Federal Election Commission

UNITED STATES – o f – AMERICA

Congressional Candidates

and Committees

CAMPAIGN GUIDE

October 2021

i

About this Guide

This Campaign Guide for Congressional Candidates and Committees replaces the July 2014 edition. It 

summarizes the federal campaign finance laws applicable to candidate committees as of September 2021.

Federal Election Commission

Washington, DC 20463

Commissioners:

Shana M. Broussard, Chair

Allen Dickerson, Vice Chair

Sean J. Cooksey

James E. “Trey” Trainor III

Steven T.  Walther

Ellen L.  Weintraub

Staff Director:

Alec Palmer

General Counsel (acting):

Lisa J. Stevenson

Prepared by the Information Division of the Office of Communications

Director:

Greg J. Scott

Deputy Assistant Staff Director for Publications:

George J. Smaragdis

Editor:

Zainab S. Smith

Layout and Design:

James Landon Jones
ii

Introduction

This guide was written to help U.S. House and Senate candidates comply with the Federal Election Campaign 

Act and FEC regulations. It may be used by committees supporting Presidential candidates who are not 

seeking public funding; however, special reporting rules apply to Presidential candidates, as explained in 

footnotes to the reporting chapters.

This publication provides guidance on certain aspects of federal campaign finance law. It is not intended to 

replace the law or to change its meaning, nor does this publication create or confer any rights for or on any 

person or bind the Federal Election Commission (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. For further information, please contact:

Federal Election Commission

1050 First Street, NE

Washington, DC 20463

800/424-9530 (toll free)

202/694-1100 (local)

202/219-3336 (for the hearing impaired)

info@fec.gov (email)

www.fec.gov (website)
iii

Using this guide

Citations

Authorities primarily cited in this guide include the Federal Election Campaign Act, FEC regulations and FEC 

Advisory Opinions (AOs). All regulatory citations are to Title 11 of the Code of Federal Regulations (CFR), 

Parts 100–116, 300, 400 and 9001–9039 (2020). Statutory citations are to Titles 26 and 52 of the United 

States Code (U.S.C.). Copies of AOs may be obtained from the FEC’s Public Records Office (800/424-9530 

or 202/694-1120) or the FEC website. In addition, each AO is summarized in the Commission’s online 

newsletter, the Record.

Getting more help

(Note that congressional campaign committees have to comply with other laws outside the FEC’s 

jurisdiction; see Appendix G.)

Advisory opinions

Any person or group requiring a clarification of the election law with regard to an activity that they plan 

to undertake or are presently undertaking and intend to undertake in the future may request an advisory 

opinion from the FEC. Individuals and organizations involved in the activity specifically addressed in an AO 

(or in an activity that is materially indistinguishable) may rely on the opinion. Advisory opinion requests 

may be addressed to the Office of General Counsel at:

Federal Election Commission

1050 First Street, NE

Washington, DC 20463

Consult the FEC’s website for more information on how to request an AO.

Toll-free line

Many questions about federal campaign finance law do not require formal advisory opinions. Such 

questions may be addressed to trained FEC staff members by calling the FEC’s 800 number. Persons in the 

Washington, DC area may call locally.

The numbers are:

800/424-9530

202/694-1100

202/219-3336 (for the hearing impaired)

Hearing-impaired persons may reverse the charges when calling long distance.

Questions may also be submitted by email to info@fec.gov.

Free publications

In addition to this guide, the FEC publishes a series of brochures and other publications on several aspects 

of the campaign finance and election laws. Email or call the FEC for a list of publications currently available, 

or visit the FEC website.
iv

Using this guide

Website

Visit the FEC’s home page at www.fec.gov. Information on the site includes campaign finance statistical 

data; committee reports for candidates, parties and PACs; FEC news releases; reporting dates; forms; the 

Record newsletter; brochures and campaign guides.

The FEC website also offers the capability to search the Commission’s legal resources. Users can perform 

full text searches of Commission advisory opinions (AOs) (1977-present) using the name of a requestor or 

other keyword information. In addition, the FEC’s Enforcement Query System allows users to search closed 

enforcement cases by such search criteria as respondent name or case number. SERS, the FEC’s Searchable 

Electronic Rulemaking System, allows searches of completed and ongoing rulemakings, Commission 

regulations and Explanations and Justifications. Users can also use SERS to submit comments to ongoing 

rulemakings.

Compliance with Small Business Regulatory Enforcement Fairness Act of 

1996

This guide serves as the small entity compliance guide for congressional candidates and committees, as 

required by Section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996, Pub. L. No. 104-

121, Title II, Stat. 857 (1996).
v

Contents

CHAPTER 1

Testing the Waters 1

1. Testing the Waters vs. Campaigning 1

2. Contribution Limits and Prohibitions 2

3. Recordkeeping and Accounting 2

4. Organizing a Testing the Waters Committee 3

CHAPTER 2

Starting the Campaign 5

1. Candidate Registration Threshold 5

2. Candidate and Committee Registration 5

3. Treasurer 6

4. Statement of Candidacy: Line-by-Line Instructions 8

5. Statement of Organization: Line-by-Line Instructions 8

6. Filing Registration Forms 11

7. Amendments 12

CHAPTER 3

Understanding Contributions 13

1. What is a Contribution 13

2. Types of Contributions 13

CHAPTER 4

Contribution Limits 17

1. Overview of Limits 17

2. How Limits Work 22

3. Contributions to Unauthorized Committees 24

4. Designated and Undesignated Contributions 24

5. Date Contribution is Made vs. Date of Receipt 25

6. Joint Contributions 26

7. Remedying an Excessive Contribution 26

8. Contributions to Retire Debts 30

9. Candidate’s Personal Funds 31

10. Repayment of Personal Loans from Candidate 32

CHAPTER 5

Prohibited Contributions 33

1. Prohibited Sources 33

2. Questionable Contributions 36

CHAPTER 6

Other Reportable Receipts 39

1. Bank Loans 39

2. Brokerage Loans and Other Lines of Credit Obtained by Candidate 40
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Table of Contents

3. Overdrafts 40

4. Investment Income 41

5. Offsets to Operating Expenditures 41

6. Legal and Accounting Services 41

CHAPTER 7

Sources of Support 43

1. Contributions 43

2. Free Legal and Accounting Services 43

3. Volunteer Activity 43

4. Travel Cost Exemptions 45

5. Vendor Discounts 46

6. Support from Other Campaigns 46

7. Party Support 48

8. Corporate/Labor Exceptions 50

9. Use of Corporate/Labor Facilities and Resources 56

10. Fundraisers for Candidates 57

11. Independent Expenditures 58

12. Electioneering Communications 59

CHAPTER 8

Expenditures and Other Uses of Campaign Funds 61

1. Permissible Uses of Campaign Funds 61

2. Prohibited Uses of Campaign Funds 63

CHAPTER 9

Transfers 69

1. Transfers between Candidate’s Committees for Same Office 69

2. Transfers between Committees of Candidate Seeking More Than One Office 69

3. Transfers from Candidate’s Nonfederal Committee Are Prohibited 71

4. Transfers of Joint Fundraising Receipts 71

5. Transfers to Party Committee 71

6. What is NOT a Transfer 71

CHAPTER 10

Conducting the Campaign 73

1. Fundraising 73

2. Disclaimers 75

3. Rates for Political Advertisements 78

4. Campaign Travel 78

CHAPTER 11

Keeping Records 83

1. Record Retention 83

2. Recording Receipts 83

3. Recording Disbursements 86

4. Recording Debts and Loans 87

5. Treasurer’s Best Efforts 87
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Table of Contents

CHAPTER 12

Filing Reports 89

1. Who Reports 89

2. Where to File Reports 90

3. When to Report 90

4. Administrative Fines for Late Filers and Nonfilers 93

5. Electronic Filing 94

6. Public Inspection of Reports 96

CHAPTER 13

Completing FEC Reports 97

1. Reporting Forms and Formats 97

2. Special Rules for First Report 98

3. Categorizing Receipts 98

4. How to Itemize Receipts 99

5. When to Itemize Receipts 99

6. Reporting Contributions, Loans and Advances from Candidate 101

7. Reporting Joint Contributions 102

8. Reporting Redesignations and Reattributions 103

9. Reporting Free Legal and Accounting Services 104

10. Reporting In-Kind Contributions 105

11. Reporting Bitcoin Contributions 107

12. Reporting Recount-Related Donations and Disbursements 108

13. Reporting Offsets to Operating Expenditures 109

14. Reporting Receipt of Refunds of Contributions Made by the Committee 109

15. Reporting Reimbursed Advances of Personal Funds (Non-Travel) 109

16. Reporting Travel Expenses 112

17. Reporting Last-Minute Contributions (48-Hour Notice) 113

18. Categorizing Disbursements 114

19. How to Itemize Disbursements 115

20. When to Itemize Disbursements 116

21. Reporting Debts Other Than Loans 117

22. Reporting Loans 119

23. Reporting Bank Loans, Brokerage Loans and Other Lines of Credit When Made to Candidates 121

24. Reporting Liquidated Bitcoins 123

25. Reporting Refunds, Returns, Bounced or Uncashed Checks and Disgorged Contributions 125

26. Reporting Transfers between Authorized Committees 127

27. Reporting Investments 128

28. Completing the Report 129

29. The Detailed Summary Page 129

30. Post-Election Detailed Summary Page 133

31. Filing Amendments 135

CHAPTER 14

Winding Down the Campaign 137

1. Terminating the Committee 137

2. Conversion to Multicandidate Committee 138

3. Winding Down Costs 138

4. Sale of Campaign Assets 139

5. Retiring Debts 139

6. Settling Debts 140
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Table of Contents

Appendix A

Earmarked Contributions 143

1. Earmarked Contributions 143

2. Effect on Contribution Limits 143

3. Forwarding Earmarked Contributions 144

4. Transmittal to Campaign 144

5. Reporting Earmarked Contributions 145

6. Contributions Bundled by Lobbyists/Registrants and Lobbyist/Registrant PACs 146

Appendix B

Contributions from Partnerships 147

1. Contribution Limits 147

2. Attribution among Partners 147

3. Prohibited Partnership Contributions 148

4. Reporting Partnership / LLC Contributions 149

Appendix C

Joint Fundraising 151

1. Introduction 151

2. Fundraising Representative 152

3. Written Agreement 152

4. Separate Depository 152

5. Statements of Organization 153

6. Start-Up Costs 154

7. Joint Fundraising Notice 154

8. Screening Contributions 155

9. Recordkeeping 155

10. Paying Expenses: Step 1—Allocating Gross Proceeds 155

11. Paying Expenses: Step 2—Allocating Expenses 156

12. Paying Expenses: Step 3—Calculating Net Proceeds 157

13. Reporting 158

14. Exception for Party Committees 159

Appendix D

Communications 161

1. Public Communications 161

2. Coordinated Communications 161

3. Independent Expenditures 165

4. Reporting Requirements for Independent Expenditures 167

5. Party Communications 168

6. Electioneering Communications 169

7. Disclaimer Notices on Communications 170

Appendix E

Fundraising by Federal Candidates and Officeholders 175

1. Fundraising for State/Local Candidates and Elections 175

2. Nonfederal Fundraising Events 176

3. Supporting Independent Expenditure-Only Political Committees 177

4. Supporting Tax-Exempt Organizations 177
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Table of Contents

Appendix F

Lobbyist Bundled Contributions 179

1. What is a Bundled Contribution? 179

2. Who are Lobbyist/Registrants and Lobbyist/Registrant PACs? 181

3. Filing Reports 182

Appendix G

Compliance with Other Laws 187

1. Ethics in Government Act/Personal Finance Reports 187

2. House and Senate Rules 187

3. Ballot Access Rules 187

4. Tax Laws 187

5. Communications Act 188

6. Hatch Act 188

Appendix H

Glossary 189
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Examples

2–1: Candidate registration 6

2–2: Committee registration 9

2–3: Committee registration 10

2–4: Committee registration 11

2–5: Committee registration 12

Table 1: Contribution limits for 2021–2022 federal elections 18

13–1: Contributions from other political committees and organizations 100

13–2: Aggregation of contributions 101

13–3: Contributions from candidate’s personal funds 102

13–4: Joint contributions 102

13–5: Redesignations 103

13–6: Reattributions 104

13–7: Free legal and accounting services 104

13–8: In-kind contribution (Schedule A) 105

13–9: In-kind contribution (Schedule B) 105

13–10: Unreimbursed disbursement by candidate (Schedule A) 105

13–11: Unreimbursed disbursement by candidate (Schedule B) 106

13–12: Appreciated goods as contributions 106

13–13: Sale of appreciated goods as contributions 107

13–14: Bitcoin contributions 107

13–15: Recount donation 108

13–16: Recount disbursement 108

13–17: Offsets to perating expenditures 109

13–18: Nontravel reimbursements 110

13–19: Nontravel staff advances made and reimbursed in different reporting periods 111

13–20: Travel expense reimbursed within time limit and in same reporting period 113

13–21: Last minute contributions (48-hour notice) 114

13–22: Operating expenditures 115

13–23: Contributions to other federal candidates 116

13–24: Credit card transactions (Schedule B) 117

13–25: Credit card transactions (Schedule D) 117

13–26: Debts owed by the committee (Schedule B) 118

13–27: Debts owed by the committee (Schedule D) 118

13–28: Bank loans endorsed by candidate 119

13–29: Loan payment 120

13–30: Loans from candidate’s personal funds (Schedule A) 120

13–31: Loans from candidate’s personal funds (Schedule C) 120

13–32: Candidate home equity line of credit (Schedule A) 121

13–33: Candidate home equity line of credit principal payment 122

13–34: Candidate home equity interest payment 122

13–35: Candidate home equity line of credit (Schedule C) 122

13–36: Candidate home equity line of credit (Schedule C-1) 123

13–37: Selling bitcoin to known purchaser 124

13–38: Selling bitcoin to unknown purchaser 124

13–39: Refunded contributions (Schedule A) 125
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Examples

13–40: Refunded contributions (Schedule B) 125

13–41: Checks returned due to insufficient funds 126

13–42: Disgorged contributions 126

13–43: Transfers between candidate’s committees, same office 127

13–44: Detailed Summary Page 129

13–45: Detailed Summary Page, continued 130

13–46: Post Election Detailed Summary Page 133

13–47: Summary Page 134

13–48: Summary Page, continued 135

A–1: Earmarked contribution 146

B–1: Partnership contributions 149

C–1: Form 1 filed by joint fundraising representative 153

C–2: Form 1 filed by PCC showing affiliation 153

C–3: Joint fundraising (Schedule A) 157

F–1: Reporting bundled contributions 181

Table 2: Form 3L covered periods and filing deadlines for quarterly filers 184
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1

CHAPTER 1

Testing the Waters

Before deciding to campaign for federal office, an individual may want to “test the waters” to explore the 

feasibility of becoming a candidate. For example, an individual may want to conduct polls or travel around 

the state or district to see if there is sufficient support for his or her candidacy.

