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James E. Trainor III

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Trey Trainor
Chair of the Federal Election Commission
In office
June 18, 2020 – December 31, 2020
PresidentDonald Trump
Preceded byCaroline C. Hunter
Succeeded byShana M. Broussard
Commissioner of the Federal Election Commission
In office
June 5, 2020 – October 3, 2025
PresidentDonald Trump
Joe Biden
Preceded byMatthew S. Petersen
Succeeded byTBD
Personal details
BornJames Edwin Trainor III
Odessa, Texas, U.S.
PartyRepublican
EducationTexas A&M University (BA)
Texas Wesleyan University (JD)

James Edwin "Trey" Trainor III is an American Republican lawyer and government official. He is a former member of the Federal Election Commission. He was nominated by President Donald Trump and confirmed by the Republican-controlled Senate. He served as chair of the commission in 2020 and again in 2025. He was a candidate for the 2026 election in Texas's 21st congressional district.

Career

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Trainor was admitted to the bar in Texas in 2003.[1] He is board certified in legislative and campaign law by the Texas Board of Legal Specialization in 2024. His practice primarily focuses on election law, campaign finance, and ethics.[2] He has been a partner at the Dhillon Law Group, Inc. since October 2025. Previously he was a partner at Akerman LLP's Austin office[3] and with the Houston based firm of Beirne, Maynard, & Parsons, LLP. He has long supported reduced regulation of money in politics,[3] and represented the right-wing advocacy group Empower Texans in lengthy disputes with the Texas Ethics Commission over whether the group was obligated to disclose its donors.[3][2]

Trainor served as chief of staff to then-State Representative Phil King from 1999 to 2003. In 2003, when Representative King was appointed Chairman of the Regulated Industries Committee for the Texas House of Representatives, Trainor served as chief clerk and counsel to the committee.

In July 2005, Trainor departed King’s staff to serve as General Counsel for the Office of the Texas Secretary of State under then-Secretary Roger Williams. In that role, he helped oversee the operation of the agency and assisted in the representation of the agency, in coordination with the Office of the Attorney General, in all civil and criminal actions brought by or against it. During his tenure, Trainor was appointed by Secretary Williams to serve as the statewide Republican member representing Texas on the Standards Advisory Board to the U.S. Elections Assistance Commission. He was also actively involved in several major cases, including Texas Democratic Party, et al. v. Tina J. Benkiser, Strayhorn v. Williams, and the LULAC v. Perry redistricting litigation. In July 2006, He was appointed by the Supreme Court of Texas to the Task Force on Jury Assembly and Administration,[4] which proposed major reforms to Texas’s jury assembly and administration system.

Trainor returned to Representative King’s staff on the Regulated Industries Committee in 2006 and continued there until 2008, when he left public service to enter private law practice.

During the 2012 Republican primaries, Trainor was counsel for the presidential campaign of Texas Governor Rick Perry.[3] In the 2016 Republican primaries, Trainor initially supported Ted Cruz, but later worked for Donald Trump.[2][3] As general counsel to the 2016 Republican National Convention platform committee, Trainor led the party's efforts to stymie last-ditch Never Trump efforts from anti-Trump Republican convention delegates.[2][3] In 2017, Trainor was appointed assistant general counsel to the Texas Republican Party; newly elected party chairman James Dickey named him to the post.[2] Trainor was also general counsel to the Secretary of State of Texas.[3]

After Trump became president, Trainor joined his administration as special assistant to Secretary of Defense James Mattis.[5]

FEC tenure

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On September 14, 2017, Trump nominated Trainor to be a member of the Federal Election Commission for a term expiring April 30, 2023.[3] Trainor's nomination languished in the Republican-controlled Senate for years,[6][7] with Trump re-nominating him twice (in 2019 and 2020).[6][8][9] During his FEC confirmation hearing, he received strong support from U.S. Senator Ted Cruz , who praised his “immense experience” in election law, his service as General Counsel to the Texas Secretary of State, and his deep commitment to the rule of law, stating that Trainor’s confirmation would strengthen the Commission with “an individual of the utmost character and experience.”[10] During his hearing he refused to recuse himself from matters related to the Trump campaign.[11]

On May 19, 2020, the Senate voted to invoke cloture on his nomination by a 50–43 vote[12] and later that day confirmed his nomination by a 49–43 vote.[13][14] Trump's nomination of Trainor broke a precedent; traditionally, presidents have made nominations to the FEC in pairs (simultaneously nominating one Republican and one Democrat); Trump's decision to nominate Trainor alone was criticized by Democrats.[11] Senator Cruz again praised him as “a friend and an effective advocate for the rule of law” and “a talented lawyer with deep experience in the issues he will face as a commissioner,” calling Trainor “a strong addition to the FEC.”[15]

