides a “solid” foundation for bringing forward McCutcheon’s request at this moment in time.

“The Supreme Court has been clear: campaign finance laws are constitutional when they prevent the corruption of candidates, and unconstitutional when they constrain some speakers to equalize others,” Hoersting told iWatch News.

“An aggregate limit on how much one individual can give to all candidates,” he continued, “constrains speakers without preventing either any additional corruption of candidates or circumvention of the $2,500 limit that any single candidate may receive.”

But not all campaign finance observers agree.

Paul Ryan, an attorney at the nonpartisan Campaign Legal Center, which favors campaign finance regulations, says the limit reduces the threat of corruption.

Absent that limit, Ryan argues, a wealthy donor, if he or she wanted, could give $2,500 or even $5,000 to all 535 members of Congress. Furthermore, that donor could also write $5,000 checks to each and every challenger to “ensure access” even if the incumbents lose. And if a wealthy donor gave millions of dollars to every candidate and officeholder, “the public would most certainly be left with the reasonable impression that the wealthy donor had all of Congress in [his or her] pocket.”

“This would surely undermine the electorate’s faith in our democracy,” he said.

For his part, McCutcheon has already donated more than $143,000 to federal candidates and political committees, according to an iWatch News analysis of campaign finance filings with the FEC.

He’s only donated $7,500 to federal candidates — $2,500 to Alabama Republican House candidate Scott Beason and $5,000 to Ohio Republican Senate candidate Josh Mandel. The bulk of McCutcheon’s giving this cycle has been to his super PAC, the Conservative Action Fund, to which he has contributed $82,300, including $75,000 in loans.

This election cycle, he also loaned a hefty chunk of change to another super PAC that he was involved with: “America Get Up,” which he gave $31,500, about half of which was repaid before the super PAC, which was formed in March of 2011, closed its doors last summer.

McCutcheon served as the treasurer of the now-defunct group, which was founded by Dale Peterson, the quick-talking, horse-riding, cowboy hat-wearing, gun-toting candidate for the Alabama Agriculture Commissioner whose first campaign ad in 2010 became an internet phenomenon.

Backer, of DB Capitol Strategies, was also involved with both America Get Up and the Conservative Action Fund, and as the assistant treasurer for each group, he regularly filed their paperwork with the FEC.

FEC may not have final say

While individuals are free to donate as much as they please to super PACs, that’s not the case with federal candidates, party committees or traditional PACs. And some say this new request before the FEC is unlikely to change that any time soon.

“The FEC has absolutely no authority to grant this request,” Larry Noble, an attorney who specializes in campaign finance law at D.C.-based firm Skadden, Arps, toldiWatch News. “A federal agency cannot declare an act of Congress unconstitutional.”

The existing contribution limits were set by Congress in the Bipartisan Campaign Reform Act of 2002, often called the “McCain-Feingold” campaign finance law after its chief sponsors in the U.S. Senate.

Action by the judicial branch of government would be required to declare the election-cycle aggregate contribution limits unconstitutional. And if the courts become involved in this fight, some political observers say the U.S. Supreme Court under the leadership of Chief Justice John Roberts may be sympathetic to McCutcheon’s case.

One such person is Rick Hasen, an election law expert and professor at the University of California-Irvine law school.

“I’ve thought for a long time that the aggregate limits could be in trouble before the Roberts Court,” Hasen told iWatch News.

That may be precisely where McCutcheon’s legal team hopes their case goes.

“I would not be surprised if the FEC is not the final stop in this matter,” said attorney Backer.

Reprinted by Permission © 2012, The Center for Public Integrity®

Help for Super PACs on its Way: At Least Four Cabinet Members May Go to Bat for Democratic Super PACs

An article regarding Super PAC’s was recently published in The National Law Review by Michael Beckel of the Center for Public Integrity:

Fundraising activities are limited, but star power brings in the bucks

At least four Cabinet members appear ready and willing to answer President Barack Obama’s call to help fill the coffers of Democratic outside spending groups, which have to date been badly outgunned by better-funded Republican organizations.

After previously denouncing the so-called “super PACs” as a “threat to democracy,” Obama signed off last week on a move to allow top campaign aides and high-level White House officials to raise money.

Some of those going to bat for the president have long histories of raising money for their own political careers, and even bundling money for Obama’s campaign four years ago.

Interior Secretary Ken Salazar, Energy Secretary Steven Chu, Education Secretary Arne Duncan and U.S. Trade Representative Ron Kirk have all indicated they would be open to participation in activities designed to help the nascent Democratic super PACs, like “Priorities USA Action,” raise money.

“Arne has spoken at campaign-related events in the past on his personal time,” Education spokesman Justin Hamilton told iWatch News. “While he doesn’t yet have any invitations to future events, any that he might attend will be done in strict compliance with the law.”

