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Make Your Laws
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*This* is what democracy looks like.
*This* is what democracy looks like.

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Contribution laundering & Citizens United petitions to FEC - you can participate

https://www.makeyourlaws.org/fec/laundering
https://www.makeyourlaws.org/fec/ravel_weintraub

The first is a fairly narrow proposal we made specifically to address the C4/C6->SuperPAC contribution laundering loophole. It's made narrowly to not require disclosure of funds used for issue advocacy, nor small donors, while still ensuring disclosure of significant sources of money that ultimately gets used to influence an election.

The second is a verbatim resubmission of the Ravel/Weintraub petition, which is meant to encourage broader public discussion and proposals (and moot the procedural concerns with Commissioners petitioning their own agency).

Public and private feedback welcome on both. See the pages for instructions on how to file public comments.

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Going dark; help needed to maintain MYL

1. I have to go dark for a while.

This means no public/group visible online posting at all, no comment on most political / legal issues, and a few other things. I don't know for how long; probably anywhere from a couple months to a year, starting around the end of this month. TBD.

For now, that's all I can say. I hope to have an update later this month with some more details. FWIW, it's due to a good thing for once; just one that comes with some significant tradeoffs, this chief among them.

I am of course still interested in social contact, talking about subjects unrelated to law and politics, and staying informed about current events. I would appreciate being included in social events, private chats, etc.

If you have any questions or comments, please contact me privately (https://s.ai/contact), though please understand that I may not be able to respond to some things.


2. I need help to take over my ongoing responsibilities by end of month, at least for the period while I'm semi-offline.

The most important is +Make Your Laws, which will be dormant during this period. Although MYL isn't currently engaged in any political activity (let alone partisan activity), I should still separate myself as much as possible for the interim.

I need a couple reliable people to take over minimal maintenance.

If you could do any subset of these things, please contact me privately ASAP. Some of it requires being a US citizen; some does not — just let me know your status and what you could do.

* basic sysadmin (installing apt / ruby / gem security patches, restarting puma if it dies and monit fails to catch it, etc)
* basic secretarial / data entry (downloading bank statements, entering the transactions into a google spreadsheet, making sure it matches)
* filing quarterly/semiannual FEC financial reports
* filing annual reports to IRS and Delaware (~1 page each per the 3 MYL corps; DE requires payment form MYL accounts)
* ensuring they have the money to keep operating, keeping an eye on expenses, not letting accounts go overdrawn, etc; everything should be on autopay, but there might be gaps to handle manually
* dealing with random things may come up - e.g. talking to IRS about filing / status issues, to Wells Fargo about account issues (possibly in person at a branch)
** very unlikely but possible: FEC inquiries; press; action on our pending rulemaking about contribution laundering (which they've been sitting on for 2 years)


I can bootstrap new people through any of this, and help behind the scenes a little bit if there's something baffling. We have pro bono lawyers if that's needed, a simple task/reminder system, and Google Apps (mainly drive & mail).

A couple non-maintenance things that would be even more helpful:
* paperwork for a small backdated salary to me from the c3, which was previously approved and would eg let me qualify for Social Security disability; I can't touch it due to conflict of interest
* coding (mainly ruby/rails & OSS) on eg payment processing, checkout, sharing, OFX sync, automating FEC reports, etc

The coding is the crucial part to having MYL actually launch. That's what's been holding it back; the legal and planning side is pretty much totally prepped.


That's about it for now — I need to shift my social life to avoid any public presence, and ensure MYL is maintained.

If you can help, I'd very much appreciate it.

It's going to be a big change for me, and disrupt a lot of my life… but I wouldn't do this if it weren't worth it. Sorry for the necessary temporary secrecy.

Please stay in touch.

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Today, makeyourlaws.org switched SSL configuration a bit.
a) Our EV cert now has Certificate Transparency support.
b) Several cipher suites have been removed, per RFC 7540
pre: ECDH+AESGCM:DH+AESGCM:ECDH+AES256:DH+AES256:ECDH+AES128:DH+AES:ECDH+3DES:DH+3DES:RSA+AESGCM:RSA+AES:RSA+3DES:!aNULL:!MD5:!DSS
post: EECDH+AESGCM:EDH+AESGCM:AES256+EECDH:AES256+EDH (w/ ECDH curve secp384r1)
c) switched from SPDY to HTTP2 (along w/ nginx & google pagespeed upgrades)
d) SSL session tickets have been disabled, due to concerns about forward secrecy protection. This may have some performance penalty.

