He reported $147,124, bringing his total raised to just under $1.73 million. That's over a million less than John Liu, who has raised $2.9 million over the course of his campaign but just $4,025 in the last period, which stretched from July 10 to August 12.

A full chart of the latest filings, from the CFB, is above.

“The issue as to what constitutes improper coordination, and thus, whether expenditures by third parties are deemed contributions to and expenditures by a campaign, has been raised and litigated in prior election cycles” but “there nevertheless remains ambiguity as to how the Board analyzes this issue,” says attorney Jerry Goldfeder in the July 7 letter to the board.

The current law “relies upon vague terms such as ‘connected to the candidate’ and ‘relationship … with the candidate,’” Goldfeder writes.

Examples that the C.F.B. cites to define these terms “are relevant for only the most egregiously improper conduct. We are, therefore, still left with an unclear presentation of what the law is and how it will be applied.”

Goldfeder says in the letter that clarification will be “useful for my client’s campaign” and for others running this year.

It’s looks like (indirect) acknowledgment that the Green campaign expects one of its rivals, Bill de Blasio, to benefit disproportionately from his supporters in the labor community, of which he has many.

“Because Mr. Bloomberg is not a candidate in the same primary election as Mr.

Thompson and his campaign have argued they should qualify for the enhanced matching funds and unlimited spending because Thompson is all-but-certain to be the Democrat to will face Bloomberg in November.

Bloomberg has said he will spend unlimited amounts of his own money on his campaign.

In the opinion, the C.F.B. wrote:

“Because Mr. Bloomberg is not a candidate in the same primary election as Mr. Thompson and the other Program participants who are seeking the Democratic Party nomination, his campaign spending prior to the primary election date does not trigger the bonus provisions for that election. Thus, there is no statutory basis for the Board to lift the primary election expenditure limit and provide Mr. Thompson and other participants with additional public matching funds for the primary election based on Mr. Bloomberg’s expenditures or contributions.”

Thompson aides have recently been speaking more openly about their desire to start raising money for the general election before the Democratic primary is over.

There is a cap on how much Thompson can spend in the primary – where he faces long-shot candidate Tony Avella. If he wins, which he likely will, he'll face self-funded candidate Michael Bloomberg in the general election--and he will have no spending cap then. 

"Obviously you can’t wait,” Thompson said when I asked him about this at his press conference just now.

“I think it creates an unfair advantage if you have to wait until after the September primary to start to raise funds for the general election.”

A spokesman for the Campaign Finance Board said mayoral candidates are not prohibited from raising money for the general election right now, but that the law, as it stands now, would not permit the spending cap to be lifted prematurely.

As I and other reporters have noted, if term limits are extended, a number of ouncil members running for higher office will wind up running for their old seats, for which the spending and contribution limits are lower.

The C.F.B. offered two solutions:

"Freeze" the current accounts and create a new campaign committee for the 2009 races. Money from those "frozen" committees can be transferred to the new accounts. Money spent running for higher office won't be counted toward the spending limit for the 2009 races. But the money transferred from that "frozen" account would mean less in matching funds in the future.

Or candidates can just keep their current campaign war chests, return any contributions that are over the limit and keep on running.

It seems, to me, like a win for incumbents, who spent and raised lavishly, and who now get the chance to use the huge sums of money they raised, basically, any way they want.

The real question now is how much more they'll need to spend on getting re-elected to their seats if they vote in favor of changing term limits.

Here are the C.F.B.'s proposals:

The Board’s advisory opinion will address the impact of campaign finance laws on two groups of candidates in the event term limits are extended.

GROUP 1: Previously term-limited candidates who anticipated running for a higher office but will decide to seek re-election to their current office in 2009

These candidates would have two options.

Option A: Start a brand new committee for 2009; “freeze” the old committee until 2013

Candidates could choose to open a new campaign committee for re-election to the candidate’s current office in 2009. These candidates must “freeze” their original 2009 committee for higher office until January 12, 2010. No activity beyond the costs of maintaining the account, like bank fees, would be allowed until January 12, 2010. (Note: with two exceptions—see discussion of transfers and durable goods below.)

The deadline for candidates to choose this option would be January 11, 2009—the end of the current disclosure period.

Contributions

· Candidates could accept contributions to the new 2009 committee up to the applicable limit, even if such contributor has already contributed to the “frozen” committee.

· Contributions that remain in the “frozen” committee could be matched with public funds for the 2013 election. The appropriate contribution limit for the 2013 election could be applied to contributions remaining in the candidate’s “frozen” committee.

Expenditures

· Campaign spending made prior to the date of the advisory opinion would not count against the candidate’s spending limit for the 2009 election. Nor would old spending be counted against the spending limit for the 2013 election, except as described below.

· Any spending made between the date of the advisory opinion and the date the new committee is opened (no later than January 11, 2009) would be counted against the 2009 spending limit.