A similar willingness was also expressed by Interior spokesman Adam Fetcher, whose boss raised more than $13.5 million for his own U.S. Senate campaigns before Obama asked him to become Secretary of the Interior in 2009, according to the Center for Responsive Politics.

“Any invitation for the Secretary to speak at campaign events will be considered in the same way we evaluate all scheduling requests, which includes making sure that all appearances fully comply with rules governing political activity,” Fetcher told iWatch News.

A spokesperson in the office of the U.S. Trade Representative likewise noted that whatever campaign-related activities Kirk may engage in would be cleared by the general counsel’s office in advance.

This wouldn’t be the first time that Kirk has helped Obama’s team raise money: He personally bundled between $50,000 and $100,000 for Obama’s campaign four years ago, according to the Center for Responsive Politics.

This nexus of power and the chase for campaign cash doesn’t sit well with many good-government advocates, especially when there’s no limit on how much money donors can give to super PACs.

“This brings into focus the whole issue of access and influence,” said Meredith McGehee, policy director for the Campaign Legal Center, a nonpartisan group that frequently supports campaign finance reforms. “When you give money, you get access and influence – a way to be heard differently from everyone else.”

Obama’s change of heart was clearly due to the fundraising disadvantageDemocratic super PACs and nonprofits have experienced compared to their Republican counterparts.

Generally speaking, federal law prohibits top White House officials like Cabinet secretaries from using their positions to raise money for candidates. The Hatch Act allows government officials to personally donate money to political committees or engage in a variety of partisan activities, so long as they do so during their personal time and do not use government resources.

They may not solicit campaign contributions — but that doesn’t prohibit them from appearing at political fundraisers.

Last year, several administration officials, including Duncan and Chu, appeared at fundraising events for the Obama campaign, as part of a “speakers series,” in which donors contributed money and mingled with high-level White House officials.

Those events, even while upholding the letter of the law, earned criticism from many Republicans, including Karl Rove, the former senior advisor and deputy chief of staff to President George W. Bush.

“What they’re doing is establishing a process by which you can buy influence,” Rove said at the time.

Rove himself had appeared at fundraisers for Bush during his time as a White House aide. He also helped operate a “political boiler room” within the White House that was criticized in an official Office of Special Counsel report last year.

Meanwhile, some other seasoned rainmakers in Obama’s Cabinet won’t be on the fundraising stump.

United Nations Ambassador Susan Rice, who bundled between $50,000 and $100,000 for Obama’s campaign four years ago, will not be participating in any fundraising events for either the new super PACs or the president.

The same is true of Secretary of State Hillary Clinton, who raised more than $200 million during her unsuccessful presidential run in 2008 – and more than $80 million during her two U.S. Senate bids after leaving the White House.

Defense Secretary Leon Panetta, Attorney General Eric Holder, Transportation Secretary Ray LaHood and Homeland Security Secretary Janet Napolitano are among other top Obama administration officials who are not expected to appear at any fundraisers.

“Longstanding Department of Defense policy requires that the Secretary and all Senate-confirmed and non-career senior executive service officials refrain from participating in partisan political activities,” said Carl Woog, a DOD spokesman.

LaHood — who raised about $7 million over his career as a congressman, according to the Center for Responsive Politics — “hasn’t and won’t be participating in any political fundraising,” said DOT spokesman Justin Nisly.

Super PACs were created last year in the wake of two federal court rulings, including the U.S. Supreme Court’s Citizens United v. Federal Election Commission decisionThey can collect unlimited amounts of money from individuals, unions and corporations to spend on advertising to elect or defeat candidates, but cannot illegally coordinate with the candidates themselves or make direct contributions.

Not everyone is concerned about Cabinet members being involved in the super PAC money chase.

“You don’t lose your rights to free speech just because you hold public office,” conservative attorney Dan Backer of DB Capitol Strategies said. “You may have a public trust, but you shouldn’t lose your free speech rights.”

Reprinted by Permission © 2012, The Center for Public Integrity®.

‘Outsider’ Candidate Santorum Collected Millions in Corporate PAC Money

An article published in the National Law Review recently by Josh Israel and Aaron Mehta of the Center for Public Integrity regarding Candidate Santorum’s PAC Campaign Donations:

 

 

Santorum’s corporate backers: Santorum took on ‘special interests’ while collecting millions in corporate PAC money

Who bankrolled Rick Santorum?

Rick Santorum the presidential candidate casts himself as a Washington outsider, “one of the most successful government reformers in our history,” according to his campaign bio, “taking on Washington’s powerful special interests from the moment he arrived in our nation’s capital.”

But Rick Santorum the House and Senate member received more than $11 million in contributions from corporate and other special interest political action committees (PACs) over his career, according to a Center for Public Integrity investigation.

