Full opinion text
ORDER ROBERT W. PRATT, Chief Judge. On September 7, 2010, Iowa Right to Life Committee, Inc. (“IRTL”) filed a “Verified Complaint for Declaratory and Injunctive Relief’ against the above-captioned government officials (collectively, “Defendants”), alleging that several provisions of Iowa’s campaign finance laws violate the First and Fourteenth Amendments of the United States Constitution. Clerk’s No. 1. On the same date, IRTL also filed a Motion for Preliminary Injunction, which is currently before the Court. Defendants filed their responses in opposition to IRTL’s motion for a preliminary injunction on September 14, 2010. Clerk’s Nos. 20, 22. The Court held a hearing on the motion on September 15, 2010. See Clerk’s No. 23. The matter is fully submitted. I. FACTUAL BACKGROUND A. Recent Changes to Iowa Law 1. Pre-existing Iowa law. Prior to January 2010, the Iowa Code banned corporations from making both independent expenditures and campaign contributions. It provided that: Except as provided in subsections 3 and 4, it is unlawful for an insurance company, savings and loan association, bank, credit union, or corporation organized pursuant to the laws of this state, the United States, or any other state, territory, or foreign country, whether for profit or not, or an officer, agent, or representative acting for such insurance company, savings and loan association, bank, credit union, or corporation, to contribute any money, property, labor, or thing of value, directly or indirectly, to a committee, or to expressly advocate that the vote of an elector be used to nominate, elect, or defeat a candidate for public office, except that such resources may be so expended in connection with a utility franchise election held pursuant to section 364.2, subsection 4, or a ballot issue. All such expenditures are subject to the disclosure requirements of this chapter. Iowa Code § 68A.503(1) (2009). However, while corporations were banned from using their own general treasury funds to make independent expenditures and contributions directly, they were allowed to do these things indirectly through political committees. See id. § 68A.503(3) (allowing corporations to engage in election-related activities by sponsoring and financing their own “committees”); § 68A.102(8) (defining “committee” to “include[] a political committee and a candidate’s committee”). A “political committee” was defined, in relevant part, as: An association, lodge, society, cooperative, union, fraternity, sorority, educational institution, civic organization, labor organization, religious organization, or professional organization that ... makes expenditures in excess of seven hundred fifty dollars in the aggregate ... in any one calendar year to expressly advocate the nomination, election, or defeat of a candidate for public office .... Id. § 68A.102(18)(b). If an organization “was originally organized for purposes other than engaging in election activities,” but temporarily engaged in activities covered by § 68A.102(18), that organization was deemed a “permanent organization” and required to organize a political committee. Id. § 402(9). Both political committees and permanent organizations were required to segregate their election-related funds. See id.; id. § 68A.203(2)(d). In addition to these provisions, § 68A.404(3) required disclosure from any “person, other than a committee registered under this chapter” who made independent expenditures. The statute defined an independent expenditure as “one or more expenditures in excess of one hundred dollars in the aggregate for a communication that expressly advocates the nomination, election, or defeat of a clearly identified candidate ... without the prior approval or coordination with a candidate [or] candidate’s committee.” Id. § 68A.404(1). The statute expressly distinguished between persons covered by § 68A.404(3) and political committees. See id. § 68A.404(3)(b) (“This section does not apply to ... a political committee.”) (emphasis added). 2. The Supreme Court’s Opinion in Citizen’s United. In January 2010, the United States Supreme Court issued its opinion in Citizens United v. Federal Election Commission. See — U.S.-, 130 S.Ct. 876, 886, 175 L.Ed.2d 753 (2010). The federal statute at issue in Citizens United barred corporations “from using general treasury funds to make direct contributions to candidates or independent expenditures that expressly advocate the election or defeat of a candidate” in certain federal elections. Id. at 887 (citing 2 U.S.C. § 441b). The statute, however, allowed corporations to establish “a ‘separate segregated fund’Cknown as a political action committee, or PAC) for these purposes.” Id. Although § 441b applied to contributions and independent expenditures, the Supreme Court limited its discussion to independent expenditures. See id. at 909 (“Citizens United has not made direct contributions to candidates, and it has not suggested that the Court should reconsider whether contribution limits should be subjected to rigorous First Amendment scrutiny.”). The Supreme Court stated that, as it pertained to independent expenditures, § 441b was a ban on corporate speech. Id. at 897. The Court reasoned that a PAC is a separate entity from the corporation itself; therefore, even though the statute allowed PACs to speak, it still did not allow the corporations themselves to speak. Id. Because the statute was a ban on speech, the Supreme Court analyzed it under strict scrutiny. Id. at 888. A previous Supreme Court case, Austin v. Michigan Chamber of Commerce, had upheld restrictions based on the fact that a speaker was a corporation. See id. at 903 (citing Austin v. Mich. Chamber of Commerce, 494 U.S. 652, 695, 110 S.Ct. 1391, 108 L.Ed.2d 652 (1990)). But in Citizens United, the Supreme Court overruled that portion of Austin and concluded that “the Government may not suppress political speech on the basis of the speaker’s corporate identity” because “[n]o sufficient governmental interest justifies” banning speech on that basis. See id. at 913. Accordingly, the Court held that the federal ban on corporate independent expenditures was invalid. Id. Notably, although the Supreme Court struck down the federal ban on independent expenditures, it upheld federal disclosure and disclaimer requirements for independent expenditures. Id. at 913-14. The Supreme Court stated that “the public has an interest in knowing who is speaking about a candidate shortly before an election,” and concluded that this informational interest alone was sufficient to justify the federal disclosure requirements. Id. at 915-16. The Supreme Court also touted the benefits of prompt disclosures: With the advent of the Internet, prompt disclosure of expenditures can provide shareholders and citizens with the information needed to hold corporations and elected officials accountable for their positions and supporters. Shareholders can determine whether their corporation’s political speech advances the corporation’s interest in making profits, and citizens can see whether elected officials are in the pocket of so-called moneyed interests. The First Amendment protects political speech; and disclosure permits citizens and shareholders to react to the speech of corporate entities in a proper way. This transparency enables the electorate to make informed decisions and give proper weight to different speakers and messages. Id. at 916 (internal quotation marks and citations omitted). Therefore, under Citizens United, “[t]he Government may regulate corporate political speech through disclaimer and disclosure requirements, but it may not suppress that speech altogether.” Id. at 886. 