Last year, Michigan's Secretary of State Jocelyn Benson unilaterally changed Michigan's election rules. In fact, even the Michigan Courts ruled that Benson's actions violated existing law. But Benson is not done yet! Recently, Jocelyn Benson submitted three rulemaking requests to change election "rules" here in Michigan, which will permanently enact her temporary changes from 2020 and weaken our election security here in Michigan. 

Per the rule-making process, the Secretary of State will be holding a public hearing on these three proposed rule sets on Friday, October 1, 2021, at 9:00 am in Detroit at the Cadillac Place Room L-150, 3044 W. Grand Blvd. Members of the public are encouraged to attend, where you will have two minutes to speak during the call to the public. 

So, what are the rules? 


MOAHR 2021-060: Would create a process for disqualifying candidates based upon certain information on a candidate's affidavit of identity. 

Under proposed rule 2021-060, candidates would be required to identify every jurisdiction they have previously sought nomination or election in on the Affidavit of Identity; requires the filing official to examine campaign finance records to ensure a candidate has not made a false statement on their affidavit; and requires the filing official to disqualify a candidate who has an error, even unintentionally, on the affidavit.  

Concerns related to MOAHR 2021-060:

  • If the proposed rules are adopted, candidates who have their Affidavit of Identity disqualified cannot reverse the disqualification by filing a correct affidavit, even before the filing deadline. 

  • City and township clerks do not have training with Michigan's Campaign Finance Act since campaign finance reports are filed with the Secretary of State's office or a County Clerk's office. 

  • Many filing officials are understaffed in their offices. Having to review potentially thousands of campaign finance records will be a major undertaking that will increase costs and cause delays. 

  • Many campaign finance reports are not available online and would require county, township, and city staff to manually search records across the state. 

  • Current record retention schedules allow for the destruction of campaign finance records, and the records may no longer be available. 

MOAHR 2021-061: Would change the signature matching standards for absent voter ballot applications and absentee voter ballot envelopes. 

Concerns related to MOAHR 2021-061: 

  • If the proposed rule were adopted, the rule would create an automatic presumption that the signature on an absentee voter ballot application and absentee voter ballot envelope is valid. 

  • A voter's signature will only be considered invalid if it differs in multiple, significant, and obvious respects from the signature on file. 

  • The rule includes overly broad "redeeming qualities" that allow a mismatched signature to be accepted. 

  • The rule includes overly broad "explanations for differences" subject to vastly different applications between election officials.

MOAHR 2021-062: Would create a process for and the forms required to allow online absent voter ballot applications. 

Concerns related to MOAHR 2021-062: 

  • This rule would require using a voter's stored digital signature on file with the Michigan Secretary of State is signing the online absentee voter ballot application. Voters would not be required to provide an "original ink" signature on the application. 

  • When reviewing online applications, election officials would review a digital signature submitted against the same digital signature in the database. 

  • Comparing a stored digital signature evades the requirements of MCL 168.759(4), which requires an applicant to sign an application for an absentee ballot. 

  • The entire purpose of the signature is to verify an official ballot is being mailed to the person eligible to receive that absentee ballot. 

  • Using an online application with a digital signature does not allow city and township clerks the opportunity to compare a voter's signature. 

  • Potential abuse of this process is highly likely, especially for senior citizens who may often have guardians or others with access to their personal information required to utilize the online absentee ballot application process. 

  • The proposed rule allows individuals to change their signature on file with the Secretary of State's office without real proof of the person providing the signature.


By clicking submit below you acknowledge that your name, address, email, phone number, and comments above will be officially submitted to the Michigan Secretary of State's office as public comment related to proposed rules 2021-60, 2021-61, and 2021-62.

Thank you for helping me secure our elections in Michigan! Your public comment has been received.