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        Making disbursements as an SSF or connected organization
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      Day-to-day operations

Day-to-day operations Using treasury funds A connected organization may use its treasury funds, including funds derived from commercial activities or dues payments, to pay the costs of establishing, administering and soliciting contributions to the SSF. Treasury money can be used, for example, to pay for office space, phones, salaries, utilities, supplies, bank charges and fundraising activities. There are no dollar limits on these disbursements, and they are not reported to the FEC. The connected organization may either pay these costs directly or establish a separate administrative account to be used solely for the SSF’s administrative and fundraising expenses. The funds contained in the administrative account may never be commingled with the SSF’s own funds, which are derived solely from lawful contributions. Trade associations sponsoring SSFs can solicit their members for donations to their administrative accounts under certain circumstances. Using the SSF’s own funds Although the law permits the connected organization to pay start-up, administrative and fundraising expenses for an SSF, the committee may use its own funds to pay those costs. All disbursements by the SSF for these purposes are reportable as operating expenditures on Line 21(b) of Form 3X. Note that the connected organization may reimburse the SSF for those operating expenditures, provided that the reimbursement is made within 30 days of the SSF’s disbursement. These reimbursements are reported as “offsets to operating expenditures.”
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          Understanding the SSF and its connected organizationFundraising for an SSFTravel on behalf of SSFRecording disbursements for an SSF Need help? Get help from the FEC by phone or email
 Legal citations Regulations 11 CFR 114.1(b)Establishment, administrative and solicitation costs 11 CFR 114.5(b)Use of treasury monies 11 CFR 114.5(e)(1)Establishment, administrative and solicitation costs not reported
 Advisory opinions AO 2006-33Association may compensate state affiliate collecting agents AO 2000-03PAC's payment for corporate communication AO 1992-20Funds from members' corporate practice accounts used to pay SSF's expenses AO 1991-36Corporate payment of employee's travel expenses to fundraiser AO 1990-04Use of credit cards to make combined dues/contribution payments AO 1986-13Eligibility of trade association's corporate members and state associations to finance PAC expenses AO 1983-22Reimbursement of PAC's administrative expenses by parent corporation AO 1981-19Combined investment of political/administrative funds in money market AO 1980-59Corporate funds donated to defray administrative costs of separate segregated fund AO 1980-50Corporate payment of expenses in connection with separate segregated funds


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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