An individual who merely tests the waters, but does not campaign for office, does not have to register or 

report to the FEC. This is the case even if the funds raised and spent to test the waters exceed the $5,000 

candidate registration threshold. Nevertheless, all funds raised and spent during the testing the waters 

period must comply with the Federal Election Campaign Act’s contribution limits and prohibitions. 

100.72(a) and 100.131(a); see also AO 1985-40 (Republican Majority Fund).

Once an individual begins to campaign or decides to become a candidate, the testing the waters period 

ends, and any funds that were raised or spent to test the waters apply to the $5,000 threshold for qualifying 

as a candidate. 100.72(a) and 100.131. After exceeding the threshold, the individual must register with 

the FEC as a candidate, designate and register a principal campaign committee, and begin to file reports. 

The first report must include all activity that occurred during the testing the waters period. 100.72(a) and 

100.131(a).

1. Testing the Waters vs. Campaigning

Testing the waters

An individual may conduct a variety of activities to test the waters. Examples of permissible testing the 

waters activities include conducting polls, travelling and making telephone calls to determine whether the 

individual should become a candidate. 100.72(a) and 100.131(a).

Campaigning

Certain activities, however, indicate that the individual has decided to become a candidate and is no longer 

testing the waters. In that case, once the individual has raised or spent more than $5,000, he or she must 

register as a candidate. As mentioned earlier, when an individual decides to run for office, funds that were 

raised and spent to test the waters apply to the $5,000 threshold.

Campaigning (as opposed to testing the waters) is apparent, for example, when individuals:

• Make or authorize statements that refer to themselves as candidates (“Smith in 2024” or “Smith for 

Senate”);

• Use general public political advertising to publicize their intention to campaign;

• Inform the media (either directly or through an advisor) that they will announce their candidacy on a 

certain date;

• Raise more money than what is reasonably needed to test the waters or amass funds (seed money) to be 

used after candidacy is established;

• Conduct activities over a protracted period of time or shortly before the election; or

• Take action to qualify for the ballot.

100.72(b) and 100.131(b); see AO 2015-09 (Senate Majority PAC and House Majority PAC).
2

Chapter 1

Also, once an individual files an FEC Form 2 (Statement of Candidacy), he or she is no longer considered to 

be “testing the waters” and must file FEC Form 1 (and subsequently file financial reports) under the rules 

described in Chapter 2, “Starting the Campaign.” AO 1979-51 (Edgar).

2. Contribution Limits and Prohibitions

Funds raised to test the waters are subject to the Act’s contribution limits and source prohibitions. 

100.72(a) and 100.131(a). The limits apply, for example, to:

• Gifts of money, goods and services;

• Loans (except bank loans);

• Certain staff advances until repaid (see Chapter 3 for more information on staff advances);

• Endorsements and guarantees of bank loans; and

• Funds given or personally loaned to the individual to pay for his or her living expenses during the 

testing the waters period (AO 1978-40 (Kogovsek)).

See 100.52(a). See Chapter 4 for more information on contribution limits.

In observing the law’s prohibitions, the individual may not accept money from foreign nationals, federal 

government contractors, corporations or labor organizations. (However, funds from a separate segregated 

fund—also called a PAC— established by a corporation or labor organization are permissible.)

See Chapter 5 for more information on contribution prohibitions.

3. Recordkeeping and Accounting

Recordkeeping

An individual who tests the waters must keep financial records. If he or she later becomes a candidate, 

the money raised and spent to test the waters must be reported by the campaign as contributions and 

expenditures. 101.3. See Chapter 11 for more information on recordkeeping.

Separate bank account

Another consideration, though not a requirement, is the segregation of testing the waters funds from 

personal funds. The FEC recommends that the individual set up a separate bank account for the deposit of 

receipts and the payment of expenses. If the individual later becomes a candidate, a campaign account must 

be established to keep the campaign funds separate from the individual’s personal funds. 102.10, 102.15, 

103.2 and 103.3(a).

Example: Mr. Jones is interested in running for a seat in the U.S. House of Representatives but is unsure 

whether he has enough support within his district to make a successful bid. He therefore accepts up to 

$2,900 from each of several relatives and friends and raises $30,000. He uses the money to pay for an 

opinion poll. He sees that good records are kept on the money raised and spent in his testing the waters 

effort. The poll results indicate good name recognition in the community, and Jones decides to run.

By making this decision, Jones has crossed the line from testing the waters to campaigning. The funds he 

raised earlier now automatically become contributions, and the funds he spent, including the polling costs, 

are now expenditures. Since his contributions or expenditures exceed $5,000, he becomes a candidate and 

must register with the FEC. The money raised and spent for testing the waters must be disclosed on the first 

report his principal campaign committee files.
3

Testing the Waters

Had Jones decided not to run for federal office, there would have been no obligation to report the monies 

received and spent for testing the waters activity, and the donations made to help pay for the poll would not 

have counted as contributions.

4. Organizing a Testing the Waters Committee

An individual may organize a “committee” for testing the waters. An “exploratory committee” (or “testingthe-waters committee”) is not considered a political committee and does not have to register or report to 

the FEC as long as its activities are limited to testing the waters and it does not engage in campaigning.

The name of the exploratory committee, and statements by committee staff, must not refer to the individual 

as a candidate. For example, an exploratory committee could not be called “Sam Jones for Congress,” 

which would indicate that Jones had already decided to run for federal office. (See Section 1.) Instead, the 

committee could be called “Sam Jones Congressional Exploratory Committee.” See AO 1981-32 (Askew).

If the individual decides to run for federal office and becomes a candidate under the Act, then he or she 

may designate the exploratory committee as the principal campaign committee and change the name of the 

committee as appropriate.
4

Chapter 1
5

CHAPTER 2

Starting the Campaign

1. Candidate Registration Threshold

An individual triggers registration and reporting requirements with the FEC when campaign activity exceeds 

$5,000 in either contributions or expenditures.1 The $5,000 threshold is reached when:

• The individual and/or persons he or she has authorized to conduct campaign activity receive over $5,000 

in contributions or make over $5,000 in expenditures; or

• The individual fails to disavow unauthorized campaign activity by writing a letter to the FEC within 30 

days after being notified by the agency that another person or group has received contributions or made 

expenditures of more than $5,000 on the individual’s behalf. 100.3(a)(1)-(3) and 102.13(a)(2).

2. Candidate and Committee Registration

The registration forms mentioned in this section (FEC Forms 1 and 2) are available from the FEC, posted 

on the Commission website, and are part of the agency’s FECFile software.2 Federal candidates and their 

committees should also contact the government offices and agencies listed in Appendix G for additional 

reporting requirements that are not within the FEC’s jurisdiction.

Candidate

Within 15 days after an individual becomes a candidate as described in Section 1, he or she must designate 

a principal campaign committee. This designation is made by filing either a Statement of Candidacy (FEC 

Form 2) or a letter with the same information.3 101.1(a) and 102.12(a). See example 2–1.

Principal campaign committee

Within 10 days after it has been designated by the candidate, the principal campaign committee must 

register with the FEC by filing a Statement of Organization (FEC Form 1). 52 U.S.C. §§ 30102(g), 30103(a); 

102.1(a).4

Candidates must register for each election cycle

A candidate (including an incumbent) must file a FEC Form 2 for each election cycle in which he or she 

is a candidate. For example, if Mr. Jones, who was a candidate for the U.S. House of Representatives in 

2020, wishes to run again in 2022, he must amend his FEC Form 2 within 15 days after crossing the $5,000 

registration threshold for the 2022 election cycle.5

Principal campaign committee

Using Form 2, the candidate may either redesignate his or her previous campaign committee (if it has not 

been terminated) or designate a new principal campaign committee.

1 Money raised and spent to test the waters does not count toward this dollar threshold until the individual decides to run for federal 

office or conducts activities that indicate he or she is actively campaigning rather than testing the waters. See Chapter 1, “Testing the 

Waters.”

2 See Section 6 for information on where to file FEC registration forms.

3 A candidate required to file electronically cannot designate a principal campaign committee with a written letter but must instead file 

Form 2. See the section “Where to file reports.”

4 Copies of FEC Forms 1 and 2 must also be filed with the appropriate office in Guam, Northern Mariana Islands or Puerto Rico for 

candidates running for office in those territories. 108.1.

5 In addition, a separate Form 2 must be filed for any special election in which the candidate is running. For example, if Mr. Jones is also 

participating in the 2021 special election in his district, he must file a Form 2 for the 2021 election year.
6

Chapter 2

If the candidate redesignates an existing 

committee, the committee need only 

amend its Statement of Organization 

(FEC Form 1) within 10 days to 

reflect any new information (e.g., a 

change in the committee’s name or 

address). 102.2(a)(2). The redesignated 

committee will retain its original FEC 

identification number.6

If the candidate designates a new 

principal campaign committee, the 

committee must file a new Statement of 

Organization (FEC Form 1) within 10 

days after being designated. 102.1(a). 

The newly designated committee 

will receive a new FEC identification 

number.

Other authorized committees

In addition to the principal campaign 

committee, the candidate may designate 

other authorized committees to receive 

contributions or make expenditures on 

his or her behalf. The following steps 

must be taken:

Action by candidate

The candidate designates the authorized 

committee by filing a statement (either 

FEC Form 2 or a letter) with the 

principal campaign committee. 101.1(b) and 102.13(a)(1).

Action by authorized committee

Within 10 days after being designated by the candidate, the authorized committee must file a Statement of 

Organization (FEC Form 1) with the candidate’s principal campaign committee. 102.1(b) and 102.13(a)(1).

Action by principal campaign committee

The principal campaign committee, in turn, files the documents with the FEC. 101.1(b).

3. Treasurer

Treasurer required

The committee must have a treasurer before it accepts contributions or makes expenditures. 102.7(a) and 

(b). The committee may also designate an assistant treasurer to assume the treasurer’s duties when the 

treasurer is unavailable. 102.7(a) and (b). Only a treasurer or designated assistant treasurer or agent may sign 

FEC reports and statements. 102.2(a) and 104.14(a). The candidate may act as the committee’s treasurer.

6 Redesignated committees are reminded that, if outstanding debts remain from the previous election, the committee must continue to 

report the debts as well as the contributions that have been designated by contributors to retire them. 104.11, 110.1(b)(3) and (4) and 

110.2(b)(3) and (4). See Chapter 13, Section 21 on reporting outstanding debt.

 (a) Name of Committee (in full)

 (b) Address (number and street)

 (c) City, State, and ZIP Code

 (a) Name of Committee (in full)

 (b) Address (number and street) 

 (c) City, State, and ZIP Code 

7. I hereby designate the following named political committee as my Principal Campaign Committee for the 

(year of election)

 election(s).

NOTE: This designation should be filed with the appropriate office listed in the instructions.

8. I hereby authorize the following named committee, which is NOT my principal campaign committee, to receive and expend funds on behalf of my 

candidacy.

 NOTE: This designation should be filed with the principal campaign committee.

I certify that I have examined this Statement and to the best of my knowledge and belief it is true, correct and complete.

Signature of Candidate Date

FEC FORM 2

STATEMENT OF CANDIDACY

9-00068

NOTE: Submission of false, erroneous, or incomplete information may subject the person signing this Statement to penalties of 52 U.S.C. §30109.

