Sunlight Foundation Reporting Group

Super PAC profile: Stephen Colbert, Jon Stewart 'not coordinating'

In what may be one of the most pointed political jokes since Jonathan Swift's Modest Proposal, Stephen Colbert's satirical mystery tour has arrived in South Carolina.

As of Wednesday, the political action committee that the comedian founded amid much fanfare last year had spent $65,000 buying time in Charleston, S.C. to air a series of ads: one attacking Republicans who benefit from super PAC spending in general; another attacking Mitt Romney in particular, and a third suggesting that a vote for the now-non-candidate Herman Cain is a vote for faux-candidate Colbert. 

Earlier TV ad campaigns by the PAC in Iowa did not result in reports to the FEC, possibly because they did not explicitly name one of the candidates on this year's presidential ballot.

Colbert recently made an elaborately choreographed handoff of his Americans for a Better Tomorrow Tomorrow PAC to fellow Comedy Central host Jon Stewart, to parody the not-so-arm's length relationship between the shadowy committees that have sprung up in the wake of the Supreme Court's Citizens United decision. Here's a video of him and Stewart "not coordinating:"

The PAC's website now bears a new title: "The Definitely Not Coordinating with Stephen Colbert Super PAC." But the URL that gets you there is still ColbertsuperPAC.com.

Colbert's send-up of federal election laws is being aided and abetted by Trevor Potter, a former Federal Election Commission chairman who is serving as the comedian's election lawyer. Potter has supported other election law reformers: He served as the lawyer for the 2008 GOP presidential nominee, Sen. John McCain, R-Ariz., once contributed to a PAC established by former Sen. Russ Feingold, a Wisconsin Democrat who partnered with McCain to write the McCain-Feingold campaign finance reform law, and more recently provided legal advice for former Louisiana Gov. Buddy Roemer, who is running a quixotic campaign for the GOP nomination based on the premise that it's time to get big money out of politics. 

The (ex) Colbert PAC's most recent filings list as treasurer Shauna Polk, a compliance officer at Potter's law firm and its ad buyer as Media Ad Ventures, which also lists McCain and Mitt Romney among its past political clients. President Brad Mont says his firm worked for Romney's 2002 gubernatorial campaign. As for the PAC's advertising plans, Mont says there's one more ad coming before South Carolina's primary this Saturday "then who knows what Florida might bring."

Colbert has mirrored the super PACs he's mocking for opacity: Like most of them, Americans for a Better Tomorrow Tomorrow has changed its filing schedule with the FEC to delay disclosing donors as long as possible. 

The South Carolina ads are the first official "independent expenditures" in the presidential campaign for the super PAC, says Matthew Sanderson, a lawyer who works with Potter. As yet unknown: how much the PAC spent on an earlier ad campaign in Iowa that featured photos of Rick Perry, and urged write-in votes at the Iowa straw poll for Rick "Parry." Sanderson said those expenditures did not have to be reported to the FEC because the straw poll was an unofficial ballot and Perry had not yet officially entered the race at the timer.

(Updated Jan. 19 at 3:22 ET: This post has been updated to add comments and information from the PAC's legal team)