Firewalls and Programmatic Independence


Susan Finkle-Sourlis, Monika Graham, Leslie Barnes


501(c)(4) Advocacy, Affiliated Organizations, Coalitions, Election Related Activities


On this episode, we discuss best practices for working in coalition and with affiliated organizations and the importance of firewalls to 501(c)(4)s that engage in independent expenditures.

Our Attorneys for This Episode:

Monika Graham Susan Finkle-Sourlis Leslie Barnes

In this Episode

Working in Coalition – Affiliated Organizations 

  • Maximize advocacy and resources
  • 501(c)(3) and 501(c)(4) activities
  • Establishing legal, financial, and programmatic independence
  • Separate names, logos, EIN, and activities
  • Cost sharing agreements
  • Separate or joint websites and social media accounts
  • Timesheets
  • Branding matters

Firewalls – 501(c)(4)s and political organizations, candidates and committees

  • What are independent expenditures?
  • Why are independent expenditures important?
  • Establishing firewalls to protect against impermissible coordination
  • Safe harbors for permissible communications
  • FEC firewall policy


Please check out the resources listed below and our extensive resource library at for more information on this topic. We hope you join us on a future episode of the podcast!