3. Iowa’s response. a. Amendments to the Iowa Code. In response to Citizens United, the Iowa Legislature passed several amendments to Iowa’s campaign-finance laws. Defs.’ Resp. to PL’s Mot. for Prelim. Inj. (hereinafter “Defs.’ Br.”) at 3 (Clerk’s No. 20); Smithson Aff. ¶ 5 (Clerk’s No. 20-1); Prelim. Inj. Hr’g Tr. (hereinafter “Hr’g Tr.”) 37:3-7 (Clerk’s No. 35); Senate File 2354, 83rd G.A., 2d. Sess., as reprinted in 2010 Iowa Legis. Serv. S.F. 2354 (West) (hereinafter “S.F. 2354”). Most significantly, the Iowa Legislature deleted the text of § 68A.503 in its entirety and replaced it with new language, eliminating the ban on corporate independent expenditures and narrowing the scope of banned contributions. See S.F. 2354 § 5. The new text of § 68A.503 also exempted the use of corporate “funds for independent expenditures as provided in section 68A.404.” Iowa Code § 68A.503(4)(d). The Iowa Legislature made other notable changes. It amended the definition of an “independent expenditure” to change the threshold from one hundred dollars to seven hundred fifty dollars. S.F. 2354 § 3 (amending Iowa Code § 68A.404(1)). The Iowa Legislature also added a requirement that organizations “other than an individual or individuals” obtain approval by “a majority of the entity’s board of directors, executive council, or similar organizational leadership body” before using general treasury funds for independent expenditures. See id. (amending Iowa Code § 68A.404(2)(a)-(b)). Finally, the Iowa Legislature also made a number of chailges related to independent expenditure reporting, including a requirement that persons covered by § 68A.404(3) file a “termination report” if they decide to stop making independent expenditures. See id. §§ 2-3. All of these amendments became effective on April 8, 2010. Id. § 7. In particular, the Iowa Legislature did not make any changes to § 68A.102. See id. §§ 1-7. Section 68A.102 provides definitions to be used in Chapter 68A “unless the context otherwise requires.” Iowa Code § 68A.102. Therefore, the definitions of “political committee” and “permanent organization” remain the same. See S.F. 2354 §§ 1-7. The Iowa Legislature also did not change the portions of § 68A.404(3) that limited that section’s applicability to any “person, other than a committee registered under this chapter” or that expressly excluded political committees from its scope. See id. § 3. Therefore, it is still clear, from the plain text of the statute, that the persons covered by § 68A.404(3) are a separate category from committees, including political committees. See Iowa Code §§ 68A.404, 404(3). However, by removing the ban on corporate independent expenditures and not amending the definitions, the Iowa Legislature unearthed some previously latent ambiguity as to the proper interplay between § 68A.404(3) and § 68A.102(18). See S.F. 2354 § 5 (striking the former version of § 68A.503 in its entirety). That ambiguity stems from the overlap between the scope of § 68A.404(3) and the definition of a “political committee” in § 68A.102(18). If an organization has not yet “registered as a committee,” but makes an independent expenditure totaling more than $750.00, it would fall under the plain text of both sections. See Iowa Code §§ 68A.404(3), 68A.102(18). But, based on the plain text of § 68A.404, it cannot be both a political committee and also “a person, other than a committee.” See Iowa Code § 68A.404(3), (3)(b). Prior to the April 2010 amendments, this tension was ameliorated by § 68A.503, at least as to corporations. Because the former text of § 68A.503 barred corporations from making independent expenditures, they could not lawfully take actions within the scope of § 68A.404(3)(b) without forming a political committee. See Iowa Code § 68A.503(l)-(3) (2009). Therefore, under the pre-April 2010 statute, the choice between these two definitions was simple — • corporations had to be covered by § 68A.102(18), not § 68A.404(3). The current text of the statute, however, does not clarify how these two sections should be applied when an organization arguably falls under both definitions. b. Amendments to the Iowa Administrative Code rules. In addition to amending the text of the statute, the Iowa Legislature authorized the Iowa Ethics & Campaign Disclosure Board (the “Board”) to promulgate emergency rules to implement the new provisions in time for the June 2010 primary. S.F. 2354 § 6. Accordingly, the Board made a number of changes to the existing rules, and added a number of new provisions, effective May 17, 2010. Vol. XXXII Iowa Admin. Bulletin, No. 25 (hereinafter “LAB”) at 2706-14, June 6, 2010; see also Smithson Aff. ¶ 6; Defs.’ Br. at 3. Two of these changes are particularly relevant to the instant case. First, the Board created a new category of regulated entities called “independent expenditure committees.” IAB at 2707, Item 1 (adding “new paragraph 4.1(l)‘d’ ”). Although the Board decided to call this new category of entities “independent expenditure committees,” it did not make them a subset of “committees.” See Iowa Admin. Code r. 351 — 4.1(1). Instead, the Board amended the rules to create three separate categories of regulated entities, each subject to different reporting requirements, specifically: (1) “committees” (including “political committees,” also known as “PACs”); (2) “permanent organizations temporarily engaging in political activity”; and (3) “independent expenditure committees.” Id.; see also id. r. 351-4.27(68A) (distinguishing between the reporting required of “independent expenditure committees” and “committees”). The Board defined an “independent expenditure committee” as an organization that is required to file an independent expenditure statement under § 68A.404(3). See id. r. 351 — 4.1(l)(d) (“A person that is required to file campaign disclosure reports pursuant to 2009 Iowa Code Supplement section 68A.404(3) ‘a’ as amended by 2010 Iowa Acts, Senate File 2354, section 3, due to the filing of an independent expenditure statement (Form Ind-Exp-O) shall be referred to as an ‘independent expenditure committee.’ ”); see also id. at 2708, Item 7 (amending rule 351-4.27(68A) to provide that organizations making independent expenditures must file Form Ind-Exp-O, while individuals making independent expenditures must file Form Ind-Exp-I). Strikingly, the term “independent expenditure committee” does not appear in the statute. See Iowa Code §§ 68A.404, 68A.102. However, the Court adopts the Board’s definition of an independent expenditure committee for the purposes of this opinion. Second, the Board made changes to its substantive rules regarding the reporting of independent expenditures. For example, the Board created a separate set of reporting requirements for independent expenditure committees. IAB at 2707, Item 3 (adding “new subrule 4.9(15)”). The Board also amended its rule regarding dissolution to state that independent expenditure committees are not required to file final bank statements when they file termination reports. See id. at 2713, Item 22 (amending rule 351-4.55(5)). B. The Parties and This Lawsuit IRTL is a “non-stock, nonprofit Iowa corporation” that is classified as a social welfare organization under 26 U.S.C. § 501(c)(4). Compl. ¶¶ 