3. Is This New Amended

 Statement (N) OR (A)

FEC Form 2 (rEv. 02/2009)

DEsigNaTiON Of pRiNcipal campaigN cOmmiTTEE

DEsigNaTiON Of OThER auThORizED cOmmiTTEEs (Including Joint Fundraising Representatives)

1. (a) Name of Candidate (in full)

 (b) Address (number and street) Check if address changed 2. FEC Candidate Identification Number 

 (c) City, State, and ZIP Code 

4. Party Affiliation 5. Office Sought 6. State & District of Candidate

Jane Doe

626 Pritham Ave.

Springfield, VA 00000

IND US House VA 12

2022

Doe for Congress

319 Main St.

Springfield, VA 00000

Friends of Jane Doe

229 Hidden View Lane

Springfield, VA 00000

X

Jane Doe 11/11/2020

2–1: Candidate registration
7

Starting the Campaign

Treasurer’s duties

The treasurer (or designated assistant treasurer) is responsible for:

• Filing complete and accurate reports and statements on time. 104.14(d).

• Signing all reports and statements. 102.2(a) and 104.14(a).

• Depositing receipts in the committee’s designated bank within 10 days of receipt. 103.3(a).

• Authorizing expenditures or appointing an agent (either orally or in writing) to authorize expenditures. 

102.7(c).

• Monitoring contributions to ensure compliance with the law’s limits and prohibitions. 103.3(b).

• Keeping the required records of receipts and disbursements for three years from the filing date of the 

report to which they relate. 102.9(c) and 104.14(b).

Treasurer’s liability

A committee’s treasurer is personally responsible for carrying out the duties listed in the previous section 

and should understand these responsibilities as well as his or her personal liability for fulfilling them.

When the Commission brings an enforcement action against a political committee, the treasurer is usually 

named as a respondent along with the committee itself. The treasurer can be named and found liable in an 

official capacity as a representative of the committee. Also, the treasurer can be named and found liable in 

a personal capacity if there is a knowing and willful violation of the Act or an intentional deprivation of the 

operative facts giving rise to the violation.

Even when an enforcement action alleges violations that occurred during the term of a previous treasurer, 

the Commission usually names the current treasurer as a respondent in the action. See the “Statement of 

Policy Regarding Treasurers Subject to Enforcement Proceedings,” 70 Fed. Reg. 3 (January 3, 2005).

Vacancy in office

A committee cannot raise or spend funds when there is a vacancy in the office of treasurer. For that reason, 

the Commission urges every committee to name (on its Statement of Organization (FEC Form 1) under 

“Designated Agent”) an assistant treasurer who may assume the treasurer’s duties when the treasurer’s 

office becomes temporarily vacant or when the treasurer is unavailable. 102.7(a) and (b). The assistant 

treasurer should be apprised of any filing requirements and, if the committee files electronically, should 

obtain an electronic filing password as well. The committee must report any change in the treasurer’s status 

within 10 days by filing an amendment to the Statement of Organization. 102.2(a)(2).

Committees typically disclose a treasurer’s resignation by naming a replacement. The committee informs 

the FEC of a change in treasurer by filing an amended FEC Form 1, which is signed by the new treasurer. 

However, in some circumstances a treasurer simply resigns without the appointment of a replacement by 

submitting a letter of resignation to the FEC. (Electronic filers use Form 99.) The letter’s stated purpose 

is to amend the committee’s Statement of Organization to reflect the resignation of the treasurer as of a 

particular date.
8

Chapter 2

4. Statement of Candidacy: Line-by-Line Instructions

Line 1. Name and address of the candidate

Enter the name and mailing address of the candidate.

Line 2. Candidate’s FEC identification number

A candidate who has never run before, is running in a different district or is seeking a different federal 

office should leave this line blank. The FEC will assign a candidate identification number upon receipt of 

Form 2.

Candidates who are seeking reelection, and candidates who have terminated a previous candidacy but are 

now running again for the same seat, should use their original identification number.

Line 3. Is this statement new or amended?

Check “New” if you are filing Form 2 for the first time for this particular office and cycle.

Otherwise, check “Amended.”

Lines 4-6. Party affiliation, office sought, state & district of candidate

Provide the requested information.

Line 7. Principal campaign committee

Each candidate for federal office (other than a nominee for the office of Vice President) must designate 

in writing a political committee to serve as his or her principal campaign committee. The name of the 

principal campaign committee must include the name of the candidate. 52 U.S.C. § 30102(e)(4). On Line 7, 

the candidate must indicate the year of the election and the full name and street address of the candidate’s 

principal campaign committee. 101.1(a)

Line 8. Other authorized committees

For Line 8, the candidate must fill in the name and address of any other authorized committees. 101.1(b). 

An authorized committee is any political committee, including the principal campaign committee, 

authorized in writing by a federal candidate to receive contributions and make expenditures on his or her 

behalf. 100.5(f)(1). This includes joint fundraising representatives.

Note that the name of any committee authorized by the candidate must include the name of the candidate. 

52 U.S.C. § 30102(e)(4).

The candidate must sign and date the Statement of Candidacy.

5. Statement of Organization: Line-by-Line Instructions

When registering, a committee must include basic information on the Statement of Organization (FEC 

Form 1). See examples 2–2 through 2–5. The registration statement also serves as the official designation 

of the treasurer and custodian of records, the only two committee officers required under the law. 102.2(a)

(1).
9

Starting the Campaign

Line 1. Name and address of 

committee

Enter the full, official name of the 

committee. The name of a principal 

campaign committee and any other 

authorized committee must include 

the name of the candidate.7 52 U.S.C. § 

30102(e)(4).

The address provided on this line is 

considered the committee’s address of 

record. 102.2(a)(1)(i).

If the committee is the principal 

campaign committee of a candidate 

for the House or the Senate, it must 

disclose its email address. 102.2(a)

(1)(viii). In addition, all committees 

required to file electronically must 

disclose their email addresses. 

102.2(a)(1)(vii). A committee may 

list up to two email addresses on 

the form. The Commission sends 

courtesy reporting reminders and 

other correspondence to the email 

address(es) listed on Form 1.

The committee must disclose the URL 

for its website, if one exists. 102.2(a)

(1)(vii).

Line 2. Date

Enter the date when the committee officially became a political committee—that is, the date when the 

committee exceeded the registration threshold.

Line 3. FEC identification number

The FEC assigns each committee an identification number after the committee has filed a Statement of 

Organization.8 Only committees that have previously filed a Statement of Organization should fill in this 

block with the number that was originally assigned to the committee. New committees should leave this 

line blank—they will be assigned identification numbers when the completed statement has been received. 

Thereafter, the committee must enter the number on all statements and reports. 102.2(c).

7 By contrast, an unauthorized committee (such as a PAC or party committee) may not use the name of a candidate in its name. 52 

U.S.C. § 30102(e)(4).

8 This number is used by the FEC for computer indexing and is not the taxpayer identification number required by the Internal 

Revenue Service. See Appendix G for information on contacting the IRS.

2–2: Committee registration

FEC 

FORM 1

1. NAME OF 

COMMITTEE (in full)

ADDRESS (number and street)

FEC FORM 1

(Revised 06/2012)

Office 

Use 

Only

NOTE: Submission of false, erroneous, or incomplete information may subject the person signing this Statement to the penalties of 52 U.S.C. §30109. 

ANY CHANGE IN INFORMATION SHOULD BE REPORTED WITHIN 10 DAYS.

I certify that I have examined this Statement and to the best of my knowledge and belief it is true, correct and complete.

Type or Print Name of Treasurer

Signature of Treasurer Date

4. IS THIS STATEMENT NEW (N) OR AMENDED (A)

STATEMENT OF 

ORGANIZATION

▼ ▼ ▼

Office Use Only

Example:If typing, type 

over the lines.

(Check if name 

is changed)

For further information contact:

Federal Election Commission

Toll Free 800-424-9530

Local 202-694-1100

COMMITTEE'S E-MAIL ADDRESS

COMMITTEE'S WEB PAGE ADDRESS (URL)

3. FEC IDENTIFICATION NUMBER ▼

C

12FE4M5

M M / D D / Y Y Y Y

2. DATE

M M / D D / Y Y Y Y

CITY STATE ZIP CODE

▼

(Check if address 

is changed)

▼

(Check if address 

is changed)

▼

(Check if address 

is changed)

Optional Second E-Mail Address

Doe for Congress

319 Main St.

Springfield VA 00000

doeforcongress@doeforcongress.com

www.doeforcongress.com

11 11 2020

X

Gottlob Frege

Gottlob Frege 11 11 2020
10

Chapter 2

Line 4. Is this statement new 

or an amendment?

Check “New” if you are filing Form 

1 for the first time. Otherwise, check 

“Amended.” (Amendments are 

discussed in the section “Changes 

in committee and/or contact 

information.”)

Line 5. Type of committee

The committee must identify itself as 

either a principal campaign committee 

or other authorized committee.9 The 

committee must choose only one 

committee type.

The committee must also disclose 

the following information about the 

candidate who authorized it: name, 

party affiliation, office sought and 

state and congressional district (if 

applicable) in which the candidate 

seeks election. 102.2(a)(1)(v).10

Line 6. Affiliated committees

A principal campaign committee 

lists the names and addresses of all 

other committees authorized by the 

candidate as affiliated committees. 

Other authorized committees list only 

the principal campaign committee as 

an affiliated committee. 102.2(b)(1)

(i).

Line 7. Custodian of records

Enter the name, address and committee position of the individual who has actual possession of the 

committee’s financial records. 102.2(a)(1)(iii). The committee’s treasurer, assistant treasurer or another 

person (such as an accountant or bookkeeper) may serve as the custodian of records. (Recordkeeping rules 

are discussed in Chapter 11.)

Line 8. Treasurer and assistant treasurer

Provide the name and mailing address of the treasurer. 102.2(a)(1)(iv). The Commission also urges all 

political committees to name an assistant treasurer (or “designated agent”). Only a registered assistant 

treasurer may sign FEC reports and statements in the treasurer’s absence. 102.7(a). (The treasurer’s 

responsibilities are discussed in detail in Section 3.)

9 See Appendix H, Glossary for distinction.

10 Joint fundraising representatives should refer to Appendix C, Section 5 for information on filing Form 1.

FEC Form 1 (Revised 02/2009) Page 2

5. TYPE OF COMMITTEE

(a) This committee is a principal campaign committee. (Complete the candidate information below.)

(b) This committee is an authorized committee, and is NOT a principal campaign committee. (Complete the candidate

information below.)

(c) This committee supports/opposes only one candidate, and is NOT an authorized committee.

(National, State (Democratic,

(d) This committee is a or subordinate) committee of the Republican, etc.) Party.

(e) This committee is a separate segregated fund. (Identify connected organization on line 6.) Its connected organization is a:

(f) This committee supports/opposes more than one Federal candidate, and is NOT a separate segregated fund or party

committee. (i.e., nonconnected committee)

Name of

Candidate

Name of

Candidate

Candidate

Party Affiliation

State

District

Office

Sought: House Senate President

In addition, this committee is a Lobbyist/Registrant PAC. 

In addition, this committee is a Lobbyist/Registrant PAC. 

In addition, this committee is a Leadership PAC. (Identify sponsor on line 6.)

Corporation Corporation w/o Capital Stock Labor Organization

Membership Organization Trade Association Cooperative

Candidate Committee:

Party Committee:

Political Action Committee (PAC):

Joint Fundraising Representative:

(g) This committee collects contributions, pays fundraising expenses and disburses net proceeds for two or more political 

 committees/organizations, at least one of which is an authorized committee of a federal candidate.

 Committees Participating in Joint Fundraiser

1.

2.

3.

4.

(h) This committee collects contributions, pays fundraising expenses and disburses net proceeds for two or more political 

 committees/organizations, none of which is an authorized committee of a federal candidate.

FEC ID number C

FEC ID number C

FEC ID number C

FEC ID number C

IND

Jane Doe

X

X

VA

12

2–3: Committee registration
11

Starting the Campaign

Line 9. Campaign depository

A committee must list the name and 

address (but not the account number) 

of the campaign depositories it 

maintains for depositing receipts and 

making disbursements. 102.2(a)(1)

(vi); 103.1. Each political committee 

must maintain at least one checking 

account or transaction account at one 

of its depositories. 103.2. (At least one 

depository is required.) The following 

institutions may be designated: 

state banks, national banks and 

depositories insured by the Federal 

Deposit Insurance Corporation or the 

National Credit Union Administration. 

52 U.S.C. §30102(h)(1).

6. Filing Registration 

Forms

Where to file

Hard copy

Principal campaign committees 

of House, Senate and Presidential 

candidates may mail in their original 

Forms 1 and 2 to the Federal Election 

Commission, 1050 First Street, NE, 

Washington, DC 20463. 52 U.S.C. 

§30102(g); 1.2, 105.1, 105.3. The 

address for courier or express delivery 

is 1050 First Street, NE, Washington, 

DC 20002.

Online

Alternatively, principal campaign committees may submit their Forms 1 and 2 electronically using the 

Commission’s online webform system. Note that filing registration forms through this system constitutes an 

electronic filing. Committees that are not required to file electronically, but choose to do so, must continue 

to file electronically for that calendar year. 104.18

Mandatory electronic filing

Under FEC regulations, the Statement of Organization (FEC Form 1) and Statement of Candidacy (Form 2) 

must be filed electronically if the campaign raises or spends more than $50,000 in any calendar year, or has 

reason to expect to do so. 52 U.S.C. §30102(g); 104.18(a).