Trainor's confirmation gave the FEC a quorum, with four of the six commission seats filled (two Republicans, one Democrat and an independent who mostly sides with the Democrat).[11] This theoretically allowed the FEC to move forward on a large backlog of enforcement matters that had effectively halted FEC activity for months during a presidential election year.[11] However, the FEC was still expected to deadlock frequently (as the commission had done for more than a decade) along party lines, since many actions of the commission require a unanimous vote.[11]

On June 18, 2020, Trainor was elected as chair for the remainder of 2020, with Steven T. Walther selected as vice chair.[16]

One of Trainor's early public statements as FEC Commissioner came in August 2020, when he detailed the "Dangers of Procedural Dysfunction"[17] at the Commission. He argued that outside groups were exploiting the FEC's unique administrative enforcement and judicial review procedures to pursue private enforcement of federal campaign finance laws and to advance preferred policy positions through the courts. According to Trainor, this approach ignored the Commission's expertise, subverted its prosecutorial role, tested constitutional separation of powers, and chilled free speech.[18]

In interviews in September 2020 with the Religion News Service, as well as Michael Voris of the right-wing Catholic website Church Militant, Trainor said that churches could endorse political candidates, contrary to common understandings of the Johnson Amendment, which bars tax-exempt nonprofits from endorsing political candidates.[19] He justified this by pointing to Trump's 2017 executive order that the amendment should not be enforced.[19] In the same interviews, Trainor called the separation of church and state a "fallacy" and accused Catholic bishops of "hiding behind" the church's nonprofit status to avoid involvement in the 2020 U.S. elections, which Trainor called a "spiritual war."[19] FEC Commissioner Ellen Weintraub disagreed with Trainor's statements on the Johnson Amendment (saying that the amendment remains law and "cannot be undone with an executive order") and took issue with his depiction of elections as "spiritual wars."[19]

In 2021, following Major League Baseball Commissioner Rob Manfred's decision to relocate the All-Star Game from Atlanta, Georgia, to Denver, Colorado, in protest of Georgia's Election Integrity Act of 2021, Trainor publicly criticized Manfred for hypocrisy. He compared the move to "an election law attorney and member of the Federal Election Commission trying to change a hitter’s swing," highlighting what he saw as inconsistent political stances and potential harm to the sport.[20]

In 2022, reports emerged that Trainor had been listed as a member of Donald Trump's legal team in a Facebook post by the Denton County Republican Party promoting an event at which he was scheduled to speak. The FEC Office of the Inspector General investigated potential ethical impropriety. The investigation concluded with Trainor's full exoneration, finding that the billing reference was made without his knowledge and that it did not create any appearance of impropriety.[21]

In early 2023, Manhattan District Attorney Alvin Bragg indicted former President Donald Trump on charges that included campaign finance violations related to payments to Stormy Daniels, Trainor publicly denounced the indictment. He stated that the case did not constitute a campaign finance violation under federal law.[22]

In April 2023, the FEC entered into a Memorandum of Understanding (MOU) with the Department of Justice to share investigative information. Trainor was the sole commissioner to dissent, describing the agreement as "a grievous affront to the First Amendment" that harmed free public discourse and the agency's transparency mission.[23]

In September 2023, during a House Committee on Administration oversight hearing on the FEC, Trainor was the only one of the six commissioners to testify who warned against the weaponization of the agency against political speech. He reiterated his opposition to the FEC-DOJ MOU and defended gridlock at the Commission as a necessary safeguard against overreach, arguing that it promotes caution, fairness, and balanced oversight while protecting individual rights and constitutional checks and balances.[24]

In November 2023, the Federal Election Commission approved a directive requiring the Office of General Counsel to obtain Commission authorization before undertaking certain investigative actions in enforcement matters.[25] Trainor described the policy as restoring the Commission's oversight of the enforcement process and ensuring that significant investigative decisions involving political committees and federal candidates would be made by the commissioners.[26] [27]Supporters characterized the directive as increasing accountability within the agency, while critics argued that it could slow enforcement proceedings.[28][29][30]

Trainor testified again before Congress in June 2024, this time before the House Judiciary Committee. He criticized Bragg's use of state law to prosecute Trump on matters involving federal campaign finance, arguing that it undermined the exclusive federal framework established by Congress and that the Department of Justice should have intervened to defend federal jurisdiction.[31][32]

In February 2024, Trainor served as an international observer for municipal elections in Costa Rica at the invitation of the Supreme Electoral Court of Costa Rica.[33] He was one of 58 observers from 21 nations. Afterward, he wrote that the successful elections underscored the need for the United States to continue supporting democracies in the Western Hemisphere and to take a stronger stance in helping allies combat mass migration, narcotrafficking, and malign foreign influences.[34]