6, 15. IRTL is the Iowa affiliate of the National Right to Life Committee, Inc. Id. ¶ 14. According to IRTL, its “primary purpose” is “to present factual information” on various social issues, including abortion and euthanasia and “its major purpose is not and will never be the nomination or election of candidates.” Id. ¶¶ 14-15. Defendants are various governmental officers who have the power to enforce the challenged provisions of Iowa’s campaign-finance laws. See id. ¶¶ 8-10. At some point in August, “an attorney from the office of IRTL’s lead counsel contacted [the Board’s] Legal Counsel, Charles Smithson, regarding the issue of ongoing reporting” Compl. at 14 n. 12; Smithson Aff. ¶ 7. But IRTL’s counsel did not mention IRTL in that call. Smithson Aff. ¶ 7. And IRTL has not sought a formal advisory opinion from the Board. Id. IRTL alleges that, prior to October 14, 2010, it wants to: (1) “make a single independent expenditure totaling more than $750, to support the election of Brenna Findley, candidate for Attorney General,” specifically, IRTL wants to create a “mailer expressing support of Ms. Findley’s pro-life beliefs” to be “sent to IRTL’s general mailing list”; and (2) make a $100 contribution to Ms. Findley. Compl. ¶¶ 16, 19. IRTL also alleges that it plans to engage in unspecified, but “materially similar” activities in the future. Pl.’s Br. in Supp. of Mot. for Prelim. Inj. (hereinafter “PL’s Br.”) at 2 (Clerk’s No. 2-1); see also Compl. ¶ 20. IRTL argues that it is “chilled from doing [these things] due to the burdens imposed by the restrictions challenged here and the potential civil and criminal penalties for violating the challenged provisions.” PL’s Br. at 1. II. LAW AND ANALYSIS IRTL requests that the Court issue a preliminary injunction enjoining the Defendants from enforcing several provisions of Iowa election law against IRTL. Mot. at 1-2 (Clerk’s No. 2); PL’s Br. at 2, 31. This Court believes that the power to grant a preliminary injunction is an awesome power vested in the district court, recognizing that it is an extraordinary form of relief and must be carefully considered. See Calvin Klein Cosmetics, Corp. v. Parfums de Coeur, Ltd., 824 F.2d 665, 667 (8th Cir.1987). The test for a preliminary injunction involves consideration of four factors: (1) the probability that the movant will succeed on the merits; (2) the threat of irreparable harm to the movant; (3) the state of the balance between this harm and the injury that granting the injunction will inflict on other parties and litigants; and (4) the public interest. Dataphase Sys., Inc. v. C L Sys., Inc., 640 F.2d 109, 113 (8th Cir.1981) (en banc). IRTL has the burden of showing that a preliminary injunction should be granted. See Baker Elec. Coop., Inc. v. Chaske, 28 F.3d 1466, 1472 (8th Cir.1994) (citing Modem Computer Sys., Inc. v. Modem Banking Sys., Inc., 871 F.2d 734, 737 (8th Cir.1989) (en banc)). However, as to the merits, “the burdens at the preliminary injunction stage track the burdens at trial.” Gonzales v. O Centro Espirita Beneficente Uniao Do Vegetal, 546 U.S. 418, 419, 126 S.Ct. 1211, 163 L.Ed.2d 1017 (2006). The Court will consider each of the Dataphase factors in turn. A. Probability of Success on the Merits The first factor the Court must consider in deciding whether to issue a preliminary injunction is the likelihood that Plaintiff will succeed on the merits. Because IRTL seeks a preliminary injunction against the enforcement of a state statute, it must “demonstrate more than just a ‘fair chance’ that it will succeed on the merits.” See Planned Parenthood Minn. v. Rounds, 530 F.3d 724, 731-32 (8th Cir.2008) (en banc). Instead, IRTL must meet a more rigorous standard, demonstrating that it is “likely to prevail on the merits.” Id. at 732 (quoting Doran v. Salem Inn, Inc., 422 U.S. 922, 931, 95 S.Ct. 2561, 45 L.Ed.2d 648 (1975)). This more “rigorous standard ‘reflects the idea that governmental policies implemented through legislation or regulations developed through presumptively reasoned democratic processes are entitled to a higher degree of deference and should not be enjoined lightly.’ ” Id. (quoting Able v. United States, 44 F.3d 128, 131 (2d Cir. 1995)). “If the party with the burden of proof makes a threshold showing that it is likely to prevail on the merits, the district court should then proceed to weigh the other Dataphase factors.” Id. The Eighth Circuit has stated that “[b]y re-emphasizing this more rigorous standard for demonstrating a likelihood of success on the merits in these cases, we hope to ensure that prehminary injunctions that thwart a state’s presumptively reasonable democratic processes are pronounced only after an appropriately deferential analysis.” Id. at 733. 1. Standing. “Article III of the Constitution limits federal jurisdiction to cases and controversies, and the ‘core component of standing is an essential and unchanging part of the case-or-controversy requirement.’ ” Advantage Media, L.L.C. v. City of Eden Prairie, 456 F.3d 793, 799 (8th Cir.2006) (quoting Lujan v. Defenders of Wildlife, 504 U.S. 555, 560, 112 S.Ct. 2130, 119 L.Ed.2d 351 (1992)). Therefore, “[a] federal court bears the burden of examining standing at all stages of litigation, even if the parties do not raise the issue themselves.” Harmon v. City of Kansas City, 197 F.3d 321, 327 (8th Cir.1999). In order to prove standing, a plaintiff must demonstrate: (1) an actual injury that is concrete and particularized and not conjectural or hypothetical; (2) a causal connection between the injury and the defendant’s conduct; and (3) a likelihood, and not a mere speculative possibility, that the plaintiffs injury will be redressed by a favorable decision. Nat’l Right to Life Political Action Comm. v. Connor, 323 F.3d 684, 689 (8th Cir.2003) (citing Lujan, 504 U.S. at 560-61, 112 S.Ct. 2130). “[Standing cannot be inferred argumentatively from averments in the pleadings, but rather must affirmatively appear in the record.” FW/PBS, Inc. v. City of Dallas, 493 U.S. 215, 231, 110 S.Ct. 596, 107 L.Ed.2d 603 (1990) (internal citation marks and quotation omitted), overruled on other grounds by City of Littleton v. Z.J. Gifts D-4, L.L.C., 541 U.S. 774, 124 S.Ct. 2219, 159 L.Ed.2d 84 (2004). [I]n the First Amendment context, even though Plaintiffs are not required to await and undergo a criminal prosecution, they must face a credible threat of present or future prosecution under the statute for a claimed chilling effect to confer standing to challenge the constitutionality of a statute that both provides for criminal penalties and abridges First Amendment rights. Zanders v. Swanson, 573 F.3d 591, 593 (8th Cir.2009). Therefore, in order to demonstrate standing to challenge a particular provision of Iowa law, IRTL must “allege[ ] an actual and well-founded fear that the law will be enforced against” it. See Virginia v. Am. Booksellers Ass’n, 484 U.S. 383, 393, 108 S.Ct. 636, 98 L.Ed.2d 782 (1988); see also Wis. Right to Life, Inc. v. Paradise, 138 F.3d 1183, 1185 (7th Cir.1998) (“We may assume that WRTL has genuine apprehension about what lies ahead. But is its concern objectively ‘well-founded’? If not, Article III of the Constitution precludes a federal court from ruling.”). IRTL has alleged four counts in its complaint. A number of IRTL’s claims raise standing concerns. The Court will consider each count in turn. a.Count 1: Iowa’s definitions of “political committee” and “permanent