Committees required to file electronically under 104.18 must also include their email address on their 

Statement of Organization. 102.2(a)(1)(vii).

2–4: Committee registration

FEC Form 1 (Revised 02/2009) Page 3

Write or Type Committee Name

8. Treasurer: List the name and address (phone number -- optional) of the treasurer of the committee; and the name and address of

any designated agent (e.g., assistant treasurer).

CITY STATE ZIP CODE

Full Name

of Treasurer

Mailing Address

Title or Position

Telephone number

6. Name of Any Connected Organization, Affiliated Committee, Joint Fundraising Representative, or Leadership PAC Sponsor

 

Mailing Address

Relationship: Connected Organization Affiliated Committee Joint Fundraising Representative 

CITY STATE ZIP CODE

Custodian of Records: Identify by name, address (phone number -- optional) and position of the person in possession of committee

books and records.

CITY STATE ZIP CODE

Full Name

Mailing Address

Title or Position

Telephone number

7.

 Leadership PAC Sponsor

Doe for Congress

Friends of Jane Doe

229 Hidden View Ln.

Springfield

Herman Lotze

319 Main St.

Springfield

Bookkeeper

Gottlob Frege

319 Main St.

Springfield

Treasurer

00000

00000

00000

703 555 0000

VA

VA

VA

703 555 0000

X
12

Chapter 2

Registration confirmation

The FEC processes each committee’s 

Form 1 upon receipt and sends a 

confirmation email to the address(es) 

provided on the form. The email 

provides the committee’s FEC 

identification number, identifies the 

Campaign Finance Analyst assigned 

to review the committee’s reports and 

provides links to helpful compliance 

information available on the FEC’s 

website. Committees that do not 

provide an email address receive 

comparable information by postal 

mail.

7. Amendments

Changes in committee 

officers and/or contact 

information

A committee must report any 

change or correction of information 

contained in its Statement of 

Organization within 10 days after the 

change. 102.2(a)(2). A committee 

may have to file an amendment, for 

example, to report a new treasurer, a 

new assistant treasurer, a new email 

address, a change of address or a new 

campaign depository. The committee must indicate on FEC Form 1 (or in a letter, if the committee does not 

file electronically) that the statement is an amendment to its registration.

The amount of information required on an amended Statement of Organization depends on whether the 

committee files on paper or electronically. If the committee files electronically, it must submit a fully 

completed Form 1.

In the case of paper filers, the Form 1 or letter needs to include only:

• The name and address of the committee (Form 1, Line 1);

• The date the change took effect (Line 2);

• The FEC ID number (Line 3);

• An indication that the statement is an amendment to the Statement of Organization (Line 4);

• The changed information (appropriate line number); and

• The name and signature of the treasurer (or assistant treasurer) and the date signed. 102.2(a)(2).

2–5: Committee registration

9. Banks or Other Depositories: List all banks or other depositories in which the committee deposits funds, holds accounts, rents

safety deposit boxes or maintains funds.

CITY STATE ZIP CODE

Name of Bank, Depository, etc.

Mailing Address

CITY STATE ZIP CODE

Name of Bank, Depository, etc.

Mailing Address

FEC Form 1 (Revised 02/2009) Page 4

CITY STATE ZIP CODE

Full Name of

Designated

Agent

Mailing Address

Title or Position

Telephone number

Bob Helpsalot

319 Main St.

Springfield

Assistant Treasurer

00000

703 555 0000

VA

Big National Bank

12345 Wilson Blvd.

Arlington VA 00000
13

CHAPTER 3

Understanding Contributions

1. What is a Contribution

A contribution is anything of value given, loaned or advanced to influence a federal election. It is important 

to understand which receipts are considered contributions because:

• Contributions count toward the threshold that determines whether an individual has qualified as a 

candidate under the Federal Election Campaign Act (the Act). 100.3(a).

• Contributions are subject to the Act’s source prohibitions.

• Contributions are subject to the Act’s amount limitations.

Like all receipts, contributions are also subject to the Act’s recordkeeping and reporting requirements. The 

next section describes different types of contributions. (Contribution limits and prohibitions are discussed 

in the chapters that follow.)

2. Types of Contributions

Gifts of money

A contribution of money may be made by check, cash (currency), credit card or other written instrument. 

See 100.52(c). See also AOs 1999-22 (Aristotle Publishing) (contributions made over the internet), 1995-09 

(NewtWatch) (contributions made over the internet), 1991-01 (Deloitte & Touche PAC) (contributions by 

credit card), 1990-04 (American Veterinary Medical Association) (contributions by credit card) and 1978-

68 (Seith for Senate Committee) (contributions by credit card).

In-kind contributions

Definition

Goods or services offered free or at less than the usual charge result in an in-kind contribution. 100.52(d)

(1). Similarly, when a person pays for goods or services on the committee’s behalf, the payment is an inkind contribution. 100.54; 100.52(d)(1). An expenditure made by any person in cooperation, consultation 

or concert with, or at the request or suggestion of a candidate’s campaign is also considered an in-kind 

contribution to the candidate. 109.20. See Appendix D, “Communications.”

Limits

The value of an in-kind contribution—the usual and normal charge—counts against the contribution limit 

as a gift of money does. 100.52(a), (d)(1). Additionally, like any other contribution, in-kind contributions 

count against the contributor’s limit for the next election, unless they are otherwise designated. See Chapter 

4, Section 4 for more information on designating contributions.

Value

Goods (such as facilities, equipment, supplies or mailing lists) are valued at the price the item or facility 

would cost if purchased or rented at the time the contribution is made. For example, if someone donates a 

personal computer to the campaign, the contribution equals the ordinary market price of the computer at 

the time of the contribution.

Services (such as advertising, printing or consultant services) are valued at the prevailing commercial rate at 

the time the services are rendered. 100.52(d)(2) and 100.111(e)(2).
14

Chapter 3

Notifying recipient

The contributor needs to notify the recipient candidate committee of the value of an in-kind contribution. 

The committee’s treasurer needs this information in order to monitor the contributor’s aggregate 

contributions and to report the correct amount.

In-kind contributions designated for more than one election in an election cycle

In AO 1996-29 (Cannon), the Commission determined that the value of an in-kind contribution of used 

computer equipment, received before the primary and designated in writing by the contributors for all 

elections in the cycle, could be allocated among all elections in the same election cycle. The contribution 

was distinguishable from the type of in-kind contribution that is used for one particular election (such as 

printing or mailing costs related to a general election fundraiser). If the candidate had lost the primary 

election, the committee would have had to refund the amount designated for the general election. (In this 

case, the candidate was active in each election within the election cycle.) The total value of the contribution 

could not exceed the contributor’s combined limit for all the elections in the cycle. (The Commission did 

not address the issue of allocating an in-kind contribution over more than one election cycle.)

Exceptions

Under limited exemptions, persons may provide certain goods and services to a committee without making 

contributions. For example, when services are volunteered—not paid for by anyone—the activity is not 

considered a contribution. 100.74. See Chapter 7 for more information.

Bitcoin

The Commission has determined that contributions of bitcoins are “money or anything of value” within the 

meaning of the Act. AO 2014-02 (Make Your Laws PAC).

Value

The value of bitcoin contributions are based on the market value of bitcoins at the time the contribution 

is received. To determine the market value, the committee should first rely on any contemporaneous 

determination provided by the entity that processes the bitcoin contribution. If, however, the contribution 

is made through an entity that does not provide an exchange rate for that contribution (or if no processor 

is involved in the transaction), then the recipient committee may value the contribution using another 

reasonable exchange rate of bitcoins for dollars. See AO 2014-02 (Make Your Laws PAC).

See Chapter 13 for information on reporting contributions of bitcoin.

Proceeds from sales

The entire amount paid to attend a political fundraiser or other political event or to purchase a fundraising 

item sold by a political committee is a contribution and counts against the individual’s contribution limit. 

100.53. For example, if a contributor pays $100 to buy a ticket to a fundraising dinner, the entire $100 

is considered a contribution to the committee, even though the meal may have cost the committee $30. 

Similarly, if a contributor spends $20 to buy a campaign t-shirt that cost the campaign $5, the contributor 

has made a $20 contribution. See also Chapter 14, Section 4, “Sale of Campaign Assets.”

Loans

A loan, including a loan to the campaign from a member of the candidate’s family, is considered a 

contribution to the extent of the outstanding balance of the loan. (Bank loans, however, are not considered 

contributions if made in the ordinary course of business and on a basis that assures repayment. 100.82. See 

Chapter 6, Section 1.) An unpaid loan, when added to other contributions from the same contributor, must 

not exceed the contribution limit. Repayments made on the loan reduce the amount of the contribution. 

Once repaid in full, a loan no longer counts against the contributor’s contribution limit. However, a loan 
15

Understanding Contributions

exceeding the limit is unlawful even if it is repaid in full. Besides being reported as a contribution, a loan 

must be continuously reported as a debt until it is fully repaid. 100.52(a) and (b), 100.111(a) and 104.3(d). 

See Chapter 13, Section 22, for more information on reporting loans.

Endorsements and guarantees of loans

An endorsement or guarantee of a loan, including a loan derived from a candidate’s brokerage account or 

other line of credit, counts as a contribution from the endorser or guarantor to the extent of the outstanding 

balance of the loan. Repayments made on the loan reduce the amount of the contribution. Once the loan 

is repaid in full, the endorsement or guarantee no longer counts against the endorser’s or guarantor’s 

contribution limit. If a written loan agreement does not stipulate the portion for which each endorser or 

guarantor is liable, then individual contributions are calculated by dividing the amount of the loan by the 

number of persons who have endorsed or guaranteed it. 100.52(b)(3).

Candidate’s use of jointly held collateral

A limited exception to this rule is provided when a candidate uses property jointly held with the candidate’s 

spouse to guarantee a bank loan to the campaign and the bank requires the spouse’s signature. Note that this 

exception applies only if the value of the candidate’s share of the property exceeds or equals the amount 

of the loan. This exception also applies when the candidate’s spouse is the endorser, guarantor or co-signer 

of a loan derived from a candidate’s brokerage account, credit card account or other line of credit. For 

unsecured loans, the spouse would not be considered a contributor if the candidate uses, in connection 

with the campaign, only one-half of the available credit. 100.52(b)(4), 100.82(c), 100.83(b). For more 

information, see Chapter 4, Section 9.

Extensions of credit

An extension of credit outside of a creditor’s ordinary course of business is considered a contribution. 

100.55. If the creditor is incorporated, an extension of credit beyond the ordinary course of business would 

result in a prohibited contribution. For more information on when an extension of credit is considered a 

contribution, see Chapter 14, Section 6, “Settling Debts.”

Personal funds of individuals

Funds from the candidate

Unlike the other types of contributions listed here, contributions (including in-kind contributions, loans, 

and advances) made from the candidate’s personal funds to his or her campaign are not subject to any 

limits, though they must still be reported. 110.10; AOs 1991-09 (Hoagland), 1990-09 (Mueller) and 1985-

33 (Collins). For more information, see Chapter 4, Section 9, “Candidate’s Personal Funds.”

Unearned income and fringe benefits

A candidate’s salary or wages earned from bona fide employment are considered his or her personal 

funds. 100.33. However, compensation paid to a candidate in excess of actual hours worked is generally 

considered a contribution from the employer. See AO 2000-01 (Taveras). Moreover, under FEC regulations 

barring personal use of campaign funds, a third party’s payment of a candidate’s personal expenses is 

considered a contribution, unless the payment would have been made irrespective of the candidacy.

To be paid “irrespective of the candidacy,” and thus not considered a contribution, compensation must:

• Result from bona fide employment that is genuinely independent of the candidacy;

• Be exclusively made in consideration for services provided by the employee; and

• Not exceed the amount paid to any other similarly qualified person for the same work over the same 

period of time.

113.1(g)(6). See AOs 2006-13 (Spivack), 2004-17 (Klein), 2004-08 (American Sugar Cane League), 1980-

115 (O’Donnell) and 1979-74 (Emerson).
16

Chapter 3

Note that when a candidate is on leave without pay, the continued payment of fringe benefits (such as 

health insurance and retirement) may also result in contributions from the employer to the campaign. 

114.12(c). (The Commission has made an exception to this rule for employers who had pre-existing 

policies providing for a limited extension of benefits for individuals who take unpaid leave. See AOs 2014-

14 (Trammell), 2014-15 (Brat), 1992-03 (Reynolds Metal).)

Advances by individuals

General rule

When an individual uses personal funds (or personal credit) to pay for a campaign expense, that payment 

is generally an in-kind contribution from that individual. 100.52(a), 116.5(b). For example, an in-kind 

contribution results if a campaign staff member pays for postage, office supplies or campaign materials with 

personal funds. This rule also applies to payments made by volunteers and by the candidate.

Although such advances are considered in-kind contributions until reimbursed, special reporting rules 

apply when individuals pay for campaign expenses and later receive reimbursement from the committee. 

See Chapter 13, Section 15, “Reporting Reimbursed Advances of Personal Funds (Non-Travel).” Travel 

expenses later reimbursed by the committee are treated differently. 116.5. See next section and Chapter 7, 

Section 4, “Travel Cost Exemptions” for more information.

