Your web browser is not supported You're using Internet Explorer, some features might not work. Please switch to another browser like Chrome, Firefox, or Edge for a better experience.


An official website of the United States government Here's how you know
 **Official websites use .gov**
            
            A **.gov** website belongs to an official government organization in the United States.
 **Secure .gov websites use HTTPS**
            
            A **lock** ( A locked padlock ) or **https://** means you've safely connected to the .gov website. Share sensitive information only on official, secure websites.


Federal Election Commission | United States of America Calendar
           Glossary
          Search
              Search


Menu
      Home
      Campaign finance data
        All data
            Raising
            Spending
            Loans and debts
            Filings and reports
            Candidates
            Committees
            Bulk data
            Campaign finance statistics
        Find elections. Search by state or ZIP code
          Look up contributions from specific individuals
      Help for candidates and committees
        All compliance resources
            Guides
            Forms
            Dates and deadlines
            Trainings
        Learn about electronic filing
          Find and contact your committee's analyst
      Legal resources
        All legal resources
            Advisory opinions
            Enforcement
            Statutes
            Legislation
            Regulations
            Court cases
            Policy and other guidance
        Search across all legal resources
          Search guidance documents
      About
        All about the FEC
            News and announcements
            Commission meetings
            Mission and history
            Leadership and structure
            Reports about the FEC
            Careers
            Working with the FEC
            Contact
        Introduction to campaign finance and elections


- Home
- ›
        Help for candidates and committees
- ›
        Making disbursements as a PAC
- ›
      Support from sponsoring organization

Support from sponsoring organization A nonconnected committee may be sponsored by a partnership or another type of unincorporated organization. However, most forms of support received by a committee from such an organization are contributions, subject to the limitations, prohibitions and reporting requirements of the Federal Election Campaign Act (the Act). Regardless of whether the committee uses the sponsoring organization’s contributions to pay for its operating expenses or to support candidates, monetary and in-kind contributions from the sponsoring organization are subject to an aggregate limit of $5,000 per calendar year. Gifts of money Subject to the PAC’s contribution limits, the sponsoring organization may contribute permissible funds directly to a nonconnected committee for any lawful purpose. In-kind contributions A sponsoring organization makes an in-kind contribution to a nonconnected committee when it: Pays a vendor for the committee’s supplies, rent, telephone bills, postage, printing, etc.;Provides goods or services to the committee at its own expense (such as a payroll deduction system to collect contributions); orPays the salary of an individual when he or she is working on committee business. In-kind contributions from the sponsoring organization must be paid for with permissible funds and are subject to the same annual limit as the committee’s direct gifts of money. Loans A sponsoring organization may loan money to a nonconnected committee. Loans from the sponsoring organization are contributions to the extent that they remain outstanding, and the outstanding balance on the principal amount is subject to the calendar year limit. A loan exceeding that amount is illegal even if repaid in full. The committee must itemize a loan on Schedule C on the first report filed after the loan is made and continue to report the outstanding balance and any payments until the debt is extinguished. Legal and accounting services A sponsoring organization may provide free legal and accounting services to a nonconnected committee if the services are provided solely to help the committee comply with federal campaign finance laws and if the individuals performing the services are regular employees of the organization. Unlike other services rendered to a committee, the cost of providing such services is not a contribution and does not count against the contribution limit. However, the committee must report the receipt of the services. Sponsors affiliated with corporations Because contributions from corporations are prohibited, a partnership or an LLC with corporate members may not attribute any portion of a contribution to the corporate partners. When a political committee is sponsored by a non-corporate entity that is entirely owned by one or more corporations (such as a joint venture partnership) and is affiliated with at least one of the corporate owners, the rules generally applicable to nonconnected committees do not apply. Instead, the committee would operate under the rules governing separate segregated funds (SSFs).
 Learn more about partnerships affiliated with corporations
 Exempt administrative and fundraising payments A corporation may use its treasury funds to pay the costs of establishing, administering and soliciting contributions to its SSF, without making a prohibited corporate contribution. In several advisory opinions, the Commission has applied this provision to permit a corporation that is affiliated with an unincorporated entity to pay the administrative and solicitation expenses of the affiliate’s PAC. In these cases, the affiliated corporation functions as the connected organization of the committee and the committee is the corporation’s SSF (with the appropriate solicitation restrictions). Moreover, when the unincorporated entity is wholly owned by corporations and affiliated with at least one of them, the unincorporated entity may also pay administration and solicitation costs of its own PAC without the payments resulting in a contribution to the sponsored committee. (Note that the owner/affiliated corporation would be listed as the connected organization of the PAC.) For more information regarding affiliation among corporations and committees, see the Campaign Guide for Corporations and Labor Organizations. It is important to note that the fact that a sponsoring noncorporate entity is owned by one or more corporations does not necessarily result in affiliation with one or more of those corporations. For instance, the Commission concluded that a nonconnected political committee sponsored by a limited liability company was not affiliated with any of the five corporations that jointly owned the LLC. As a result, neither the sponsoring LLC nor any of its corporate owners could pay the committee’s administrative and solicitation expenses. Instead, the committee had to cover these expenses using the contributions it received. Solicitation restrictions Under the Act and FEC regulations, SSFs may solicit contributions from only a restricted class of individuals. In several advisory opinions, the Commission has applied this restriction to political committees sponsored by unincorporated entities that are affiliated with corporate SSFs. As a result, this type of committee cannot solicit contributions from the general public; it may only solicit the restricted class of its sponsoring organization and affiliated corporation(s). Corporate personnel and nonconnected PACs Individuals associated with an incorporated entity (including an incorporated trade association or nonprofit organization) may establish a nonconnected PAC. To do so, the individuals must demonstrate that their PAC is financially and organizationally independent of the incorporated entity by: Reimbursing the corporation for any use of office facilities within a commercially reasonable time and at the usual and normal charge;Paying in advance for any use of corporate staff, customer/mailing lists, catering services and any other goods and services that the corporation does not supply in the ordinary course of business; andHaving a diversified leadership which, for example, ensures that individuals affiliated with a particular incorporated entity will not form the majority of the committee’s board. Note, however, that even if a nonconnected committee demonstrates financial and organizational independence, it may nevertheless become affiliated with the SSF of the incorporated entity. If this were to occur, the nonconnected PAC would become an SSF. For information on SSFs, see the FEC’s Campaign Guide for Corporations and Labor Organizations.
 Read next
            