organization.” In Count 1 of its complaint, IRTL challenges Iowa Code §§ 68A.102(18) and 68A.402(9), which define “political committee,” and “permanent organization,” respectively. Compl. ¶23. IRTL also asks the Court to enjoin enforcement of these sections in the instant motion. Mot. at 1. IRTL’s main contention is that if IRTL makes $750.00 in independent expenditures, it will be “defined by statute as a political committee.” Compl. ¶ 18 (citing Iowa Code § 68A.102(18)); see also Pl.’s Br. at 6. Under § 68A.102(18), “Political committee” means any of the following: a. A committee, but not a candidate’s committee, that accepts contributions in excess of seven hundred fifty dollars in the aggregate, makes expenditures in excess of seven hundred fifty dollars in the aggregate, or incurs indebtedness in excess of seven hundred fifty dollars in the aggregate in any one calendar year to expressly advocate the nomination, election, or defeat of a candidate for public office, or to expressly advocate the passage or defeat of a ballot issue. b. An association, lodge, society, cooperative, union, fraternity, sorority, educational institution, civic organization, labor organization, religious organization, or professional organization that accepts contributions in excess of seven hundred fifty dollars in the aggregate, makes expenditures in excess of seven hundred fifty dollars in the aggregate, or incurs indebtedness in excess of seven hundred fifty dollars in the aggregate in any one calendar year to expressly advocate the nomination, election, or defeat of a candidate for public office, or to expressly advocate the passage or defeat of a ballot issue. c. A person, other than an individual, that accepts contributions in excess of seven hundred fifty dollars in the aggregate, makes expenditures in excess of seven hundred fifty dollars in the aggregate, or incurs indebtedness in excess of seven hundred fifty dollars in the aggregate in any one calendar year to expressly advocate that an individual should or should not seek election to a public office prior to the individual becoming a candidate as defined in section 68A.102, subsection 4. Iowa Code § 68A.102(18). Even if IRTL is correct that it falls under this definition, IRTL cannot be covered by § 68A.102(18) unless Iowa interprets it in an unconstitutional manner. In Citizens United, the Supreme Court held that a federal ban on corporate independent expenditures was unconstitutional. 130 S.Ct. at 913. The federal statute at issue in Citizens United allowed corporations to set up a “separate segregated fund” to make independent expenditures. Id. at 887-88 (citing 2 U.S.C. § 441b(b)(2)). The Supreme Court held that this was unconstitutional because the PAC option did not allow corporations to speak for themselves. Id. at 897. Thus, under Citizens United, Iowa may not constitutionally require corporations to use segregated funds in order to make independent expenditures. See id. Under Iowa law, both political committees and permanent organization must keep their election-related funds segregated from their general treasury funds. Iowa Code §§ 68A.203(2)(d); 68A.402(9). Therefore, in light of Citizens United, Iowa may not interpret § 68A.102(18) or § 68A.402(9) to include corporations that make only independent expenditures without running afoul of the Constitution. Thus, IRTL would only be covered by these provisions if Iowa interpreted them in a manner prohibited by Citizens United. There is no indication in the record, however, that Iowa “intends to interpret its own [statute] in contradiction to this established law.” See W. Tradition P’ship v. City of Longmont, No. 09-cv-2303, 2009 WL 3418220, at *7 (D.Colo. Oct. 21, 2009). And “there is nothing on the face of the statute to prevent it from being construed and enforced in a constitutional manner.” Cf. Nat’l Right to Life Political Action Comm. v. Lamb, 202 F.Supp.2d 995, 1012 (W.D.Mo.2002), affd sub nom. Nat’l Right to Life Political Action Comm. v. Connor, 323 F.3d 684 (8th Cir.2003) (finding that a challenged statute was amenable to a narrowing construction). To the contrary, all of the evidence currently before the Court indicates that Iowa already interprets these provisions to exclude corporations that make only independent expenditures. See, e.g., Advisory Op. 2010-03 (Clerk’s No. 20-1 at 13) (“[A]n independent expenditure committee will not be subject to the same registration and reporting requirements as a PAC.”); id. at 12 (stating that “corporations may make independent expenditures so long as the disclosure provisions of Iowa Code section 68A.404 [which govern independent expenditure committees] are followed”); see also Iowa Admin. Code r. 351^.1(1) (providing different rules for independent expenditure committees, permanent organizations and political committees). Indeed, Defendants insist that IRTL will not be considered a political committee if it makes its intended expenditure. See Hr’g Tr. 28:8-16 (arguing that this is “clear from ... a plain reading of the statute” that IRTL will be an independent expenditure committee, not a political committee); see also id. 26:5-6 (“If you want to make an independent expenditure, you don’t have to be a PAC.... ”); Smithson Aff. ¶ 9 (“The Board has created Form Ind-Exp-0 for organizations such as IRTL that make independent expenditures.”); Defs.’ Br. at 4 n. 1 (indicating that IRTL would be considered an independent expenditure committee) id. at 4 n. 2 (same). And, at the hearing, IRTL’s counsel conceded that “[t]he State in its [advisory opinion] has said that [IRTL] will not be subject to the same types of restrictions that a political committee will be subject to.... ” Hr’g Tr. 9:1-3. The Court finds, therefore, that it is more likely than not that Iowa will apply §§ 68A.102(18) and 68A.404(9) in a manner that is consistent with Citizens United. Accordingly, IRTL has failed to show that there is a credible threat that Iowa will interpret these provisions as applying to IRTL’s intended activities or threaten to enforce them against IRTL. See Lamb, 202 F.Supp.2d at 1010. The Court also finds that IRTL’s alleged fears that those provisions will be enforced against IRTL are not objectively well-founded in light of the statute, regulations, and the evidence in the record. IRTL offers two arguments in support of the proposition that its speech has been chilled, one based on the statutory text and one based on the Board’s application of that text. See Pl.’s Br. at 6. First, IRTL argues that, no matter how the relevant officials interpret the statute, IRTL is still a political committee under the plain text of the statute. Hr’g Tr. 9:1-7; see also Pl.’s Br. at 6; Compl. ¶ 18. As discussed above, there is some ambiguity in the statute on this point. Thus, this is not a case where the challenged provisions clearly target the plaintiffs activities, creating a clear threat of enforcement. Cf. Ark. Right to Life State Political Action Comm. v. Butler, 146 F.Bd 558, 560 (8th Cir.1998) (affirming a determination that the plaintiffs had standing where they were clearly “a target or object of the prohibitions” in the challenged provision). And, to the extent that IRTL is arguing that the relevant officials might change their interpretation of the statute, this Court declines to offer an advisory opinion. Second, IRTL argues that the Board uses a “vague we-know-it-when-we-see-it approach” to determine whether an organization