As framed by the Commonsense Ten Advisory Opinion Request, there is no longer a rational justification to prohibit individuals, corporations, and unions from making unlimited contributions to an IE-only PAC.  IE's by themselves do not create the appearance of or actual quid pro quo corruption which the Supreme Court held in Citizens United was the sole grounds to restrict this form of free speech.  As a result, individuals may now lawfully support a cause or candidate through (a) limited direct candidate contributions, (b) limited PAC contributions, and (c) unlimited IE expenditures or contributions to IE-only PACS - but are forced to do so in separate transactions.  This is an unnecessary and possibly unconstitutional restriction of free speech and association.  Individual should be free to contribute to a single PAC both for IE's and candidate contributions provided that the amount applied to direct contributions is (a) intended by the donor (though this is speculative), (b) within the existing limits, and (c) accounted for separately from that unlimited amount intended for IE's.  While SpeechNOW laid the foundation for IE-only PACs, we need not create added bureaucracy nor is there sufficient rationale to limit the free speech and association rights of individual donors.  At the same time, since corporations and unions are likely to now able to contribute to IE-only PACs - the issue brought forth by Commonsense Ten - it is likely that the same PAC can accept unlimited corporate and union contributions so long as accounted for separately from individual contributions used for direct candidate contributions.  Thus, a single non-connected committee PAC should be able to accept both unlimited individual, corporate, and union contributions for IE's (and administrative expenses), and limited individual contributions for direct campaign contributions (and administrative expenses), provided that these contributions are accounted for separately and likely requiring a firewall between IE and direct contribution activities.

Under current law, the Separate Segregated Fund (SSF) has two major features - the benefit of receiving the support of its corporate parent for administrative expenses and the limitation of accepting contributions only from its restricted class.  Should the all-inclusive model of non-connected committees come to pass, it is likely the death knell for the SSF.  If a corporation or union may make unlimited contributions to any PAC, restricted to IE's but including administrative/operating costs, and that PAC may also raise funds from individuals for both IE's (unlimited) and direct candidate contributions (limited), what is the purpose of having an SSF?  The primary benefit - parent company financial support - is achieved without any limitation, and the primary detriment - limited solicitation only to the restricted class - is removed.  As a consequence, it seems likely that corporations may spin-off their SSF PACs, while still retaining nominal control as a function of their principle financial support even as other corporations, unions, organizations, and non-restricted class individuals are potentially solicited.  Conversely, as these PACs absorb political capital from more sources and enhance their influence, they will likely drown out the effectiveness of smaller "Citizen's PACs" - those grassroots activist organizations without a leading personality that will be unable to compete for dollars raised or expenditures made.