· A 15 percent fundraising allocation for spending (approximating the cost of raising those funds) would be made against the funds in the “frozen” committee as determined by cash-on-hand on January 11, 2009. This total would be counted against the candidate’s “out-year” spending limit for the 2013 election.

· If a candidate’s total spending is less than 15 percent of cash-on-hand, then only the lower total would apply.

· If the new 2009 committee uses durable goods, such as computer equipment or other office supplies, purchased by the “frozen” committee, the 2009 committee would report an in-kind contribution from the “frozen” committee, or reimburse the “frozen” committee for the cost of those goods by January 11, 2009.

Transfers

· The candidate may transfer funds from the “frozen” committee to the new 2009 committee, but as always, any transfer is presumed to consist entirely of matching claims. With the $6-to-$1 matching rate, a $100,000 transfer from a “frozen” 2013 committee to a new 2009 committee could reduce the amount of public funds available to the candidate in 2013 by $600,000.

· If candidates transfer funds from the “frozen” committee to the new campaign committee, 15 percent of the total transferred would be counted against the 2009 spending limit. (A transfer would reduce the fundraising allocation counted against the candidates’ 2013 spending limit by the same amount.)

· If a candidate chooses to transfer any of the money from the “frozen” committee to the new committee, contribution limits for the appropriate office must be observed. Any over-the-limit amounts can remain in the “frozen” committee. Transferred funds cannot be matched with public funds.

Option B: Maintain the same committee for 2009

Candidates could also choose to keep their current committee and run for re-election to their current office instead of running for higher office.

Contributions

· The campaign must abide by the contribution limit for the office he or she seeks in 2009. (See the CFB website for contribution limits by office.) For any contributions that exceed the applicable limit, the over-the-limit portion must be returned to the contributor.

· Contributions returned by the candidate on his or her own would not be subject to findings of violation by the Board.

· Assuming the candidate meets the qualifications, eligible contributions remaining in the committee would be matched with public funds for the 2009 election.

Expenditures

· Spending made before the date of the advisory opinion would not be counted against the candidate’s spending limit for the 2009 election.

· A 15 percent fundraising allocation for spending (i.e. the cost of raising those funds) would be made against the candidate’s cash on hand as of January 11, 2009, less the amount of refunded over-the-limit contributions. This total would be counted against the candidate’s spending limit for the 2009 election.

· If a candidate’s total spending is less than 15 percent of cash-on-hand, then only the lower total would apply.

Eligibility

In order to take advantage of one of these two options, candidates must show they were seeking a higher office. If they have not declared an office to the CFB, they could show other materials, such as a solicitation for contributions as large as $4,950 (or $3,850 for borough president), or previous public statements of the intention to run for higher office.

GROUP 2: Candidates who choose not to run in 2009, but may plan to seek office in 2013

Maintain the same committee for 2013

These candidates may choose to use their existing committee for the 2013 election. (Note: This guidance assumes the candidate does not use their 2009 committee to run for office in an intervening election, e.g., if they run for state office in 2010.)

Contributions

· All contributions for a 2013 campaign would be subject to the 2013 contribution limits.

· Contributions to the committee would be eligible for public matching funds for a 2013 election.

Expenditures

· Spending made for the aborted 2009 election would not count towards the 2013 spending limit. Only spending from January 12, 2010 onwards would count towards the limit for the 2013 election.

· A 15 percent fundraising allocation for spending (i.e. the cost of raising those funds) would be made against the candidate’s cash on hand as of January 11, 2010. This total would be counted against the candidate’s out-year spending limit for the 2013 election.

· If a candidate’s total spending is less than 15 percent of cash-on-hand, then only the lower total would apply.

The Board will not issue a formal advisory opinion unless and until legislation affecting term limits is enacted. Until that time, the Board welcomes written comments from all interested parties. Comments should be submitted via email to info@nyccfb.info, or via mail to Sue Ellen Dodell, General Counsel, New York City Campaign Finance Board, 40 Rector Street, 7th Floor, New York, NY 10006.

As I and other reporters have noted, if term limits are extended, a number of ouncil members running for higher office will wind up running for their old seats, for which the spending and contribution limits are lower.

The C.F.B. offered two solutions:

"Freeze" the current accounts and create a new campaign committee for the 2009 races. Money from those "frozen" committees can be transferred to the new accounts. Money spent running for higher office won't be counted toward the spending limit for the 2009 races. But the money transferred from that "frozen" account would mean less in matching funds in the future.

Or candidates can just keep their current campaign war chests, return any contributions that are over the limit and keep on running.

It seems, to me, like a win for incumbents, who spent and raised lavishly, and who now get the chance to use the huge sums of money they raised, basically, any way they want.

The real question now is how much more they'll need to spend on getting re-elected to their seats if they vote in favor of changing term limits.

Here are the C.F.B.'s proposals: