1. Ellen L. Weintraub is Vice Chair of the United States Federal Election Commission, where she has served as a Commissioner since December 2002 and was Chair in 2003. Samuel C. Brown is an attorney at Allen & Overy, LLP. He previously served as Counsel to Commissioner Weintraub. The views expressed in this article are solely those of the authors. The authors thank Daniel Tokaji, Claire N. Rajan, Daniel I. Weiner, and Nicole K. Zeitler for their helpful suggestions and comments.