Among the largest donors are giants from the telecommunications, tobacco, and banking industries, the analysis found. The Center examined contributions to the Pennsylvanian’s congressional, senatorial and 2012 presidential campaigns — as well as his “America’s Foundation” and “Fight PAC” leadership PACs, entities set up by Santorum to aid others in their political campaigns.

Corporate PACs connected to telecommunications firms that became today’s AT&T Inc. poured more than $98,000 into Santorum’s campaign coffers, making the behemoth his top career patron.

Those donations may have been rewarded with support for the industry; in 1996 Santorum was one of 91 Senators to approve the heavily lobbied rewrite of telecommunications law that deregulated the industry.

Government watchdog group Common Cause decried the industry for “buying” the legislation.

Verizon Communications Inc. (and companies now part of the Verizon empire, including GTE, Bell Atlantic Corp., NYNEX and Verizon Wireless, a joint venture with British wireless giant Vodafone Group PLC), also made the top-ten (No. 6), with more than $75,000 in corporate PAC contributions.

Santorum’s second-highest total came from the Altria Group, including predecessor companies like the Philip Morris Companies and U.S. Tobacco. The makers of Marlboro cigarettes and Skoal tobacco have spent more than $96,000 in PAC funds to advance Santorum’s political career.

Santorum, a member of the Senate Committee on Agriculture, Nutrition and Forestry, opposed increased restrictions on the tobacco industry — joining with 39 other Republicans and two tobacco-state-Democrats to kill the 1998 Universal Tobacco Settlement Act.

The bill aimed to “prevent the use of tobacco products by minors” and to “redress the adverse health effects of tobacco use.” It also would have incorporated a settlement requiring the industry to pay billions of dollars to state governments. After Congress failed to pass it, a narrower settlement was reached between the tobacco companies and state attorneys general.

In addition, documents made public as a result of the tobacco settlement with the states indicate that representatives from Philip Morris communicated with then-Rep. Santorum in 1994 during the debate on the Clinton health care reform proposals.

A March 20, 1994, interoffice memo notes that several company employees attending public meetings with Santorum reported “very positive” conversations aimed at ensuring his opposition to an increase in the federal excise tax on cigarettes.

Santorum’s Nos. 3, 4, 5, 7 and 8 backers were all financial services companies. Bank of America Corp. and companies it has acquired gave more than $92,000; PNC Financial Services Group Inc., a Pittsburgh-based bank, gave more than $87,000; JPMorgan Chase & Co. gave at least $76,000; Wells Fargo & Co. gave more than $73,000; and Bank of New York Mellon Corp. gave more than $69,000.

Santorum served on the Senate’s Committee on Banking, Housing and Urban Affairs and was one of 54 senators to back the Financial Services Modernization Act of 1999 (commonly known as Gramm-Leach-Bliley), a bank deregulation law signed by President Clinton.

That law eliminated several restrictions on the size and scope of banks, precipitating the mergers that allowed these and other financial services giants to merge and grow. The law has been blamed for setting the stage for the financial collapse of 2008 and resulting recession. Despite the banks’ largesse, Santorum has been a vocal opponent of the Troubled Asset Relief Program bank bailout, often using it as a club against other Republican candidates.

Rounding out the top 10 were GlaxoSmithKline PLC (more than $68,000), a pharmaceutical company, and energy powerhouse Exelon Corp. (more than $67,000).

Corporate PACs are funded by employees who may give up to $5,000 per calendar year. The PAC itself may give $5,000 per election to candidates. These PACs are usually controlled by the corporation’s chief lobbyist.

It should be no surprise that Santorum’s donors are among the biggest corporate interests in the country.

The anti-tax lobbying group Club for Growth rates Santorum’s record on economic issues in the U.S. Senate as “above average,” while the U.S. Chamber of Commerce gave him a 100 percent rating for 2005.

And if elected, it is likely Santorum will continue his support for business.

On his website he promises to cut the corporate tax rate in half “to make our businesses competitive around the world,” eliminate the corporate income tax for manufacturers and sharply reduce taxes on repatriated foreign income. The Center recently reported on how the issue of repatriation is currently a cause célèbre for many large corporations.

As Bloomberg reported recently, since his 2006 Senate re-election defeat, Santorum has received hundreds of thousands of dollars in directors’ fees and stock options from Universal Health Services Inc. Though it did not rank among his top patrons, Santorum received at least $11,500 from that company’s PAC.

Santorum later received a consulting contract with Consol Energy Inc., reportedly worth more than $140,000. The Pennsylvania-based company donated almost $20,000 to Santorum while he was in office. The Center previously reported on Consol’s long-wall mining operations in southwestern Pennsylvania.

Santorum’s campaign did respond to a request for comment on this story.