During the 2024 U.S. presidential election cycle, Trainor commented on the legal and campaign finance challenges surrounding a potential replacement of President Joe Biden with Vice President Kamala Harris on the Democratic ticket, noting the complexities of such a transition.[35]

Following the assassination attempt on former President Donald Trump in Butler, Pennsylvania, in July 2024, Trainor advocated for and voted to amend federal campaign finance regulations to allow candidates to use campaign funds for security upgrades, describing it as a practical safety measure in light of heightened threats to public officials and candidates.[36]

During the final open meeting of the Commission for 2024, Commissioner Ellen L. Weintraub was elected Chair of the Federal Election Commission for 2025, and Trainor was elected Vice Chair.[37] On February 6, 2025, Commissioner Weintraub was removed from the FEC by President Trump.[38] Given his role as the Vice Chair at the time, Trainor immediately became the Acting Chair. He continued to serve in that role, and oversaw the election of a new Chair at the April 30, 2025 open meeting of the FEC. Commissioner Shana M. Brousard was duly installed as Chair beginning July 1, 2025.[39]

In May 2025, while serving as Acting Chairman of the Federal Election Commission, Trainor led a delegation of U.S. election observers to Romania, at the invitation of the country's Permanent Electoral Authority, for the 2025 Romanian presidential election.[40] The group monitored the first round of the Romanian presidential election rerun, held on May 4, 2025, including visits to polling stations in Bucharest. Trainor described the process as highly transparent and secure, noting the use of paper ballots, the presence of poll watchers from every political party, and video recording of ballot counting.[41]

In June of 2025, Trainor was approached about running for Texas Attorney General, but ultimately decided against such a run.[42][43] On October 3, 2025, Trainor announced that he would resign from the Commission.[44][45] On October 6, 2025, he announced he would seek the 21st Congressional District, being vacated by Congressman Chip Roy, in the 2026 United States House of Representatives elections in Texas.[46]