Travel exception

When a campaign staff member, volunteer or the candidate uses personal funds to pay for that individual’s 

own travel expenses (transportation, meals and lodging) incurred on behalf of a candidate, the payments 

are not considered contributions if they fall under one of two exceptions:

Exempt unreimbursed travel: An individual may spend up to $1,000 per candidate, per election, on 

transportation expenses without making a contribution, and volunteers may spend unlimited amounts 

on meals and lodging in connection with volunteer activity. 100.79.

Reimbursed travel: Any other payments by individuals for travel expenses are not considered 

contributions if the committee reimburses them within specified time limits. 116.5(b). See Chapter 7, 

Section 4, “Travel Cost Exemptions” for more information.

Congressional staff

The official staff of members of Congress cannot contribute to their employing member’s campaign. See 

18 U.S.C. §603. As such, it is important for those individuals to avoid advancing any funds to the campaign 

(e.g., buying stamps for a campaign mailing). See also 18 U.S.C. §602.

For more information, contact the Senate Select Committee on Ethics or the House Committee on Ethics 

(see Appendix G). For information about political activity by federal employees, contact the U.S. Office of 

Special Counsel at (202) 254-3600.

Coordinated communications

If a committee, group or individual pays for a communication that is coordinated with a campaign or a 

candidate, the communication may result in an in-kind contribution to the campaign committee. For more 

information on determining whether a communication is coordinated, see Appendix D.

Earmarked contributions and bundling

An earmarked contribution is one which the contributor directs (either orally or in writing) to a candidate 

through an intermediary or conduit. 110.6(b). Special rules govern this type of transaction; see Appendix 

A. Contributions bundled by lobbyists require additional disclosure, as described in Appendix F.
17

CHAPTER 4

Contribution Limits

Under the Federal Election Campaign Act (the Act) contributions are subject to limits. This chapter examines 

the rules concerning the limits placed on contributions to a candidate’s campaign. The limits apply to 

all types of contributions (except contributions made from a candidate’s personal funds, as explained in 

Chapter 3).

The chart on the next page summarizes the Act’s contribution limits. It is important to note that a campaign 

is prohibited from retaining contributions that exceed the limits. 110.9. In the event that a campaign receives 

excessive contributions, it must follow special procedures for handling such funds. See “Remedying an 

Excessive Contribution” in Section 7 of this chapter.

1. Overview of Limits

This section outlines the limits the Act places on contributions to a candidate’s campaign. The term 

campaign is used in this guide to mean a candidate for a specified federal office, his or her authorized agents, 

the principal campaign committee and any other authorized committees.

$2,900 per election1

Under the Act, individuals and groups (such as partnerships, sole proprietorships, certain LLCs, Indian 

tribes and other groups that are not prohibited from making contributions to candidates) may contribute a 

maximum of $2,900 per election to a candidate’s campaign. This limit also applies to: 

• Contributions from nonmulticandidate and nonfederal political committees;

• Contributions from the members of a candidate’s family (e.g., spouse, parent) (110.1(a) and (b)(1)); 

and

• Contributions from nonfederal campaign committees (see “Contributions from other candidates”).

$5,000 per election—multicandidate committees

Political committees that qualify as multicandidate committees have a higher contribution limit of $5,000 

per election to a candidate’s campaign. 110.2(a) and (b)(1). To qualify as a multicandidate committee, a 

political committee must have:

• Been registered with the FEC for at least six months;

• Received contributions for federal elections from more than 50 contributors; and

• Made contributions to at least five candidates for federal office.2 100.5(e)(3).

When making a contribution to a candidate’s campaign, a multicandidate PAC or party committee must 

notify the campaign in writing that it has qualified for multicandidate committee status. 110.2(a)(2). (The 

notice may be pre-printed on the committee’s checks, letterhead or other appropriate materials.3) If the 

1 The limit is indexed for inflation in odd-numbered years. 110.1(a) and (b)(1); 110.17(b).

2 State party organizations are not required to meet this third requirement. Also, principal campaign committees of active candidates 

cannot qualify as multicandidate committees. 102.12(c) and 102.13(c). The principal campaign committee of a former candidate may, 

however, become a multicandidate committee. AOs 2004-03 (Dooley for the Valley), 1993-22 (Roe), 1988-41 (Stratton) and 1985-30 

(Holt).

3 See the Explanation and Justification to Rules on Contributions by Multicandidate Political Committees, 58 Fed. Reg. 42172, 42173 

(August 6, 1993), available on FEC.gov.
18

Chapter 4

Contribution limits

for 2021–2022

Recipient

Candidate 

committee

PAC† (SSF and 

nonconnected)

Party 

committee: 

state/district/

local

Party 

committee:

national

Additional 

national party 

committee 

accounts‡

Donor

Individual $2,900* per 

election $5,000 per year $10,000 per year (combined)

$36,500* 

per year

$109,500* per 

year, per year

Candidate 

committee

$2,000 per 

election $5,000 per year Unlimited transfers

Unlimited 

transfers

PAC:

multicandidate

$5,000 per 

election $5,000 per year $5,000 per year (combined)

$15,000 per 

year

$45,000 per 

year, per year

PAC:

nonmulticandidate

$2,900* per 

election $5,000 per year $10,000 per year (combined)

$36,500* 

per year

$109,500* per 

year, per year

Party committee: 

state/district/local

$5,000 per 

election $5,000 per year Unlimited transfers

Unlimited 

transfers

Party committee:

national

$5,000 per 

election** $5,000 per year Unlimited transfers

Unlimited 

transfers

* Indexed for inflation in odd-numbered years.

†“PAC” here refers to a committee that makes contributions to other federal political committees. Independent-expenditureonly political committees (sometimes called “Super PACs”) may accept unlimited contributions, including from corporations 

and labor organizations.

‡ The limits in this column apply to a national party committee’s accounts for: (i) the presidential nominating convention; 

(ii) election recounts and contests and other legal proceedings; and (iii) national party headquarters buildings. A party’s 

national committee, Senate campaign committee and House campaign committee are each considered separate national 

party committees with separate limits. Only a national party committee, not the parties’ national congressional campaign 

committees, may have an account for the presidential nominating convention.

**Additionally, a national party committee and its Senatorial campaign committee may contribute up to $51,200 combined 

per campaign to each Senate candidate. 110.2(e).

Table 1: Contribution limits for 2021–2022 federal elections
19

Contribution Limits

contributing committee fails to provide this notification, the candidate committee’s treasurer should verify 

whether that committee has qualified in order to avoid accepting an excessive contribution. 103.3(b). 

Multicandidate status can be verified by consulting the FEC’s campaign finance data website. Committees 

that have satisfied the criteria for multicandidate status and have filed FEC Form 1M (Notification of 

Multicandidate Status) will be identified as “qualified.” 

$51,200 national party committee limit for Senate candidates

A national party committee and its Senatorial campaign committee (if applicable) may contribute up to 

$51,200 combined per campaign to each Senate candidate. Unlike other candidate contribution limits, this 

limit applies to the total contributions made to a Senate candidate by those party committees for the entire 

campaign period (the primary and general elections). 110.2(e). This limit is indexed for inflation in oddnumbered years.

$100 limit on cash contributions

A campaign may not accept more than $100 in cash from a particular source with respect to any campaign 

for nomination for election, or election to federal office. 110.4(c).

$50 limit on anonymous contributions

An anonymous contribution of cash is limited to $50. Any amount in excess of $50 must be promptly 

disposed of and may be used for any lawful purpose unrelated to any federal election, campaign or 

candidate. 110.4(c)(3).

Contributions from other candidates

A candidate’s authorized committees may accept a contribution of up to $2,000 per election from the 

authorized committee of another federal candidate. 102.12(c)(2) and 102.13(c)(2).

The contribution limit for contributions from a nonfederal candidate’s campaign is $2,900 per election. 

See 110.1(b)(1); 110.17(b). However, a contribution of more than $1,000 may trigger registration by the 

nonfederal campaign as a federal political committee. 100.5(a). For more information and other applicable 

restrictions (such as the requirement that the funds given be federally permissible), see “Contributions 

from Unregistered Organizations” in Chapter 10, Section 1.

Affiliated committees—shared limit

Political committees established, financed, maintained or controlled by the same person, organization or 

group are affiliated. 110.3(a) and (b). This definition applies to all types of political committees, including 

nonconnected committees, party committees, corporate/labor PACs and authorized committees. This is 

important because affiliated committees that make contributions to candidate committees share one overall 

contribution limit, per candidate, per election. See 110.3(a).

Party committees

Each state party committee has its own contribution limit, but local party committees within a state are 

presumed to be affiliated with the state party committee.4 This means that contributions from those 

local party committees that are required to register as federal political committees count against the state 

committee’s limit. 110.3(b)(1)(ii) and (3). See AOs 2005-02 (Corzine II) and 1999-04 (Republican Party of 

Minnesota).

4 A local party committee may be considered independent of the state party committee if it can meet certain standards. See 110.3(b)

(3)(i) and (ii). See also AOs 1999-04 (Republican Party of Minnesota) and 1978-09 (Republican State Central Committee of Iowa).
20

Chapter 4

Note, however, that the national party committee, the House campaign committee and the Senate campaign 

committee are each considered a separate committee, with separate contribution limits (except for the 

special national party committee limit of $51,200 for Senate candidates, as explained previously). 110.2(e) 

and 110.3(b)(2).

Corporate/labor/membership organization PACs

All separate segregated funds (also called political action committees or PACs) established, financed, 

maintained or controlled by the same corporation or labor organization are affiliated. For example:

• PACs established by a parent corporation and its subsidiaries are affiliated.

• PACs established by a national or international union and its local unions are affiliated.

• PACs established by a federation of national or international unions and the federation’s state and local 

central bodies are affiliated.

• PACs established by an incorporated membership organization and its related state and local entities are 

affiliated.

100.5(g)(2) and (3); 110.3(a)(1)(ii) and (2).

When committees are not automatically affiliated under these conditions, the Commission may 

nevertheless conclude that two or more committees are affiliated based on factors listed in the regulations. 

100.5(g)(4)(ii)(A)-(J) and 110.3(a)(3)(ii)(A)-(J). The Commission makes these decisions, through 

advisory opinions, on a case-by-case basis. For examples, see AOs 2009-18 (Penske Truck Leasing), 2006-

12 (IAM), 2005-03 (ACOG), 2004-32 (Spirit), 2002-11 (Mortgage Bankers) and 2001-07 (NMC PAC) (plus 

opinions cited within those AOs).

Authorized committees

An authorized committee, however, can be affiliated only with another authorized committee of the 

same candidate. 100.5(g)(5) and 110.3(a)(1)(i). Note that, by definition, an unauthorized committee 

sponsored by an officeholder (i.e., a “leadership PAC”) is not considered to be affiliated with any authorized 

committees sponsored by the same individual. 100.5(e)(6) and (g)(5).

Unregistered local party organizations

Local party organizations may contribute an aggregate of $1,000 to federal candidates (assuming no other 

federal expenditures are made) without triggering a registration requirement with the FEC. 100.5(a).

The organization must be able to show that the contribution was made with funds permissible under the 

Federal Election Campaign Act. 102.5. Prior to crossing the registration threshold, the local organization 

does not share a contribution limit with the state party committee. AOs 2005-02 (Corzine II) and 1999-04 

(Republican Party of Minnesota).

Partnerships

Partnerships are permitted to make contributions up to $2,900 per candidate per election according to 

special rules. 110.1(e) and (k)(1). For details, see Appendix B.

Limited liability companies

Corporation vs. partnership

For purposes of contribution limitations and prohibitions, a limited liability company (LLC) is treated as 

either a corporation or a partnership.
21

Contribution Limits

An LLC is treated as a corporation if:

• It has chosen to file, under Internal Revenue Service (IRS) rules, as a corporation; or

• It has publicly traded shares. 110.1(g)(3).

An LLC is treated as a partnership if:

• It has chosen to file, under IRS rules, as a partnership; or

• It has made no choice, under IRS rules, as to whether it is a corporation or a partnership. 110.1(g)(2).

If an LLC is treated as a corporation, it is prohibited from making contributions to candidate committees, 

but it can establish an SSF (see Chapter 5 for general information on the corporate prohibition). It may 

also give money to Independent expenditure-only PACs. If it is considered a partnership, it is subject to the 

contribution limits for partnerships outlined in Appendix B. 110.1(g).

Single member LLC

If an LLC with a single natural person member has not chosen corporate tax treatment, it may make 

contributions; the contributions will be attributed to the single member, not the LLC. 110.1(g)(4).

Notifying recipient committee

An LLC must, at the time it makes a contribution, notify the recipient committee:

• That it is eligible to make the contribution; and

• How the contribution is to be attributed among members.

This requirement will prevent the recipient committee from inadvertently accepting an illegal contribution. 

110.1(g)(5).

Minors

An individual who is under 18 years old may make contributions to candidates and political committees, 

subject to the limit of $2,900 per election, if:

• The decision to contribute is made knowingly and voluntarily by the minor;

• The funds, goods or services contributed are owned or controlled by the minor, proceeds from a trust for 

which he or she is a beneficiary, or funds withdrawn by the minor from a financial account opened and 

maintained in his or her name; and

• The contribution is not made using funds given to the minor as a gift for the purpose of making the 

contribution, and is not in any way controlled by another individual. 110.19.