qualifies as a political committee. See Pl.’s Br. at 6. However, the only support IRTL cites for this assertion is Advisory Opinion 2010-03. Id. That advisory opinion does not state — or even suggest — a “vague we-know-it-when-we-see-it approach.” See Advisory Op. 2010-03. To the contrary, that opinion clearly indicates that organizations that spend more than $750.00 on express advocacy are subject to disclosure requirements, but those requirements vary depending on an organization’s exact activities. See id.; see also Iowa Admin. Code r. 351^4.1(1). Because IRTL’s reading of this opinion is patently unreasonable, the Court finds that IRTL’s citation to it does not demonstrate that there is a credible risk that the Board will use a “vague we-know-it-when-we-see-it approach” to determine whether IRTL qualifies as a political committee. For all of these reasons, the Court concludes that IRTL has not demonstrated that it has standing to challenge Iowa Code § 68A.102(18) or § 68A.402(9). Therefore, on the current record, IRTL is not likely to succeed on the merits of its constitutional challenges to these provisions. b.Count 2: Iowa’s requirements for independent expenditure committees. In Count 2 of its complaint, IRTL challenges Iowa Code §§ 68A.402B(3), 68A.404(3), 68A.404(4), Iowa Administrative Code Rule 351-4.9(15), Form Ind-Exp-0 and Board Form DR-3. Compl. ¶ 30. IRTL also asks the Court to preliminarily enjoin enforcement of these provisions. Mot. at 1. All of these provisions apply to persons required to file independent expenditure statements under § 68A.404, i.e., any “person, other than a committee registered under this chapter, that makes one or more independent expenditures.” See Iowa Code § 68A.404(3). IRTL is not currently registered as a committee. See Compl. ¶ 18. And it alleges that it intends to make one or more independent expenditures. Id. ¶ 16. Therefore, IRTL’s intended activities fall under the plain text of § 68A.404(3). Defendants do not dispute that those provisions apply to IRTL. See Defs.’ Br. at 4-5, 73; Smithson Aff. ¶ 9. The Court concludes that IRTL has standing to challenge these provisions. c. Count 3: Iowa’s ban on corporate campaign contributions. IRTL also asks this Court to enjoin enforcement of Iowa Code § 68A.503. Mot. at 1. As amended in April 2010, § 68A.503 provides that, subject to some exceptions, “an insurance company, savings and loan association, bank, credit union, or corporation shall not make a monetary or in-kind contribution to a candidate or committee except for a ballot issue committee.” Iowa Code § 68A.503(1). Section 68A.503 clearly targets IRTL’s intended conduct — making a campaign contribution. Compl. ¶ 19. Defendants do not dispute that this ban applies to IRTL. See generally Defs.’ Br. at 13-15; Smithson Aff. ¶ 15. Therefore, IRTL has standing to challenge § 68A.503. d. Count I: Iowa’s requirement of board for equivalent) approval. In Count 4 of its complaint, IRTL challenges Iowa Code §§ 68A.404(2)(a)-(b), 68A.404(5)(g), and Form Ind-Exp-O. Compl. ¶ 45. IRTL has asked the Court to enjoin these provisions. Mot. at 1-2. Section 68A.404(2) provides: a. An entity, other than an individual or individuals, shall not make an independent expenditure or disburse funds from its treasury to pay for, in whole or in part, an independent expenditure made by another person without the authorization of a majority of the entity’s board of directors, executive council, or similar organizational leadership body of the use of treasury funds for an independent expenditure involving a candidate or ballot issue committee. Such authorization must occur in the same calendar year in which the independent expenditure is incurred, b. Such authorization shall expressly provide whether the board of directors, executive council, or similar organizational leadership body authorizes one or more independent expenditures that expressly advocate the nomination or election of a candidate or passage of a ballot issue or authorizes one or more independent expenditures that expressly advocate the defeat of a candidate or ballot issue. Section 68A.404(5)(g) states that an independent expenditure statement must include, inter alia: A certification by an officer of the corporation that the board of directors, executive council, or similar organizational leadership body expressly authorized the independent expenditure or use of treasury funds for the independent expenditure by resolution or other affirmative action within the calendar year when the independent expenditure was incurred. IRTL also objects to the “Statement of Certification” on Form Ind-Exp-O, which states, in relevant part: I affirm that the independent expenditure reported above is accurate. I also affirm that this expenditure was made without the prior approval or in coordination with the benefiting committee. I understand that by filing this form, I am subject to the campaign laws in Iowa Code chapter 68A and administrative rules in chapter 351. I also understand that the failure to timely file this form leads to the imposition of civil penalties and the intentional failure to file the form may lead to additional civil and criminal sanctions. If this expenditure was made by a corporation that the board of directors, executive council, or similar organizational leadership body expressly authorized the expenditure by resolution or other affirmative action this year. See Form Ind-Exp-0 (Clerk’s No. 1-1). IRTL argues that these provisions are unconstitutional both “facially and as applied to IRTL,” in violation of the First and Fourteenth Amendments. Compl. ¶ 53. The Court will address whether IRTL has standing to make arguments under each of these Amendments in turn. i. First Amendment. “[W]hen a party brings a pre-enforcement challenge to a statute that both provides for criminal penalties and abridges First Amendment rights,’a credible threat of present or future prosecution itself works an injury that is sufficient to confer standing.’ ” Minn. Citizens Concerned for Life v. Fed. Election Comm’n, 113 F.3d 129, 131 (8th Cir.1997) (quoting N.H. Right to Life Political Action Comm. v. Gardner, 99 F.3d 8, 13 (1st Cir.1996)). The Iowa campaign-finance statute does provide for criminal penalties. See Iowa Code § 68A.701 (“Any person who willfully violates any provisions of this chapter shall upon conviction, be guilty of a serious misdemeanor.”). Therefore, IRTL “suffers Article III injury when it must either make significant changes to its operations to obey the regulation, or risk a criminal enforcement action by disobeying the regulation.” See Minn. Citizens Concerned for Life, 113 F.3d at 131. But IRTL has not alleged either of these things. First, IRTL has not alleged that it must make any changes to its current operating procedures, let alone any significant changes. See Compl. ¶¶ 44-53. IRTL alleges only that these requirements “burden[] IRTL’s ability to select the most effective means of advancing its cause.” Id. ¶ 51. At most, this allegation suggests that, at some point, IRTL might like to select some different “means” that are somehow more “effective” than what is required by the statute. Such speculative, hypothetical allegations are not sufficient to bestow standing. Likewise, IRTL’s suggestion that these provisions might burden the “inner workings and decision-making process of a citizen-group engaged in core political speech,” fails to state any concrete, particularized