Here is a list of Santorum’s top 10 political action committee donors:

  1. AT&T – at least $98,603
  2. Altria – at least $96,500
  3. Bank of America – at least $92,250
  4. PNC – at least $87,805
  5. JPMorgan Chase – at least $76,000
  6. Verizon – at least $75,165
  7. Wells Fargo – at least $73,050
  8. Bank of New York Mellon – at least $69,374
  9. GlaxoSmithKline – at least $68,305
  10. Exelon – at least $67,589

Source: Center for Public Integrity analysis of contributions from political action committees to Rick Santorum’s congressional, senatorial, and presidential campaign committees and leadership PACs: “America’s Foundation” and “Fight PAC.” Data was obtained from subscription-only CQ-MoneyLine, and covered Santorum’s first campaign, in 1989-1990. The data was retrieved Jan. 4, 2012.

Republican presidential candidate, former Pennsylvania Sen. Rick Santorum speaks during a town hall meeting in South Carolina.David Goldman/AP

Reprinted by Permission © 2012, The Center for Public Integrity®. All Rights Reserved.

‘Super PACs’ Spend $13 Million on Early Primaries, Romney Top Beneficiary

Posted previously by the National Law Review, an article by The Center for Public Integrity regarding Super PACs Spending on Early Primaries:

New outside spending groups, dubbed super PACs, that can accept unlimited donations from corporations and wealthy individuals, spent $12.9 million in Iowa and other early GOP battleground states through New Year’s Day, according to an analysis of federal data.

The top beneficiary was former Massachusetts Gov. Mitt Romney. A total of $4.6 million was spent to help the nominal front-runner, the vast majority for ads torpedoing former House Speaker Newt Gingrich. Second was Texas Gov. Rick Perry, who benefited from $3.7 million in outside spending.

According to a Center for Public Integrity analysis of Federal Election Commission data,12 outside super PACs spent money, mostly on advertising, with the intention of electing or defeating a GOP presidential candidate. Ten have not yet reported their donors. The two that have did so last summer.

The upshot is that voters in Iowa, New Hampshire, South Carolina and Florida, all of whose contests will be held this month, won’t know who is paying for much of the advertising they see until after their votes are cast.

The next reports on donors aren’t due until January 31, the day of the Florida primary.

Federal court decisions in 2010 made it possible for individuals, corporations and labor unions to give unlimited contributions to political organizations (super PACs) and certain types of nonprofits, which can then spend the money to elect or defeat candidates. The groups are prohibited from coordinating their activities with candidates.

The top super PAC spender was “Restore Our Future” — the ambiguously named group set up to help Romney. The group spent $4.1 million, all of it in opposition to Gingrich, who enjoyed a brief lead in Iowa polls last month before the shellacking.

Restore Our Future has moved on from Iowa and spent $622,000 in Florida, a likely harbinger of more to come in that high stakes contest. Almost $100,000 has been spent by the pro-Romney group in South Carolina, whose primary is January 21.

Restore Our Future reported raising over $12 million in the first six months of 2011; it is apparently the best-funded of the new breed of PACs, and has received a few seven-figure donations. Not so well known is a second organization that hopped on the Romney bandwagon, Citizens for a Working America Inc.

The group spent $475,000 on a Christmas Eve ad buy praising the candidate.

The group initially supported Rep. Michele Bachmann of Minnesota but changed course shortly before the big ad buy.

The Center traced an address in an FEC filing for Citizens Inc. to the office of JSN Associates in Dayton, Ohio. The “JSN” is James S. Nathanson, who said Monday the group is “very definitely pro-Romney.” He would not say who the group’s donors are.

A previous incarnation of the group met with some controversy when it accepted a single $255,000 donation in 2010 from a Virginia consulting group called “New Models.” Questions were raised as to whether the group was being used as a pass-through for unnamed donors.

A super PAC supporting Perry, “Make Us Great Again,” spent all of its $3.7 million on ads backing the Texas governor.

Former Utah Gov. Jon Huntsman enjoyed the support of “Our Destiny PAC” which spent $1.9 million for ads in New Hampshire, where he opted to compete first rather than Iowa.

Two groups supporting Gingrich ponied up just over $900,000 for TV spots. The bulk of the pro-Gingrich spending was done by “Winning Our Future,” a super PAC that was just started last month.

A surging Rick Santorum, a former U.S. senator from Pennsylvania, enjoyed $631,000 in supportive spending by outside groups.

“Priorities USA,” a super PAC supporting President Obama, was also active, spending a little more than $306,000 on advertising opposing Romney.

And “Endorse Liberty Inc.,” a new super PAC embracing Rep. Ron Paul of Texas, spent more than $448,000, most of that on Internet advertising. It also listed one of the more unusual expenditures of the 2012 campaign — $2,000 on “costumes and makeup.”

Peter Stone contributed to this report.

Reprinted by Permission © 2011, The Center for Public Integrity®. All Rights Reserved.