This means improved security and faster page speed for most people. 

However, Windows XP is no longer supported at all, because its versions of IE 6 & 8 don't support secure SSL versions. (IE 6 hadd already been dropped in our previous SSL update.)

No ALPN for now, pending Ubuntu putting out an openssl 1.0.2 update. (It's currently 1.0.1f.)

One issue that has concerned me lately is the balance of transparency of MYL's operations and legal privilege and strategy. A lot of what we have been doing lately is on the legal side — pursuing policy changes with the FEC through advisory opinions and petitions for rulemaking.

These necessarily involve consultation with our lawyers, which we can't disclose because it would jeopardize attorney/client privilege.

It also involves a lot of strategic decision making, as well as negotiation with potential collaborators. What we plan to do, when, and how, is often something that can't readily be discussed publicly without harming their potential for success.

A lot of the rest isn't sensitive, but just not particularly interesting. One recent example: we filed for and received IRS recognition of MYL C3's 501(c)(3) tax-deductible status, and enrolled in Benevity / GooglersGive so that we can get employer-matched donations. These things need doing, but aren't really worth public input enough to justify the effort to write them up.

I'd be interested in reading any feedback or suggestions y'all may have on how we can balance our commitment to transparency with our need for some things to be non-public (especially in prep stages) — as well as the pragmatic issues of having limited resources to spend (where posts like this compete for time working on e.g. drafting an upcoming AOR). - +Sai 

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Tuesday 27 is the LAST DAY to comment. Email the #FEC @ https://www.makeyourlaws.org/fec/laundering & help us stop contribution laundering!
If you care about stopping contribution laundering, or enacting reforms in the wake of Citizens United, just send an email using the links below. You have until October 27, but please don't wait. This isn't a toothless petition — it's actual rulemaking that could change the law if approved, and that we can follow up in court if it isn't. Comments matter. Please send yours today.

https://www.makeyourlaws.org/fec/laundering
https://www.makeyourlaws.org/fec/ravel_weintraub

Post has shared content
Tuesday 27 is the LAST DAY to comment. Email the #FEC @ https://www.makeyourlaws.org/fec/laundering & help us stop contribution laundering!
Contribution laundering & Citizens United petitions to FEC - you can participate

https://www.makeyourlaws.org/fec/laundering
https://www.makeyourlaws.org/fec/ravel_weintraub

The first is a fairly narrow proposal we made specifically to address the C4/C6->SuperPAC contribution laundering loophole. It's made narrowly to not require disclosure of funds used for issue advocacy, nor small donors, while still ensuring disclosure of significant sources of money that ultimately gets used to influence an election.

The second is a verbatim resubmission of the Ravel/Weintraub petition, which is meant to encourage broader public discussion and proposals (and moot the procedural concerns with Commissioners petitioning their own agency).

Public and private feedback welcome on both. See the pages for instructions on how to file public comments.

Post has shared content
And yes, you can comment without being a US citizen.
If you care about stopping contribution laundering, or enacting reforms in the wake of Citizens United, just send an email using the links below. You have until October 27, but please don't wait. This isn't a toothless petition — it's actual rulemaking that could change the law if approved, and that we can follow up in court if it isn't. Comments matter. Please send yours today.

https://www.makeyourlaws.org/fec/laundering
https://www.makeyourlaws.org/fec/ravel_weintraub

Post has shared content
If you care about stopping contribution laundering, or enacting reforms in the wake of Citizens United, just send an email using the links below. You have until October 27, but please don't wait. This isn't a toothless petition — it's actual rulemaking that could change the law if approved, and that we can follow up in court if it isn't. Comments matter. Please send yours today.

https://www.makeyourlaws.org/fec/laundering
https://www.makeyourlaws.org/fec/ravel_weintraub

Post has attachment
If you care about stopping contribution laundering, or enacting reforms in the wake of Citizens United, just send an email using the links below. You have until October 27, but please don't wait. This isn't a toothless petition — it's actual rulemaking that could change the law if approved, and that we can follow up in court if it isn't. Comments matter. Please send yours today.

https://www.makeyourlaws.org/fec/laundering
https://www.makeyourlaws.org/fec/ravel_weintraub

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This is a very interesting & thorough advisory opinion request re "non-candidate" candidates. It asks the FEC permission to have SuperPACs coordinate with political candidates who claim not to be, saying it's probably illegal, but leaves them at a competitive disadvantage not to do when their opponents are doing it.

 If you have comments, email ao@fec.gov, and mention "AO 2015-09".
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