References

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  1. ^ Mr. James Edwin "Trey" Trainor III, State Bar of Texas.
  2. ^ a b c d e Svitek, Patrick (September 12, 2017). "Trump nominates Texas lawyer Trey Trainor for Federal Election Commission". Texas Tribune. Retrieved 1 November 2017.
  3. ^ a b c d e f g h Gold, Matea (September 13, 2017). "Trump nominates conservative Texas lawyer to Federal Election Commission". The Washington Post. Retrieved 1 November 2017.
  4. ^ Order Creating Task Force on Jury Assembly & Administration
  5. ^ Svitek, Patrick (January 25, 2017). "Austin lawyer Trey Trainor joins Trump administration". Texas Tribune. Retrieved 1 November 2017.
  6. ^ a b Courtney Bublé, Commissioner's Resignation Renders FEC Toothless as 2020 Elections Heat Up, Government Executive (August 27, 2019).
  7. ^ The Election Watchdog That Can't Bark, New York Times (August 29, 2019).
  8. ^ PN197 — James E. Trainor III — Federal Election Commission, 116th Congress (2019-2020), Congress.gov.
  9. ^ PN1600 — James E. Trainor III — Federal Election Commission, 116th Congress (2019-2020), Congress.gov.
  10. ^ "Sen. Cruz Praises Nomination of Trey Trainor to the Federal Election Commission | U.S. Senator Ted Cruz of Texas". www.cruz.senate.gov. 2020-03-10. Retrieved 2026-04-08.
  11. ^ a b c d e Ruiz, Rebecca R. (May 19, 2020). "Election Watchdog, Dormant for Months, Can Finally Move Into Action". The New York Times. ISSN 0362-4331.
  12. ^ "U.S. Senate Roll Call Votes 116th Congress - 2nd Session". United States Senate. Retrieved 2020-05-19.
  13. ^ "U.S. Senate Roll Call Votes 116th Congress - 2nd Session". United States Senate. Retrieved 2020-05-19.
  14. ^ Waltens, Brandon (2020-05-20). "After Nearly 3 Years, Texas Election Expert Trey Trainor Confirmed to FEC". Texas Scorecard. Retrieved 2026-04-08.
  15. ^ "Sen. Cruz Applauds Senate Confirmation of Trey Trainor to Be a Member of the Federal Election Commission | U.S. Senator Ted Cruz of Texas". www.cruz.senate.gov. 2020-05-19. Retrieved 2026-04-08.
  16. ^ "FEC elects James E. "Trey" Trainor as Chair, Steven T. Walther as Vice Chair for the remainder of 2020" (Press release). Washington, D.C.: United States Federal Election Commission. June 18, 2020. Retrieved June 29, 2020.
  17. ^ Statement on FEC Procedural Disfunction
  18. ^ "James E. "Trey" Trainor III". FEC.gov. Retrieved 2026-03-27.
  19. ^ a b c d Jack Jenkins (September 18, 2020). "FEC chairman, in interviews, says this year's election amounts to a 'spiritual war'". Religion News Service – via The Washington Post.
  20. ^ "TRAINOR: Commissioner Rob Manfred Is Inconsistently Woke". dailycaller.com. Retrieved 2026-03-27.
  21. ^ Hall, Madison. "FEC Commissioner Trey Trainor cleared of ethics violation after Insider reporting spurred investigation". Business Insider. Retrieved 2026-03-27.
  22. ^ Bedard, Paul (2023-04-05). "FEC: Trump-Stormy case 'not a campaign finance violation'". Washington Examiner. Retrieved 2026-03-27.
  23. ^ "April 19, 2023 open meeting". FEC.gov. Retrieved 2026-03-27.
  24. ^ Altimari, Daniela (2023-09-20). "Democrats rap FEC gridlock that Republicans say is a feature". Roll Call. Retrieved 2026-03-27.
  25. ^ "FEC Agenda Document No. 23-21-B" (PDF).
  26. ^ Express, Dallas (2023-11-16). "Federal Election Commission to give political appointees authority over agency's unelected bureaucrats who conduct investigations into campaign finance". Dallas Express. Retrieved 2026-06-27.
  27. ^ "Satement of Commissioners Allen J. Dickerson and James E. "Trey" Trainor, III Regarding the Commission's Newly Adopted Directive Concerning Investigations Conducted by the Office of General Counsel, November 2, 2023" (PDF).
  28. ^ "Institute for Free Speech (Bradley A. Smith and Gary M. Lawkowski)" (PDF).
  29. ^ "Campaign Legal Center (Erin Chlopak and Saurav Ghosh)" (PDF).
  30. ^ "Campaign for Accountability (Michelle Kuppersmith)" (PDF).
  31. ^ Oliver, Ashley (2024-06-13). "Bragg 'usurped' federal law to charge Trump, FEC commissioner says". Washington Examiner. Retrieved 2026-03-27.
  32. ^ "TREY TRAINOR: Alvin Bragg's Overreach Into Federal Election Law To Take Down Trump Is Extremely Dangerous. Here's Why". dailycaller.com. Retrieved 2026-03-27.
  33. ^ "Week of February 5-9, 2024". FEC.gov. Retrieved 2026-03-27.
  34. ^ Trainor, Trey (2024-03-22). "Successful elections in Costa Rica show the continued need for the Monroe Doctrine". Washington Examiner. Retrieved 2026-03-27.
  35. ^ "FEC COMMISSIONER TREY TRAINOR: Replacing Joe Biden Wouldn't Be So Easy". IJR. 2024-06-28. Retrieved 2026-03-27.
  36. ^ "TREY TRAINOR: Strengthening Candidate Security With Campaign Funds Is A Common Sense Solution". dailycaller.com. Retrieved 2026-03-27.
  37. ^ "Ellen L. Weintraub elected Chair, James E. "Trey" Trainor, III elected Vice Chairman for 2025". FEC.gov. Retrieved 2026-03-27.
  38. ^ "Trump ousted the top Democratic campaign finance regulator. She says it's illegal". POLITICO. 2025-02-07. Retrieved 2026-03-27.
  39. ^ "Shana M. Broussard becomes Chair of the Commission". FEC.gov. Retrieved 2026-03-27.
  40. ^ "Week of April 28 – May 2, 2025". FEC.gov. Retrieved 2026-03-27.
  41. ^ Trainor, Trey (2025-05-09). "What Romania can teach America about election integrity". Washington Examiner. Retrieved 2026-03-27.
  42. ^ Bedard, Paul (2025-06-09). "Pro-Trump FEC chairman eyes bid for Texas attorney general". Washington Examiner. Retrieved 2026-03-27.
  43. ^ Bedard, Paul (2025-07-07). "Lone FEC Republican to stay and block weaponization by Democrats". Washington Examiner. Retrieved 2026-03-27.
  44. ^ Paul Bedard (September 25, 2025). "FEC vice chairman resigns, eyes Chip Roy's Texas House seat". Washington Examiner.
  45. ^ "The Federal Election Commission is down to 2 members. So its work is at a standstill". NPR. Archived from the original on 2025-10-09. Retrieved 2026-03-28.
  46. ^ Birenbaum, Gabby (2025-10-06). "Texas GOP lawyer and former FEC chair Trey Trainor announces run for Chip Roy's seat in Congress". The Texas Tribune. Retrieved 2026-03-27.