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. He is a candidate for the 2026 election in Texas's 21st congressional district.
Trainor was admitted to the bar in Texas in 2003. He was board certified in legislative and campaign law by the Texas Board of Legal Specialization in 2024. He practiced election law, campaign finance, and ethics as a partner in Akerman LLP's Austin office. He has long supported reduced regulation of money in politics, 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.
During the 2012 Republican primaries, Trainor was counsel for the presidential campaign of Texas Governor Rick Perry. In the 2016 Republican primaries, Trainor initially supported Ted Cruz, but later worked for Donald Trump. 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. In 2017, Trainor was appointed assistant general counsel to the Texas Republican Party; newly elected party chairman James Dickey named him to the post. Trainor was also general counsel to the Secretary of State of Texas.
After Trump became president, Trainor joined his administration as special assistant to Secretary of Defense James Mattis.
On September 14, 2017, Trump nominated Trainor to be a member of the Federal Election Commission for a term expiring April 30, 2023. Trainor's nomination languished in the Republican-controlled Senate for years, with Trump re-nominating him twice (in 2019 and 2020). During his FEC confirmation hearings, he refused to recuse himself from matters related to the Trump campaign.
On May 19, 2020, the Senate voted to invoke cloture on his nomination by a 50âÂÂ43 vote and later that day confirmed his nomination by a 49âÂÂ43 vote. 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.
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). 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. 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.
On June 18, 2020, Trainor was elected as chair for the remainder of 2020, with Steven T. Walther selected as vice chair.
One of Trainor's early public statements as FEC Commissioner came in August 2020, when he detailed the "Dangers of Procedural Dysfunction" 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.
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. He justified this by pointing to Trump's 2017 executive order that the amendment should not be enforced. 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." 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."
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 hitterâÂÂs swing," highlighting what he saw as inconsistent political stances and potential harm to the sport.
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.
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.
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.
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.
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.
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. 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.
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.
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.
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. On February 6, 2025, Commissioner Weintraub was removed from the FEC by President Trump. 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.
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. 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.
In June of 2025, Trainor was approached about running for Texas Attorney General, but ultimately decided against such a run. On October 3, 2025, Trainor announced that he would resign from the Commission. 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.