The Supreme Court’s Dec. 2003 decision upholding the Bipartisan Campaign Reform Act (BCRA) has raised new questions about what kinds of political action committees are subject to federal campaign finance laws. On Jan. 15 the Federal Election Commission (FEC) voted to consider new regulations defining what kinds of political action committees would be subject to contribution and expenditure limits for federal election activity. FEC plans to have a proposed rule published on March 4. There will be a comment period followed by a public hearing in mid-April. The final rule is expected to be published on May 13. Prior to the Supreme Court’s decision in McConnell v. FEC regulated "federal" election activity was limited to electioneering that used "magic words" that expressly advocated for or against a federal candidate, such as "vote for" or "vote against." FEC regulations had been written and interpreted using this standard. Since the McConnell case held that Congress is not limited to regulating federal activity to express advocacy, the traditional boundary line between regulated and unregulated political committees has been erased. Nothing clearly replaces the old standard, and the FEC rulemaking process is meant to resolve the issue. In the meantime, three campaign finance reform groups filed an enforcement complaint against political action committees that are conducting voter mobilization campaigns with donations from individuals. The complaint says the groups should be subject to the FEC rules, including limits on contributions and expenditures, because they are focusing their efforts on this year's federal election. The complaint was filed by the Campaign Legal Center, the Center for Responsive Politics and Democracy 21 against America Coming Together (ACT), The Media Fund and the Leadership Forum. BCRA bans "soft money" contributions to political parties, but does not directly address the question of soft money contributions to political action committees. Up until now "soft money" has been unregulated by the FEC. (IRS rules require disclosure of these groups' finances.) Similar issues have been raised in two Advisory Committee requests pending at the FEC. One has been filed by Americans for a Better Country, a Republican leaning group, asking about the legality of activities similar to the Democratic leaning ACT's agenda. ACT has also filed a request for clarification of the legality of its program.