          
            
          Registering affililated nonconnected PACsPartnership and LLC contributionsSupport from corporations and labor organizations From the FEC Record Notice of proposed rulemaking on limited liability partnerships (2012)
 Need help? Get help from the FEC by phone or email
 Legal citations Regulations 11 CFR 100.52(b)Gift, subscription, loan, advance or deposit of money 11 CFR 100.86Legal or accounting services to other political committees 11 CFR 110.1Communications; advertising; disclaimers 11 CFR 114.2(b)Prohibitions on contributions, expenditures and electioneering communications
 Advisory opinions AO 2014-17Commission treatment of partnerships and LLCs that may not make contributions AO 2011-10Contribution deduction program by nonconnected committee of LLC AO 2010-16Wholly corporate owned LLC as connected organization for SSF AO 2005-20Use of federal contractor partnership's automated payroll system to allow partners to designate funds from their electronic payroll distributions as contributions to the partnership's nonconnected PAC AO 2004-42Limited liability company as connected organization for SSF AO 2003-28LLC's nonconnected PAC may become an SSF AO 2001-18Affiliation between LLC PAC and PACs of corporate owners in 60-40 joint venture AO 2001-07Nonaffiliation of LLC PAC with PACs of its five corporate owners AO 2000-20Creation of nonconnected committee AO 1997-26Establishment of nonconnected PAC by individuals affiliated with trade association AO 1997-15Establishment of nonconnected PAC by incorporated membership organization's CEO AO 1997-13Relationship of limited liability company's nonconnected PAC to parent corporations' SSFs AO 1996-49Superseded in part by AO 1997-13. Affiliation between joint venture partnership PAC and corporate partner SSF AO 1996-38Solicitable class of nonconnected PAC affiliated with SSF AO 1994-09Transfers from nonfederal PACs; effect of corporate reorganization on affiliation AO 1992-17Partnership PAC affiliated with SSFs of corporate partners AO 1989-08Solicitable class and name of PAC established by corporation affliliated with partnership AO 1987-34Solicitation of joint venture partnership's restricted class


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.


About
          Careers
          Press
          Contact
   Privacy and security policy
          Plain language
          No FEAR Act
          Strategy, budget and performance
 Open government
          Protected Voices
          USA.gov
          Inspector General
          FOIA
 OpenFEC API
          GitHub repository
          Release notes
          FEC.gov status


Federal Election Commission
 The FEC's Twitter page
            The FEC's YouTube page Sign up for FECMail


Hide glossary Glossary Search terms