Trusts

A political committee may accept contributions from an individual’s estate made through a testamentary 

trust, subject to the same limitations and prohibitions that were applicable to the decedent during the 

decedent’s lifetime.5 Note that the committee must disclose the name of the both the trust and the name of 

the decedent on its report. See AO 2004-02 (NCEC). 

Contributions may be made from a living (inter vivos) trust as long as the trust’s beneficial owner has control 

over the use of the trust funds. The contribution should be reported as a contribution from the beneficial 

owner (as signor on the contribution), rather than from the trust. See AO 1999-19 (Andrea Ellis).6

5 A political committee may only accept contributions from trusts in which neither the committee nor any officer, director, employee, 

member, agent, or affiliated organization of the political committee serves as a trustee or exercises any control over any undistributed 

trust corpus or interest amount.

6 Special requirements apply to contributions from trusts to Presidential campaigns that are eligible for federal matching payments. 

9034.2(c)(2).
22

Chapter 4

2. How Limits Work

The limits on contributions to candidates apply separately to each federal election in which the candidate 

participates. A primary, general, runoff and special election are each considered a separate election with a 

separate limit.7 100.2. 

Under certain circumstances, additional elections may be called that bring about additional per election 

contribution limits. For example, a separate election may occur when a judicial decision creates a new 

election. See AOs 2016-09 (Martins for Congress); 2016-03 (Holding for Congress); 2006-26 (Texans for 

Henry Bonilla). A special election may also involve separate primary, general and/or runoff elections, 

each with a separate contribution limit.8 And in some cases, a party caucus or convention is considered an 

election, as explained in the next section. Each of these elections would be considered a separate election 

with a separate contribution limit.

Party caucus or convention

A party caucus or convention constitutes an election only if it has the authority under relevant state law 

to select a nominee for federal office. (Notable examples of these types of conventions are those held in 

Connecticut, Utah and Virginia.) Otherwise, there is no separate limit for a caucus or convention; it is 

considered part of the primary process. When the caucus or convention does constitute a primary election, 

reports must be filed for the convention as they would for the primary. 100.2(c)(1) and (e). See also, for 

example, AOs 1992-25 (Owens), 1986-21 (Owens) and 1986-17 (Green); cf. AO 1979-71 (PASPAC). See 

Chapter 12 for information on filing reports.

Candidates who lose in the primary

A candidate is entitled to an election limit only if he or she seeks office in that election. Thus, a candidate 

who loses the primary (or otherwise does not participate in the general election) does not have a separate 

limit for the general. If a candidate accepts contributions for the general election before the primary is held 

and loses the primary (or does not otherwise participate in the general election), the candidate’s principal 

campaign committee must refund, redesignate or reattribute the general election contributions within 60 

days of the primary or the date that the candidate publicly withdraws from the primary race.9 110.1(b)

(3) and 110.2(b)(5). See also in this chapter, Section 4, “Designated and Undesignated Contributions” and 

Section 8, “Contributions to Retire Debts.”

Independent and non-major party candidates

Even when independent and non-major party candidates are not involved in an actual primary, they are 

entitled to a primary limit. They may choose one of the following dates to be their “primary” date, and, until 

that date, they may collect contributions that count towards the contributor’s primary limits.

• The last day on which, under state law, a candidate may qualify for a position on the general election 

ballot; or

• The date of the last major primary election, caucus or convention in that state.

Non-major party candidates may also choose the date of the nomination by their party as their primary 

7 Presidential campaigns should note that all Presidential primary elections held during a calendar year are considered one election for 

the purposes of the contribution limits. 110.1(j)(1).

8 In AO 2009-15 (Bill White for Texas), the Commission concluded that under certain circumstances an authorized committee may 

accept contributions that may be used in a special or emergency election or runoff, even though an election has not been scheduled 

and may not occur.

9 In AO 2008-04 (Dodd for President), the Commission determined that the authorized committee of a Presidential candidate 

receiving primary matching funds may issue refunds or obtain redesignations to his or her Senate campaign for contributions made in 

connection with the general election.
23

Contribution Limits

date. 100.2(c)(4). Whichever date they choose, the candidate’s campaign must file all pre-election reports 

and notices associated with that election date.

Primary vs. general election

Campaigns must adopt an accounting system to distinguish between contributions made for the primary 

election and those made for the general election, as discussed in Chapter 10, Section 1, “Fundraising.” 

102.9(e).10 As previously noted, should the candidate lose the primary election, contributions accepted for 

the general election must be refunded, redesignated or reattributed within 60 days and may not be used to 

repay primary election debt. AO 1986-17 (Green). Therefore, candidate committees should ensure they have 

enough cash on hand to make those refunds if needed.

Candidates running in the general election, however, may spend unused primary contributions for general 

election expenses. The contributions would continue to apply toward the contributors’ limits for the primary. 

110.3(c)(3). In addition, the campaign of a candidate running in the general election may use general 

election contributions for primary election debts; the contributions would still count against the contributor’s 

general election limits. 110.1(b)(3)(iv). 

Unopposed candidates; elections not held

A candidate is entitled to a separate contribution limit even if:

• The candidate is unopposed in an election;

• A primary or general election is not held because the candidate is unopposed;11 or

• The general election is not held because the candidate received a majority of votes in the previous 

election.

The date on which the election would have been held is considered the date of the election. 110.1(j)(2) and 

(3). The campaign must file pre-election reports and, in the case of a general election, a post-election report. 

AO 1986-21 (Owens). See also Chapter 12, Section 3, “When to Report.”

Recounts

A federal campaign may establish a recount fund either as a separate bank account of the candidate’s 

authorized committee or as a separate entity. Although they are not considered contributions under the Act, 

any funds solicited, received, directed, transferred or spent in connection with a recount are subject to the 

amount limitations, source prohibitions and reporting requirements of the Act. See 52 U.S.C. §30125(e). This 

means that the normal contribution limits, reporting requirements and source restrictions apply. 

The Commission has addressed the use of funds raised for recount purposes in AO 2010-14 (DSCC) 

(permitting the use of such funds before an election for certain recount-related purposes), AO 2010-

18 (DFL) (permitting the redesignation of excess recount funds to a state party committee’s federal 

account), and AO 2019-02 (Nelson) (permitting donation of excess recount funds to charity and national 

party’s recount account). Committees must disclose funds received for a recount as “Other Receipts” and 

funds spent as “Other Disbursements.” For more information and reporting instructions, see AO 2006-24 

(Republican and Democratic Senatorial Committees) and Chapter 13, “Completing FEC Reports.”

10 In AO 2007-03 (Obama), the Commission concluded that a Presidential candidate could solicit and receive private contributions for 

the 2008 Presidential general election without losing eligibility to receive public funding if the candidate received his party’s nomination 

for President, provided that the campaign (1) deposited and maintained all private contributions designated for the general election in a 

separate account; (2) refrained from using these contributions for any purpose; and (3) refunded the private contributions in full if the 

candidate ultimately decided to receive public funds.

11 A primary election that is not held because the candidate was nominated by a caucus or convention with authority to nominate is not 

a separate election with a separate contribution limit. 110.1(j)(4).
24

Chapter 4

3. Contributions to Unauthorized Committees

If a contributor makes a contribution to a committee not authorized by any candidate and knows that a 

substantial portion of the contribution will be contributed to or spent on behalf of a particular candidate, 

the contribution counts against the contributor’s per election limit with respect to that candidate. 110.1(h).

4. Designated and Undesignated Contributions

The Commission strongly recommends that campaigns encourage contributors to designate their 

contributions for specific elections. Designated contributions ensure that the contributor’s intent is 

conveyed to the candidate’s campaign. In the case of contributions from political committees, written 

designations also promote consistency in reporting and thereby avoid the possible appearance of excessive 

contributions on reports.

Effect of designating vs. not designating

Designated contributions count against the donor’s contribution limits for the election that is named. 

Undesignated contributions count against the donor’s contribution limits for the candidate’s next election. 

110.1(b)(2). For example:

• An undesignated contribution made12 after the candidate has won the primary, but before the general 

election, applies toward the contribution limit for the general election.

• In the case of the candidate who has lost the primary, an undesignated contribution made after the 

primary automatically applies toward the limit for the next election in which the candidate runs for 

federal office.

If the candidate does not plan to run for federal office in the future, the committee may:

• Presumptively redesignate the contribution to retire any net primary debts it may have (110.1(b)(5)(ii)

(C); see “Remedying excessive contributions” for proper procedure); or

• Request a written redesignation from the contributor to retire net debts from a previous election 

cycle.13

Otherwise, the committee must return or refund the contribution.

For additional information on presumptive redesignation, see Section 7 of this chapter, “Remedying an 

Excessive Contribution.” See Section 8 for information on calculating net debts.

How contributions are designated

Contributors designate contributions by indicating in writing the specific election to which they intend a 

contribution to apply. 110.1(b)(2)(i). Contributors may make this written designation on the check (or 

other signed written instrument) or in a signed statement accompanying the contribution. 110.1(b)(4). A 

designation also occurs when the contributor signs a form supplied by the candidate. 110.1(b)(4); see also 

AO 1990-30 (Helms).

Campaign must retain designations

The campaign must retain copies of contribution designations for three years. If the designation appears on 

12 See Section 5 for an explanation of when a contribution is “made.”

13 Note that if a contribution designated to retire the net debt of a previous campaign exceeds the amount of the net debt, the 

contribution must be returned, refunded, redesignated or reattributed. Contributions can be designated for debt retirement only if net 

debt exists and if the contributor has not already met the contribution limit for that election. 110.1(b)(3)(i).
25

Contribution Limits

the check (or other written instrument), the campaign must retain a full-size photocopy. 102.9(c) and (f); 

110.1(l)(1).

5. Date Contribution is Made vs. Date of Receipt

The date a contribution is made by the contributor and the date the contribution is received by the 

campaign are significant for purposes of the contribution limits. It is important to understand the 

distinction.

Date contribution is made

The date a contribution is made is the date the contributor relinquishes control over it. 110.1(b)(6). For 

example:

• A hand-delivered contribution is considered made on the date it is delivered by the contributor to the 

campaign. 110.1(b)(6).

• A mailed contribution is made on the date of the postmark. 110.1(b)(6). (If a campaign wishes to rely 

on a postmark as evidence of the date a contribution was made, it must retain the envelope or a copy of 

it.) 110.1(l)(4).

• An in-kind contribution is made on the date that the goods or services are provided by the contributor. 

110.1(b)(6). See AOs 2004-36 (Risley) and 1996-29 (Cannon).

• A contribution made via the internet is considered made on the date the contributor electronically 

confirms making the transaction. AO 1995-09 (NewtWatch).

• An earmarked contribution is considered made during the election cycle in which the contribution is 

actually made, regardless of the year in which the election is held. See AOs 2008-08 (Zucker) and 2006-

30 (footnote 5) (ActBlue). (The conduit must forward this information to the campaign. See Appendix 

A for more information.)

Date contribution is received

The date of receipt is the date the campaign (or a person acting on the campaign’s behalf) actually receives 

the contribution. 102.8(a). This is the date used by the campaign for reporting purposes, but it also affects 

the application of the net debts outstanding rule (discussed in Section 8 of this chapter).

Contributions charged on credit cards

When 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. The 

treasurer should retain a copy of the authorization form in the committee’s records. See AOs 1995-09 

(NewtWatch) and 1990-04 (American Veterinary Medical Association). 

In-kind contributions

The date of receipt for an in-kind contribution is the date the goods or services are provided to the 

committee, even if the contributor pays the bill for the goods or services after they are provided. See 

110.1(b)(6).

Effect of dates on undesignated contributions

The date an undesignated contribution is made determines which election limit it counts against. The date 

of receipt, however, does not affect the application of the contribution limits. An undesignated contribution 

made on or before Election Day counts against the donor’s limit for that election, even if the date of 

receipt is after the election and even if the campaign has no net debts outstanding. On the other hand, an 

undesignated contribution made after an election counts against the donor’s limit for the candidate’s next 

election. 110.1(b)(2)(ii).
26

Chapter 4

Effect of dates on designated contributions

Both the date a contribution is made and the date of receipt affect the application of the net debts 

outstanding rule to a designated contribution. The date the contribution is made determines whether the 

rule will apply, while the date of receipt governs whether the contribution is acceptable under the rule. For 

example, a contribution designated for the primary and made before that election will not be subject to the 

net debts outstanding rule, even if the campaign receives the contribution after the primary. By contrast, a 

contribution designated for—but made after—the primary is acceptable only to the extent the campaign has 

net debts outstanding for the primary on the date of receipt. 110.1(b)(3)(i) and (iii). See Section 8 of this 

chapter.

Date of deposit

While all contributions must be deposited within 10 days, the date of deposit is not used for reporting or 

contribution limit purposes.