injury to IRTL. Id. Indeed, if IRTL’s board approved independent expenditures prior to the passage of S.F. 2354, then IRTL would not have to make any changes. If that is the case, then IRTL’s claim would also lack the requisite element of redressibility. See Advantage Media, 456 F.3d at 801; Wis. Right to Life, Inc., 138 F.3d at 1185. Second, IRTL has not alleged that it plans to make any expenditures without complying with the challenged provisions. See Compl. ¶¶ 44-53. Therefore, IRTL has not alleged that it will “risk criminal enforcement action by disobeying the regulation.” See Minn. Citizens Concerned for Life, 113 F.3d at 131; see also Babbitt v. United Farm Workers Nat’l Union, 442 U.S. 289, 298, 99 S.Ct. 2301, 60 L.Ed.2d 895 (1979) (stating that a claim is justiciable “[wjhen the plaintiff has alleged an intention to engage in a course of conduct arguably affected with a constitutional interest, but proscribed by a statute, and there exists a credible threat of prosecution thereunder.... ”). IRTL has not pled sufficient facts to allow the Court to conclude that it has suffered a First Amendment “injury in fact” caused by the challenged provisions. Therefore, IRTL has failed to demonstrate that it has standing to challenge these provisions based on the First Amendment. See Lamb, 202 F.Supp.2d at 1003. ii. Fourteenth Amendment. IRTL also alleges that the challenged provisions violate the Fourteenth Amendment. Compl. ¶ 52. In its brief, IRTL only argues that these provisions violate the Fourteenth Amendment because they violate the First Amendment. See Pl.’s Br. at 29-30 (“As demonstrated above in the First Amendment argument section, Iowa is unable to prove that the prior-board-approval requirement is narrowly tailored to a compelling state interest (or substantially related to any state interest). For the same reasons, the requirement fails strict (or lesser) scrutiny under equal protection.”). It is true that “[t]he Equal Protection Clause requires that statutes affecting First Amendment interests be narrowly tailored to their legitimate objectives.” Police Dep’t of City of Chicago v. Mosley, 408 U.S. 92, 101, 92 S.Ct. 2286, 33 L.Ed.2d 212 (1972). But Article Ill’s requirements “appl[y] with as much force in the equal protection context as in any other.” See United States v. Hays, 515 U.S. 737, 743, 115 S.Ct. 2431, 132 L.Ed.2d 635 (1995). As discussed above, IRTL has not alleged a First Amendment injury. Therefore, IRTL has not demonstrated that it has standing to bring a Fourteenth Amendment claim based only on a violation of the First Amendment. To the extent, however, that IRTL is stating a separate disparate treatment claim, the Court is satisfied that IRTL has standing. In its complaint, IRTL alleges that the challenged provisions “unconstitutionally burden[ ] the speech-related activities of corporations while not similarly regulating labor unions and other entities, such as LLCs and general partnerships, that are similarly situated.” Compl. ¶ 52. This is sufficient to demonstrate standing. See Russell v. Burris, 146 F.3d 563, 572 (8th Cir.1998) (rejecting an argument that certain PACs lacked standing because the challenged provisions burdened those PACs more than other PACs); Gray v. City of Valley Park, 567 F.3d 976, 984 (8th Cir.2009) (“It is customary that ‘the court must accept all factual allegations in the complaint as true and draw all inferences in the plaintiffs favor’ when making a determination on standing.”) (quoting Young Am. Corp. v. Affiliated Computer Servs. (ACS), Inc., 424 F.3d 840, 843 (8th Cir.2005)). Having concluded that IRTL has demonstrated that it has standing to maintain some of its claims, the Court proceeds to consider the merits of those remaining claims. 2. Iowa’s requirements for independent expenditure committees. IRTL argues that Iowa Code §§ 68.402B(3), 68A.404(3), 68A.404(4), Iowa Administrative Code rule 351-4.9(15), Form Ind-Exp-O, and Form DR-3 are all unconstitutional, both facially and as applied to IRTL. Pl.’s Br. at 11 — 12. These provisions create a number of obligations for groups that are classified as independent expenditure committees. IRTL does not seriously dispute that the government has valid interests in disclosure. See Hr’g Tr. 49:16-19 (“We are not asking you to take away disclosure, we think disclosure is good. We think disclaimers are important. We think that does serve the informational interest, and we think that is important to the public to know who is speaking.”). Rather, IRTL focuses its attack on the “fit” of Iowa’s regulations to those interests. In doing so, IRTL makes two categories of arguments — broad, generalized arguments that it apparently aims at all of the challenged provisions as well as specific arguments against particular provisions. The Court will address each of these groups of arguments in turn. a. Generalized arguments. IRTL makes two generalized arguments against all of the challenged provisions. However, the Court finds neither of these arguments to be persuasive. i. Least-restrictive means. IRTL’s main argument is that Iowa’s regulations are onerous because they are not the least-restrictive means for meeting the state’s interests. Hr’g Tr. 49:5-6; see also Pl.’s Br. at 8-9 (“In analyzing the constitutionality of Iowa’s scheme, it is important to compare it to the less-restrictive, independent-expenditure federal scheme.... ”). The least restrictive means test applies only to a strict scrutiny analysis. See N.C. Right to Life, Inc. v. Leake, 525 F.3d 274, 331 (4th Cir.2008) (Michael, J., dissenting); see also Nixon v. Shrink Mo. Gov’t PAC, 528 U.S. 377, 400, 120 S.Ct. 897, 145 L.Ed.2d 886 (2000) (Breyer, J., concurring) (noting that “least restrictive means” is a test associated with strict scrutiny review). IRTL argues that these requirements are subject to strict scrutiny because they are “PAC-style” requirements that “impose the kind of burdens imposed on PACs.” Id. at 8. The Court does not agree. Unlike the federal ban that was at issue in Citizens United, the requirements contested here “impose no ceiling on campaign-related activities and do not prevent anyone from speaking.” See Citizens United, 130 S.Ct. at 914 (quoting Buckley v. Valeo, 424 U.S. 1, 64, 96 S.Ct. 612, 46 L.Ed.2d 659 (1976) and McConnell v. Fed. Election Comm’n, 540 U.S. 93, 201, 124 S.Ct. 619, 157 L.Ed.2d 491 (2003)) (internal quotation marks omitted); see also Iowa Code §§ 68.402B(3), 68A.404(3), 68A.404(4); Iowa Administrative Code rule 351^4.9(15); Form Ind-Exp-O; Form DR-3. Therefore, although they “may burden the ability to speak,” they are not subject to strict scrutiny. Citizens United, 130 S.Ct. at 914. Instead, they are subject to exacting scrutiny. See id.; see also Doe v. Reed, — U.S. -, 130 S.Ct. 2811, 2818, 177 L.Ed.2d 493 (2010) (applying exacting scrutiny where the challenged provision was “not a prohibition on speech, but instead a disclosure requirement”); Speech-Now.org v. Fed. Election Comm’n, 599 F.3d 686, 691, 696 (D.C.Cir.2010) (en banc) (applying exacting scrutiny to federal “organizational, administrative, and continuous reporting requirements” for political committees). Under exacting scrutiny, Iowa is not required to employ the “least-restrictive means to meet a compelling government interest.” See Citizens United, 130 S.Ct. at 914 (requiring only a “substantial relation” to a “sufficiently important” interest). Therefore, even if less-burdensome alternatives