The Federal Election Commission (FEC) voted unanimously to approve the Explanation and Justification (E&J), implementing the new disclosure rule for lobbyist bundled contributions. In doing so, the FEC finally put into effect section 204 of the Honest Leadership and Open Government Act of 2007. The rules were approved by the FEC in Dec. 2008, but are only now in effect with the E&J. FEC disclosure reports due this summer will include federal candidates' campaign committees and other political committees' lobbyist-bundled contributions.

Bundled contributions included those that are collected by a lobbyist or lobbying organization from at least two other contributors; the threshold to report is $16,000 per lobbyist in a six month period. The FEC has a FAQ on lobbyist bundling, available here.

Many have been critical of these rules for being too lenient and the same concerns were echoed again. Democracy 21 issued a statement that the FEC has "provide[d] members of Congress and other federal candidates with a roadmap on how to circumvent the law and keep secret from the public and the media the amount of money each lobbyist is raising for them."

Whether or not there will be adequate enforcement of all bundled contributions is questionable considering contributions would not have to be reported if a lobbyist "merely tells" a lawmaker that they have raised a certain amount. Contributions only have to be reported if they are recognized through a formal crediting system or if "benefits" are given to a lobbyist for raising a certain amount.

Another criticism is when multiple lobbyists sponsor fundraising events, but they are providing the same bundled contribution. Instead of disclosing each lobbyist as responsible for providing the total amount raised at the event, the committee decides which lobbyist to credit and for how much.