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      Recording nonconnected PAC receipts

Recording nonconnected PAC receipts With respect to receipts, the Federal Election Campaign Act (the Act) requires reporting of all receipts, but requires recordkeeping only for contributions. Nevertheless, nonconnected PACs must keep records for all types of receipts in order to comply with the reporting requirements of the Act and FEC regulations. The committee must maintain the following information for contributions of any amount and should maintain these records for other receipts: Amount received;Date of receipt; andName and address of source.
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      Recording nonconnected PAC disbursements
            
             Recording nonconnected PAC debts and loans
            
             Reporting examples
 Forwarding contributions
          
            Date of receipt
          
            Recording contributions
          
            Documenting a contribution’s legality
          
            Recording other receipts
          
          
            Legal citations
 Forwarding contributions

  
  
    A person who collects contributions on behalf of a nonconnected committee must not commingle them with personal funds. Instead, he or she must forward the contributions, together with the appropriate recordkeeping information about the contributors to the committee treasurer within the following time periods:Contributions of $50 or less: Within 30 days after receiving the funds.Contributions of more than $50: Within 10 days after receiving the funds.Depositing fundsAll contributions, regardless of amount, must be deposited in a committee bank or credit union account within 10 days of the treasurer’s receipt.
 Date of receipt

  
  
    The "date of receipt" of a contribution is the date on which a person receiving the contribution on behalf of the committee obtains possession of it. That date is the date used for recordkeeping and reporting of receipts.The date of receipt may be earlier than the date the committee treasurer receives the money, since a person collecting contributions has several days in which to forward them to the treasurer.Credit card receiptsWhen the committee receives contributions through credit card charges, the date of receipt is the date on which the committee receives the contributor's signed authorization to charge the contribution or on the date the contributor's credit card account is charged. The treasurer should retain a copy of the authorization form in the committee's records.Deposit of receiptsOnce the treasurer receives a contribution, he or she must deposit it within 10 days. Contributions not deposited within 10 days must be returned to their donors.
 Recording contributions

  
  
    Contributions from individuals and from groups other than political committees must be recorded as follows:Contributions aggregating over $200For each contribution that exceeds $200, either by itself or when aggregated with (added to) previous contributions from the same donor to the committee during the same calendar year, records must identify the following information:Amount;Date of receipt;Donor’s full name and address; andDonor’s occupation and employer.
      
      Learn more about best efforts to document receipts
      
      Contributions of more than $50Records must identify each contribution exceeding $50 by noting the following:Amount;Date of receipt; andDonor’s full name and address. In addition to any other recordkeeping requirements, committees must retain a full-size photocopy or digital image of the check for any contribution over $50.Contributions of $50 or lessThe Commission recommends two possible accounting methods:Keep the same records as those required for contributions that exceed $50; orIn the case of small contributions collected at a fundraising event (such as gate receipts, cash contributions, etc.), keep a record of the name of the event, the date and the total amount of contributions received on each day of the event.
      
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      How to report
        Proceeds from sales
      
      Contributions from political committeesCommittee records must identify all contributions from political committees regardless of amount by noting the amount, date of receipt and the name and address of the contributing committee.
      
      Joint fundraising receiptsWith regard to gross proceeds, the joint fundraising representative must collect the following contributor information and later forward it to the participating political committees:For contributions exceeding $50, the amount, date of receipt and the contributor's name and address.For contributions exceeding $200, the amount, date of receipt and the contributor's name, address, occupation and employer.The date of receipt is the date the joint fundraising representative receives the contribution.
      
      Learn more about the rules for joint fundraising
 Documenting a contribution’s legality

  
  
    In order to determine whether a contribution of questionable legality was made by a permissible source and was not excessive, the treasurer must make at least one written or oral request for evidence of the contribution's legality. If the contribution cannot be determined to be legal, the treasurer must refund the contribution to the source within 30 days of receiving it.A committee must keep a written record noting the basis for concern for each deposited contribution that:Requires a written reattribution from the contributor; orRequires confirmation that it is not from a prohibited source.
      
      Learn more about the rules for reattributed contributions
 Recording other receipts

  
  
    The FEC recommends that committees keep records on the following receipts in order to fully comply with reporting requirements:Transfers from affiliated committees;Bank loans;Interest and dividends received on invested committee funds; andRepayments on loans made by the committee.Committee records should contain the full name of the source and the date and amount of each receipt.
      
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      How to report
        Debts owed by the committee
      
      Learn more about the rules for loans and debts
 Legal citations Regulations 11 CFR 100.12Definition of identification 11 CFR 102.8(b)Receipt of contributions 11 CFR 102.9Accounting for contributions and expenditures 11 CFR 102.15Commingled funds 11 CFR 102.17(c)(3)(iii), (c)(4)(ii)Joint fundraising by committees other than SSFs 11 CFR 103.3(a), (b)(1), (b)(5)Deposit of receipts and disbursements 11 CFR 104.7(a), (b)Best efforts
 Advisory Opinions AO 2007-17Signature requirements for contributions in the form of physical checks generated through online banking services AO 1999-17Internet use by campaign AO 1995-09Operating a political committee in cyberspace AO 1992-29Late deposit of contributions AO 1991-18Telemarketing services provided by corporate vendor AO 1991-01Credit card contributions to PAC of federal contractor partnership AO 1990-04Use of credit cards to make combined dues/contribution payments AO 1983-15State funds deposited in state party's account AO 1981-48Recordkeeping requirements for party's bingo fundraisers AO 1980-99Accounting for contributions under $50


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This information is not intended to replace the law or to change its meaning, nor does this information create or confer any rights for or on any person or bind the Federal Election Commission or the public. The reader is encouraged also to consult the Federal Election Campaign Act of 1971, as amended (52 U.S.C. 30101 et seq.), Commission regulations (Title 11 of the Code of Federal Regulations), Commission advisory opinions and applicable court decisions.


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