6. Joint Contributions

A joint contribution is a contribution that is made by more than one person using a single check or other 

written instrument. Although each individual has a separate contribution limit, joint contributors may 

combine their contributions in a joint contribution (for example, one check for $5,800 representing 

contributions from two individuals for a candidate’s primary election) as long as both contributors sign the 

check or an attached statement. 110.1(k). Note that a joint contribution must represent the personal funds 

of each contributor because contributions made in the name of another are prohibited. See 110.4(b).

Each contributor must sign the check

When making a joint contribution, each contributor must sign the check (or other written instrument) or 

a statement that accompanies the contribution. 110.1(k)(1). If the check or an accompanying statement 

of attribution is not signed by each contributor, the entire contribution will be attributed only to the party 

who signed the check. 104.8(c). However, under certain circumstances the committee may presumptively 

reattribute the excessive portion of a contribution. See Section 7 on “Reattribution.”

Exception: partnerships and LLCs

Contributions from partnerships and certain LLCs are not considered joint contributions but do trigger 

special attribution requirements. See Appendix B.

Attribution

If the check or statement does not indicate how much should be attributed to each donor, the recipient 

committee must attribute the contribution in equal portions. 110.1(k)(1) and (2). For example, if a 

committee receives a $1,000 joint contribution signed by two individuals but with no written attribution, 

the committee must attribute a $500 contribution to each donor.

A campaign may request that a contribution be reattributed, as explained in next section.

7. Remedying an Excessive Contribution

When a committee receives an excessive contribution—one which exceeds the contributor’s limit or the 

campaign’s net debts outstanding for an election—the committee may remedy the violation by refunding 

the excessive amount or by seeking a redesignation or reattribution of it within 60 days.

Step-by-step procedures for obtaining a redesignation or reattribution are explained in this section.
27

Contribution Limits

Redesignation

By contributor

With a redesignation, the contributor instructs the committee to use the excessive portion of a contribution 

for an election other than the one for which the funds were originally given. For example, the contributor 

may redesignate the excessive portion of a contribution made for the primary election so that it counts 

against his or her limit with respect to the general election (provided the contributor has not already 

contributed the maximum for the general election).

When requesting a redesignation, the committee must inform the contributor that he or she may, 

alternatively, request a refund of the excessive amount. 110.1(b)(5).

Presumptive redesignation by committee

Under certain circumstances, the committee may make a presumptive redesignation of an excessive 

contribution. When an individual or a non-multicandidate committee makes an excessive contribution to a 

candidate’s authorized committee, the campaign may presumptively redesignate the excessive portion to the 

general election if the contribution:

• Is made before that candidate’s primary election;

• Is not designated in writing for a particular election;

• Would be excessive if treated as a primary election contribution; and

• As redesignated, does not cause the contributor to exceed any other contribution limit. 110.1(b)(5)(ii)

(B)(1)-(4).

Also, the excessive portion of an undesignated contribution made after the primary, but before the general 

election, may be automatically applied to the primary if the campaign’s net debts outstanding from the 

primary equal or exceed the amount redesignated. 110.1(b)(5)(ii)(C). See Section 8 in this chapter. Note that 

a contribution that is designated in writing for a particular election may not be presumptively redesignated to 

another election. In this case, the committee must request a written redesignation. 

The committee is required to notify the contributor in writing of the presumptive redesignation within 60 

days of the treasurer’s receipt of the contribution and must offer the contributor the option to receive a 

refund instead. 110.1(b)(5)(ii)(C). 

It is important to note that presumptive redesignations may be made only within the same election cycle. 

Also, presumptive redesignation is not an option when the contributor is a multicandidate committee.

Reattribution

By contributor

With a reattribution, the contributor instructs the committee in writing to attribute the excessive portion of 

a joint contribution to another individual. For example, if the committee receives an excessive contribution 

drawn on a joint checking account, but signed by only one account holder, the committee may seek a 

reattribution signed by each contributor of the excessive amount to the other account holder. 110.1(k)(3). 

(A joint contribution may also be reattributed so that a different amount is attributed to each contributor.14) 

Note that a joint contribution must represent the personal funds of each contributor because contributions 

made in the name of another are prohibited. See 110.4(b).

When requesting reattributions, the committee must also inform contributors that they may, alternatively, 

ask for a refund of the excessive portions of their contributions. 110.1(k)(3).

14 See the Explanation and Justification published with the final rule, Contribution and Expenditure Limitations and Prohibitions; 

Contributions by Persons and Multicandidate Political Committees, 52 Fed. Reg. 760, 765-766 (Jan. 9, 1987), available on FEC.gov.
28

Chapter 4

Presumptive reattribution by committee

When a committee receives an excessive contribution made via a written instrument with more than one 

individual’s name imprinted on it, but only one signature, the committee may attribute the permissible 

portion to the signer. The committee may make a presumptive reattribution of the excessive portion to the 

other individual whose name is imprinted on the written instrument, without obtaining a second signature, 

so long as the reattribution does not cause the contributor to exceed any other contribution limit. 110.1(k)

(3)(ii)(B)(1).

The committee is required to notify the contributors in writing of the presumptive reattribution within 60 

days of the treasurer’s receipt of the contribution, and must offer the contributors the option to receive a 

refund if it was not intended to be a joint contribution. 110.1(k)(3)(ii)(B)(2)-(3).

When to request redesignations and reattributions

In many circumstances, the committee will be able to presumptively redesignate or reattribute 

contributions. For all other circumstances, contributions can be redesignated or reattributed only by the 

individual contributor. 

A committee may ask a contributor to redesignate and/or reattribute a contribution, for example, when the 

committee receives:

• A designated or undesignated contribution that exceeds the donor’s limit. 110.1(b)(5)(i)(A) and (C).

• A designated or undesignated contribution for an election in which the candidate is not running. For 

example, a contribution that was designated for the general but was received before the primary may 

be redesignated for a future primary if the candidate loses the primary or otherwise does not run in 

the general election. See 102.9(e); see also AOs 1996-29, fn. 5 (Cannon), 1992-15 (Russo) and 1986-17 

(Green).

• A contribution that is designated for, but made after, an election and that exceeds the campaign’s net 

debts outstanding for that election. 110.1(b)(3)(i) and (5)(i)(B).

• An undesignated contribution (which normally applies to the candidate’s upcoming election) that 

the committee wants to use to retire debts of a previous election. Note that, if it is redesignated, the 

contribution then counts against the donor’s contribution limits for that previous election. 110.1(b)(5)

(i)(D). 

Procedures for obtaining redesignations and reattributions from contributors

The committee treasurer is the person ultimately responsible for complying with the procedures outlined in 

this section. 103.3(a) and (b).

Step 1: Deposit contribution

A committee must deposit contributions within 10 days of the treasurer’s receipt. (If a contribution is not 

deposited, it must be returned to the contributor within 10 days of receipt.) 103.3(a).

Step 2: Determine whether excessive

The committee must determine whether a contribution exceeds the donor’s limit or the campaign’s net 

debts outstanding. The Commission encourages committees to make this determination within 30 days of 

receiving the contribution. This allows a committee sufficient time to request and receive a redesignation 

and/or reattribution within the 60-day limit, as explained in the next step.

Step 3: Be prepared to make refund

When a committee deposits contributions that may exceed the limits or net debts outstanding for an 

election, the committee must not spend the funds because they may have to be refunded. To ensure that 

the committee will be able to refund the contribution in full, the committee may either maintain sufficient 

funds in its regular campaign depository or establish a separate account used solely for the deposit of 
29

Contribution Limits

possibly illegal contributions. 103.3(b)(4). Furthermore, the committee must keep a written record noting 

the reason a contribution may be excessive and must include this information when reporting the receipt of 

the contribution. 103.3(b)(5).

Step 4: Request redesignation and/or reattribution

When requesting a redesignation, the committee asks the contributor to provide a written, signed 

redesignation of the contribution for another election. The request must also state that the donor may 

receive a refund of the excessive portion of the contribution if he or she does not wish to redesignate it. 

110.1(b)(5)(ii)(A).15

When requesting a reattribution, the committee asks the contributor whether the contribution was 

intended to be a joint contribution from more than one person. Alternatively, if the original contribution 

was a joint contribution, the committee requests that the contributors adjust the amount attributable 

to each.16 In either case, the committee should inform the contributors that they must each sign the 

reattribution. The request must notify each contributor that, instead of reattributing the contribution, he or 

she may seek a refund of the portion of the contribution that exceeds the limits or the campaign’s net debts 

outstanding. 110.1(k)(3)(ii)(A).

Step 5: Redesignation/reattribution made or make refund within 60 days

Within 60 days after the date of the committee’s receipt of the contribution either:

• The contributor must provide the committee with a redesignation or reattribution, or

• The committee must refund the excessive portion of the contribution.

103.3(b)(3).

A contribution is properly redesignated if, within the 60-day period, the contributor provides the 

committee with a written, signed statement redesignating the contribution for a different election. 110.1(b)

(5)(ii)(A).

A contribution is properly reattributed if, within the 60-day period, the contributors provide the committee 

with a written statement reattributing the contribution. The statement must be signed by all contributors 

and must indicate the amount attributable to each donor. (If the contributors do not specify how to divide 

the contribution, the committee must attribute the contribution equally among the contributors.) 110.1(k)

(2) and (3)(ii)(A). 

Step 6: Keep records and report

The committee must keep documentation for each redesignation and reattribution to verify that it was 

received within the 60-day time limit. Documentation for a redesignation or reattribution must include one 

of the following:

• A copy of the postmarked envelope bearing the contributor’s name, return address or other identifying 

code;

• A copy of the signed statement redesignating or reattributing the contribution with a date stamp 

showing the date of the committee’s receipt; or

• A copy of the written redesignation or reattribution dated by the contributor.

110.1(l)(6).

The documentation relating to a redesignation or reattribution must be retained for three years. 102.9(c).

15 Redesignations may be made electronically provided that the method offers a sufficient degree of assurance of the contributor’s 

identity and intent to redesignate, and the committee retains a record of the redesignation in a manner consistent with the 

recordkeeping requirements in 110.1(1). For more information, see the FEC’s Interpretive Rule Regarding Electronic Contributor 

Redesignations, (76 Fed. Reg. 16233 (March 23, 2011)) on FEC.gov.

16 See the Explanation and Justification published with the final rule, Contribution and Expenditure Limitations and Prohibitions; 

Contributions by Persons and Multicandidate Political Committees, 52 Fed. Reg. 760, 766 (Jan. 9, 1987), available on FEC.gov.
30

Chapter 4

8. Contributions to Retire Debts

If a committee has net debts outstanding after an election is over, a campaign may accept contributions 

made after the election to retire the debts provided that:

• The contribution is designated for that election;17

• The contribution does not exceed the contributor’s limit for the designated election; and

• The campaign has net debts outstanding for the designated election on the day it receives the 

contribution.

110.1(b)(3)(i) and (iii).

How to calculate net debts outstanding

A campaign’s net debts outstanding consist of unpaid debts incurred with respect to the particular election 

minus the sum of cash on hand and the total amounts owed to the campaign.18 110.1(b)(3)(ii).

Unpaid debts

Unpaid debts include the following:

• All outstanding debts and obligations;

• The estimated cost of raising funds to liquidate the debts; and

• If the campaign is terminating, estimated winding down costs (for example, office rental, staff salaries 

and office supplies).

110.1(b)(3)(ii).

Cash on hand and amounts owed to the campaign

Cash on hand consists of the resources available to pay the campaign’s total debts, including currency, 

deposited funds, traveler’s checks, certificates of deposit, treasury bills and any other investments valued at 

fair market value. 110.1(b)(3)(ii)(A).

For the purpose of calculating net debts outstanding for the primary, cash on hand need not include 

contributions designated for the general.19

Amounts owed to the campaign include credits, refunds of deposits, returns and receivables or a 

commercially reasonable estimate of the collectible amount, and the outstanding balance of candidate 

personal loans20 exceeding $250,000 per election.

Adjustment to net debts total

A campaign first calculates its net debts outstanding as of the day of the election. Thereafter, the campaign 

continually recalculates its total net debts outstanding as additional funds are received for, or spent on, the 

election for which the debt remains. 110.1(b)(3)(ii) and (iii).

17 An undesignated contribution made after an election counts toward the limit for the candidate’s upcoming election, unless the 

campaign requests its redesignation.

18 For an illustration of how the net debts outstanding calculation is performed, see the Explanation and Justification published with 

the final rule, Contribution and Expenditure Limitations and Prohibitions; Contributions by Persons and Multicandidate Political 

Committees, 52 Fed. Reg. 760, 762 (Jan. 9, 1987), available on FEC.gov.

19 See the Explanation and Justification published with the final rule, Contribution and Expenditure Limitations and Prohibitions; 

Contributions by Persons and Multicandidate Political Committees, 52 Fed. Reg. 760, 762 (Jan. 9, 1987), available on FEC.gov.

20 The definition of a candidate “personal loans” includes bank loans guaranteed by the candidate as well as loans from the candidate’s 

personal funds. 116.11(a).
31

Contribution Limits

Contributions exceeding net debts

If, on the same day, a campaign receives several contributions made after the election that, together, exceed 

the amount needed to retire its debts, the campaign may:

• Accept a proportionate amount of each contribution and either refund the remaining amount or ask 

contributors to redesignate the excessive portions for another election; or

• Accept some contributions in full and either return or refund the others or seek redesignations or 

reattributions for them. (See “Redesignations” and “Reattributions” in Section 7.)