do exist, that fact does not, contrary to IRTL’s contentions, render these provisions unconstitutional. ii. Major purpose “test ” IRTL argues that the challenged provisions “violate Buckley’s mandate that burdensome PAC-style regulations may be imposed only on’ organizations that are under the control of a candidate or the major purpose of which is the nomination or election of a candidate.” Pl.’s Br. at 11 (citing Buckley, 424 U.S. at 79, 96 S.Ct. 612). But the Court reads no such “mandate” in Buckley. In the portion of Buckley relied upon by IRTL, the Supreme Court considered federal disclosure requirements and specifically approved of such disclosures, as long as they were limited to “spending that is unambiguously related to the campaign of a particular federal candidate.” Buckley, 424 U.S. at 80, 96 S.Ct. 612. The Supreme Court reasoned that expenditures made by organizations that were “under the control of a candidate or the major purpose of which is the nomination or election of a candidate” were, “by definition, campaign related.” Id. at 79, 96 S.Ct. 612. Therefore, Congress could require such organizations to disclose all of their expenditures, i.e., they could be regulated as “political committees.” See id. For other organizations, however, Congress could only require disclosure of “spending that is unambiguously related to the campaign of a particular ... candidate.” Id. at 80, 96 S.Ct. 612. When limited in this way, the Supreme Court concluded that the disclosure requirements had “a sufficient relationship to a substantial governmental interest.” Id. Therefore, the Court concludes that “Buckley’s statement — that defining groups with ‘the major purpose’ of political advocacy as political committees is sufficient ‘to fulfill the purposes of the Act[ ]’— does not indicate that an entity must have that major purpose to be deemed constitutionally a political committee.” Human Life of Wash. Inc. v. Brumsickle, 624 F.3d 990, 1009-10 (9th Cir.2010) (internal citation omitted). Indeed, “Buckley ... only defined the outer limits of permissible political committee regulation” and “left room for legislative judgment within these limits, so long as the resulting regulation does not prohibit a substantial amount of non-electoral speech.” See Leake, 525 F.3d at 327 (Michael, J., dissenting). Because Buckley simply does not categorically “prohibit! ] the government from designating a group as a ‘political committee’ unless the group’s sole, primary purpose is political advocacy,” it also does not categorically prohibit Iowa from subjecting entities to disclosure requirements simply because those requirements may be characterized as “PAC-style regulations.” See Brumsickle, 624 F.3d at 1008-09; Pl.’s Br. at 11. Therefore, the Court concludes that the challenged provisions are not rendered unconstitutional by the “major purpose” language in Buckley. b. Specific Arguments. In addition to its generalized arguments, IRTL makes particularized arguments against the provisions challenged in Count 2. See Pl.’s Br. at 7-12. At the hearing, IRTL’s counsel summarized its main complaints as follows: Iowa has chosen not to use that federal model that it clearly knows about and goes above and beyond and requires more. It requires you to register before you speak. That’s onerous. It requires you to continue reporting even when you don’t speak. It requires you to terminate and essentially say you are not going to speak anymore. And then you would have to file another registration if you change your mind. These are onerous burdens. Hr’g Tr. 49:5-11. As discussed above, these provisions are subject to exacting scrutiny. See Citizens United, 130 S.Ct. at 914. This standard “requires a ‘substantial relation’ between the disclosure requirement and a ‘sufficiently important’ governmental interest.” Id. The Court will address IRTL’s specific contentions in turn. i. Initial filing requirements. IRTL first objects to the initial filing requirements contained in Iowa Code §§ 68A.404(4)(a), 68A.404(3)(a), and Form Ind-Exp-O. See Pl.’s Br. at 7, 9 & n. 3. As an initial matter, IRTL’s counsel repeatedly insisted at the hearing that Iowa requires corporations to register before they speak. Hr’g Tr. 12:12-13, 49:5-7; see also id. at 19:24-25. However, the statute contains no such requirement. Section 68A.404(3)(a) provides that “[a]n initial report shall be filed at the same time as the independent expenditure statement.” Section 68A.404(4)(a) further provides: An independent expenditure statement shall be filed within forty-eight hours of the making of an independent expenditure in excess of seven hundred fifty dollars in the aggregate, or within forty-eight hours of disseminating the communication to its intended audience, whichever is earlier. For purposes of this section, an independent expenditure is made when the independent expenditure communication is purchased or ordered regardless of whether or not the person making the independent expenditure has been billed for the cost of the independent expenditure. Although the statute requires both an “independent expenditure statement” and an “initial report,” the Board allows independent expenditure committees to file a single form, Form Ind-Exp-O, to satisfy both requirements. See Smithson Aff. ¶ 8 (citing Iowa Admin. Code r. 351-4.27(2)); Pl.’s Br. at 7 n. 3. For the purposes of § 68A.404, “an independent expenditure is made at the time that the cost is incurred.” Iowa Code § 68A.404(4)(e). Therefore, it is possible that a corporation would have to make its initial filing before it actually disseminates its speech to the public. See Iowa Code § 68A.404(4)(a). However, the fact that this possibility exists is very different from a blanket requirement that corporations “register before they speak.” See Hr’g Tr. 49:7. In its brief, IRTL argues that §§ 68A.404(3)(a) and 68A.404(4)(a) are unconstitutionally burdensome because an independent expenditure committee must make its initial filing within 48 hours of making an independent expenditure. See PL’s Br. at 9. According to IRTL, the state has “no justification” for requiring independent expenditure committees to file so quickly. See id. at 10-11. Defendants argue that the state has an important interest in letting the public know “who is speaking about a candidate shortly before an election.” See Defs.’ Br. at 8 (quoting Citizens United, 130 S.Ct. at 915-16); see also id. at 10 (arguing that the 48-hour filing requirement is substantially related to this interest). The Court agrees that this is a sufficiently important government interest. See Citizens United, 130 S.Ct. at 915-16. The Court also finds that the 48-hour reporting requirement is substantially related to this important government interest. Requiring prompt disclosures, especially close to an election, helps to assure that they are made “in time to provide relevant information to voters.” See McConnell, 540 U.S. at 200, 124 S.Ct. 619; see also Citizens United, 130 S.Ct. at 916 (praising the benefits of “prompt disclosures”). And, contrary to IRTL’s assertions, the Court does not find the 48-hour reporting requirement to be an “onerous” burden. See Hr’g Tr. 49:5-11. Therefore, Iowa’s initial filing requirements pass exacting scrutiny. Because these provisions pass exacting scrutiny, the Court concludes that IRTL is unlikely to succeed on the merits of its claims against the initial filing requirements contained in Iowa Code §§ 68A.404(4)(a), 68A.404(3)(a) and Form Ind-Exp-O. ii. Subsequent reporting requirements. IRTL argues that Iowa’s subsequent reporting requirements for independent expenditure committees, as contained in Iowa Code §§ 68A.404(3)(a), 68A.404(3)(a)(l), and Iowa Administrative Code rule 351-4.9(15), are unconstitutionally burdensome. See PL’s Br. at 7-8, 8 n. 6. First, IRTL objects to the fact that § 68A.404(3)(a) and rule 351 — 1.9(15) require periodic disclosures instead of “event-driven” disclosures. See PL’s Br. at 9. Both the statute and the rule require independent expenditure committees to file reports “according to the same schedule as the office or election to which the independent expenditure was directed.” Iowa Code § 68A.404(3)(a); Iowa Admin. Code r. 351 — 1.9(15). Defendants argue that this periodic reporting requirement serves the state’s informational interest, allowing Iowa to help its citizens “make informed choices in the political marketplace.” Defs.’ Br. at 11-12 (quoting Citizens United, 130 S.Ct. at 914). The Court agrees, and finds that the periodic reporting requirement is substantially related to this important informational interest. See Citizens United, 130 S.Ct. at 915-16; see also SpeechNow.org, 599 F.3d at 696 (noting that “[t]he Supreme Court has consistently upheld organizational and reporting requirements against facial challenges,” based on this informational interest); Minn. Citizens Concerned for Life v. Swanson, No. 10-2938, 741 F.Supp.2d 1115, 1130-31, 2010 WL 3768041, at *11 (D.Minn. Sept. 20, 2010) (slip copy) (upholding periodic reporting requirements). Iowa “is entitled to conclude that its electorate needs to know, on an ongoing basis, the source of financial support for those who are taking positions” in support of a candidate for state office. Cf. Nat’l Org. For Marriage v. McKee, 666 F.Supp.2d 193, 208 (D.Me.2009) (upholding reporting requirements in the context of ballot-initiative advocacy). Therefore, the periodic reporting requirements pass exacting scrutiny. Second, IRTL objects to the fact that Iowa “requir[es] supplemental reports from groups simply raising over $1,000 in contributions earmarked for making independent expenditures.” Pl.’s Br. at 9 (citing Iowa Code § 404(3)(a)(l)); see also Hr’g Tr. 49:8 (“It requires you to continue reporting even when you don’t speak.”). Section 404(3)(a)(l) states, in relevant part, that an independent expenditure committee must file supplemental reports “if the person making the independent expenditure either raises or expends more than one thousand dollars.” Iowa Code § 404(3)(a)(l). IRTL refers to money raised under this provision as “earmarked contributions.” See Pi’s Br. at 11. As discussed above, Defendants have asserted an important government interest in providing the electorate with information about campaign-related spending. See Defs.’ Br. at 11-12. Earmarked contributions, like independent expenditures, constitute “spending that is unambiguously related to the campaign of a particular ... candidate.” Buckley, 424 U.S. at 80, 96 S.Ct. 612. The Court concludes that Iowa’s requirements that these contributions be reported is substantially related to the government’s important informational interest because it can help “shed the light of publicity on spending that is unambiguously campaign related.” See id. at 81, 96 S.Ct. 612. Therefore, the supplemental reporting requirement also passes exacting scrutiny. Because both of these requirements pass exacting scrutiny, the Court concludes that IRTL is unlikely to succeed on the merits of its claims against the periodic and supplemental requirements contained in Iowa Code §§ 68A.404(3)(a), 68A.404(3)(a)(l) and Iowa Administrative Code rule 351— 4.9(15). Hi. Termination notice. IRTL argues that Iowa requires independent expenditure committees to formally dissolve in a manner that “effectively requires the entity to cease to exist.” PL’s Br. at 10; see also Hr’g Tr. 11:19-20. IRTL also argues that an independent expenditure committee may not terminate its status as such without the Board’s approval. Pl.’s Br. at 10-11; Hr’g Tr. 11:21-23. According to IRTL, these requirements are unconstitutionally burdensome and are imposed on independent expenditure committees by Iowa Code § 68A.402B(3), Iowa Administrative Code rule 351-4.9(15), and Form DR-3. See Pl.’s Br. at 8, 10-11 & n. 6; see also Mot. at 1 (challenging these provisions). However, none of these three challenged provisions actually impose such requirements on independent expenditure committees. First, there is simply no requirement in § 68.402B(3) that “effectively requires [a covered] entity to cease to exist.” PL’s Br. at 10; see also Mot. at 1 (challenging only subsection (3) of § 68A.402B). Section 68A.402B provides, in its entirety, that: 1. If a committee, after having filed a statement of organization or one or more disclosure reports, dissolves or determines that it will no longer receive contributions or make disbursements, the committee shall notify the board within thirty days following such dissolution or determination by filing a dissolution report on forms prescribed by the board. 2. A committee shall not dissolve until all loans, debts, and obligations are paid, forgiven, or transferred and the remaining moneys in the committee’s account are distributed according to sections 68A.302 and 68A.303. If a loan is transferred or forgiven, the amount of the transferred or forgiven loan must be reported as an in-kind contribution and deducted from the loans payable balance on the disclosure form. If, upon review of a committee’s statement of dissolution and final report, the board determines that the requirements for dissolution have been satisfied, the dissolution shall be certified and the committee relieved of further filing requirements. 3. If a person who files an independent expenditure statement and a disclosure report, pursuant to section 68A.404, determines that the person will no longer make an independent expenditure, the person shall notify the board within thirty days following such determination by filing a termination report on forms prescribed by the board. Thus, the statute clearly distinguishes between requirements for committees (including political committees) and independent expenditure committees. Section 68A.402B requires both committees and independent expenditure committees to notify the Board if they determine that they will no longer participate in covered election-related activities. See Iowa Code §§ 68A.402B(1), (3). However, the required reports are not the same. Committees (which, as noted above, include political committees) must file a “dissolution report,” while “a person who files an independent expenditure statement and a disclosure report, pursuant to section 68A.404” (i.e., an independent expenditure committee) must file a “termination report.” Compare Iowa Code § 68A.402B(1) ivith Iowa Code § 68A.402B(3). Additionally, the statute indicates that committees must formally dissolve and seek Board approval before their reporting requirements are extinguished. Iowa Code § 68A.402B(2). But there is no such requirement for independent expenditure committees. See Iowa Code § 68A.402B. Therefore, § 68A.402B simply does not require independent expenditure committees to formally dissolve or obtain Board approval before their reporting requirements are extinguished. Second, IRTL points to the use of the term “notice of dissolution” in Iowa