110.1(b)(3).

9. Candidate’s Personal Funds

When candidates use their personal funds for campaign purposes, they are making contributions to their 

campaigns. Candidate contributions to their own campaigns are not subject to any limits. 110.10; AOs 

1991-09 (Hoagland), 1990-09 (Mueller), 1985-33 (Collins) and 1984-60 (Mulloy). They must, however, be 

reported (as discussed in next section).

Contributions from members of the candidate’s family are subject to the same limits that apply to any other 

individual. For example, a candidate’s parent or spouse may not contribute more than $2,900 per election to 

the candidate. 

Definition of a candidate’s “personal funds”

The personal funds of a candidate include:

• Assets which the candidate has a legal right of access to or control over, and which he or she has legal 

title to or an equitable interest in, at the time of candidacy;

• Income from employment;

• Dividends and interest from, and proceeds from sale or liquidation of, stocks and other investments;

• Income from trusts, if established before the election cycle;

• Income from trusts established by bequests (even after candidacy);

• Bequests to the candidate;

• Personal gifts that had been customarily received by the candidate prior to the beginning of the election 

cycle; and

• Proceeds from lotteries and similar games of chance.

100.33(a) and (b).

Assets jointly held with spouse

A candidate may also use, as personal funds, his or her portion of assets owned jointly with a spouse (for 

example, a checking account or jointly owned stock). If the candidate’s financial interest in an asset is not 

specified, then the candidate’s share is deemed to be half the value. 100.33(c).

Some banks may require a spouse to cosign a loan obtained by the candidate using jointly held assets as 

collateral. While an endorsement or guarantee of a loan normally constitutes a contribution, in this instance 

the spouse is not considered a contributor as long as the candidate’s share in the collateral equals or exceeds 

the amount of the loan. 100.52(b)(4); AO 1991-10 (Guernsey).

Example: A candidate obtains a $5,000 bank loan for his campaign using, as collateral, property valued 

at $20,000 held jointly (in equal shares) with his spouse. Both co-sign the loan. Because the candidate’s 

interest in the property is $10,000, which exceeds the amount of the loan, his spouse has not made a 

contribution by co-signing it.
32

Chapter 4

What are not considered personal funds

Personal gifts and loans

If any person, including a relative or friend of the candidate, gives or loans the candidate money “for 

the purpose of influencing any election for federal office,” the funds are not considered personal funds 

of the candidate even if they are given to the candidate directly. Instead, the gift or loan is considered 

a contribution from the donor to the campaign, subject to the per election limit and reportable by the 

campaign. 100.52. See AOs 2000-08 (Harvey); 1985-33 (Collins) and 1982-64 (Hein); see also AO 1987-01 

(Dawson).

Bank loans used in connection with campaign

Bank loans are not considered contributions from the bank if they comply with FEC regulations on bank 

loans. (See “Bank Loans” in Chapter 6.)

When a candidate obtains a bank loan for use in connection with his or her campaign, the loan is 

considered to be from the bank and not from the candidate’s personal funds. The candidate is acting as the 

agent of the campaign. 102.7(d) and AO 1985-33 (Collins).

10. Repayment of Personal Loans from Candidate

For personal loans (including advances of personal funds or endorsements of bank loans to the committee) 

from the candidate to his or her authorized committee, that aggregate more than $250,000 per election, the 

following rules apply.21

• The committee may use contributions to repay the candidate for the entire amount of the loan or loans 

only if those contributions were made on or before the day of the election; and

• The committee may use contributions to repay the candidate only up to $250,000 of the personal loans 

from contributions made after the date of the election. 116.11(b).

Furthermore, if the committee uses the amount of cash-on-hand as of the date of the election to repay the 

candidate for loans in excess of $250,000, it must do so within 20 days of the election. 116.11(c). Within 

that time, the committee must treat the portion of candidate loans that exceed $250,000, minus the amount 

of cash-on-hand as of the day after the election used to repay the loan, as a contribution by the candidate. 

116.11(c). AO 2003-30 (Fitzgerald). See also AOs 2008-22 (Lautenberg) and 2008-09 (Lautenberg).

Note that a runoff election has a separate limit for the purposes of repaying candidate loans. For example, 

if a candidate loaned the committee $345,000 for the primary election, the committee could repay the 

candidate up to $250,000 from contributions made after the date of the primary election. Similarly, if the 

candidate loaned $300,000 for a primary runoff election, the committee could repay the candidate up to 

$250,000 from contributions made after the date of the runoff election. See 116.11(d).

21 These rules apply to personal loans from candidates that were made on or after November 6, 2002.
33

CHAPTER 5

Prohibited Contributions

Campaigns are prohibited from accepting contributions from certain sources. See 110.9, 110.20, 114.2(c) 

and 115.2. If a committee is uncertain whether a contribution comes from a prohibited source, it must 

follow the procedures described in Section 2, “Questionable Contributions.”

1. Prohibited Sources

Corporations, labor organizations, national banks

Campaigns may not accept contributions made from the general treasury funds of corporations, labor 

organizations or national banks.1 114.2(a), (b) and (d). This prohibition applies to any incorporated 

organization, including a nonstock corporation, a trade association, an incorporated membership 

organization and an incorporated cooperative.2

Example: The owner of an incorporated “mom and pop” grocery store is not permitted to use a business 

account to make contributions. Instead, the owner would have to use a personal account.

A campaign may, however, accept contributions from separate segregated funds (PACs) established 

by corporations, labor organizations, incorporated membership organizations, trade associations and 

national banks. 114.2 and 114.5. Moreover, the Federal Election Campaign Act permits corporations, labor 

organizations, incorporated membership organizations, trade associations and national banks to use their 

treasury funds for certain election-related activities that benefit candidates. 114.5. See also Chapter 7, 

Sections 8 and 9 for more information.

Federal government contractors

Campaigns may not accept or solicit contributions from federal government contractors. 115.2. Since 

corporate contributions are already prohibited, the government contractor ban applies primarily to 

contributions from a partnership (or a limited liability company) with a government contract. It also applies 

to the personal and business funds of (1) individuals under contract to the federal government and (2) sole 

proprietors of businesses with federal contracts. 115.4 and 115.5.

The spouses of individuals and sole proprietors who are federal government contractors, and employees 

of federal government contractors, however, may make contributions from their personal funds. 115.5 and 

115.6.

Foreign nationals

Federal law prohibits contributions, donations, expenditures (including independent expenditures), and 

disbursements solicited, directed, received or made directly or indirectly by or from foreign nationals in 

connection with any federal, state or local election. 110.20(b)-(g). This prohibition includes advances of

1 National banks and federally chartered corporations may not make contributions in connection with any election—federal, state or 

local. 114.2(a).

2 However, a political committee that has incorporated for liability purposes only is not considered a prohibited source. 114.12(a).
34

Chapter 5

personal funds, contributions or donations made to political party committees and organizations, state 

or local party committees for the purchase or construction of an office building funds under 300.35, and 

contributions or disbursements to make electioneering communications.3

In addition, foreign nationals are prohibited from participating in decisions involving election-related 

activities. A foreign national may not direct, dictate, control, or directly or indirectly participate in the 

decision-making process of any person (such as a corporation, labor organization, political committee, 

or political organization) with regard to the person’s Federal or non-Federal election-related activities. 

110.20(i). This includes decisions concerning the making of contributions, donations, expenditures, 

or disbursements in connection with any federal state or local election or decisions concerning the 

administration of a political committee. 110.20(i).

Furthermore, it is a violation of federal law to knowingly provide substantial assistance in the making, 

acceptance or receipt of contributions or donations in connection with federal, state, or local elections, 

to a political party committee, or for the purchase or construction of an office building by a state or local 

party committee. 110.20(h)(1). Similarly, it is a violation to provide substantial assistance in the making 

of a disbursement to make electioneering communications, or an expenditure, independent expenditure 

or disbursement in connection with a federal, state, or local election. This prohibition includes, but is not 

limited to, acting as a conduit or intermediary for foreign national contributions and donations. 110.20(g) 

and (h)(2). See also, 300.2(d) and (e).

For the purposes of this section, knowingly means that a person must:

• Have actual knowledge that the source of the funds solicited, accepted or received is a foreign national;

• Be aware of facts that would lead a reasonable person to conclude that there is a substantial probability 

that the source of the funds solicited, accepted or received is a foreign national; or

• Be aware of facts that would lead a reasonable person to inquire whether the source of the funds 

solicited, accepted or received is a foreign national, but the person failed to conduct a reasonable 

inquiry.

110.20(a)(4).

Pertinent facts that satisfy the “knowing” requirement include knowledge of:

• Use of a foreign passport or passport number for identification purposes;

• Use of a foreign address;

• A check or other written instrument drawn on an account or wire transfer from a foreign bank; or

• Contributor or donor living abroad.

110.20(a)(5)(i)-(iv).

Definition of foreign national

A foreign national is:

• An individual who is: (1) not a citizen of the United States and (2) not lawfully admitted for permanent 

residence (as defined in 8 U.S.C. §1101(a)(20)); or

• A foreign principal, as defined in 22 U.S.C. §611(b). Section 611(b) defines a foreign principal as a 

foreign government or political party; or a partnership, association, corporation, organization, or other 

combination of persons organized under the laws of a foreign country or whose principal place of 

business is in a foreign country. 110.20(a)(3).

3 Foreign nationals are also prohibited from, directly or indirectly, donating to an inaugural committee; and it is a violation of federal 

law to knowingly accept such donations from a foreign national. 110.20(j).
35

Prohibited Contributions

“Green Card” exception

An individual who is not a citizen of the United States is eligible to make a contribution if he or she has a 

“green card” indicating that he or she is lawfully admitted for permanent residence in the United States. 

110.20(a)(3)(ii).

Determining nationality of contributor

In AO 1998-14 (Douglass), the Commission stated that the use of any surname on a contribution check 

(or similar instrument) would not, by itself, give any reason to inquire as to the person’s nationality. 

Nonetheless, the Commission advised the committee to take the following minimally intrusive steps to 

ensure that the contributions it received did not come from foreign nationals:

• Ensure that public political ads and solicitations directed to audiences outside the U.S. contain a 

summary of the foreign national prohibition of 52 U.S.C. § 30121.

• Make further inquiry into the nationality of the contributor if the committee receives a contribution 

postmarked from any non U.S. territory.

• Make further inquiry into the nationality of the contributor if the committee receives a contribution 

indicating that either the bank or the account owner has a foreign address.

In all of these instances, if the contribution is submitted along with credible evidence (e.g., a copy of a valid 

U.S. passport) that the contributor is a U.S. citizen, a U.S. national or a permanent resident alien, no further 

inquiry need be made. However, if the committee has actual knowledge that the contributor is a foreign 

national, it may not rely on these documents as a defense. 110.20(a)(7). See also AO 2016-10 (Parker) 

(setting forth the duty of an individual fundraiser to determine the nationality of contributors).

Domestic subsidiaries of foreign corporations

 The Commission has said that a foreign corporation may not establish and administer a separate segregated 

fund. However, a United States domestic corporation that is a subsidiary of a foreign corporation may 

establish and administer a separate segregated fund which can make contributions to federal candidates as 

long as:

• The domestic corporation is a discrete entity incorporated under the laws of any state within the United 

States, and its principal place of business is within the United States.

• The foreign parent does not finance election-related contributions or expenditures either directly or 

through the subsidiary, including through subsidizing the subsidiary’s business operations, unless the 

subsidiary can demonstrate by a reasonable accounting method that it has sufficient funds from its own 

domestic operations to make any contributions or expenditures.

• All decisions concerning the administration of the domestic subsidiary’s separate segregated fund are 

made by U.S. citizens or permanent residents. See 110.20(i).

See also AOs 2009-14 (Mercedes-Benz USA/Sterling), 2006-15 (TransCanada), 2000-17 (Extendicare 

Health Services, Inc.), 1995-15 (Allison Engine PAC), 1992-16 (Nansay Hawaii), 1990-08 (CIT) and 1985-

03 (Diridon).

Contributions in the name of another

A contribution made by one person in the name of another is prohibited. 52 U.S.C. §30122; 110.4(b)4. For 

example, an individual who has already contributed up to the limit to the campaign may not give money to 

another person to make a contribution to the same candidate. Similarly, a corporation is prohibited from 

using bonuses or other methods of reimbursing employees for their contributions. 114.5(b)(1).

4 In FEC v. Johnson, et al., a federal district court struck 11 C.F.R. 110.4(b)(1)(iii) holding that it exceeds the Commission’s authority. 

The stricken paragraph provided that the Act’s ban on contributions in the name of another included knowingly helping or assisting 

any person in making a contribution in the name of another.
36

Chapter 5

Candidate employed by prohibited source

As noted in Chapter 4, Section 9, a candidate’s salary or wages earned from bona fide employment are 

considered his or her personal funds. 100.33(b). However, compensation paid to a candidate in excess of 

actual hours worked, or in consideration of work not performed, is generally considered a contribution 

from the employer. 113.1(g)(6)(iii). If the employer is a corporation, federal government contractor, 

or another prohibited source, the excess payment would result in a prohibited contribution under the 

regulations applicable to that employer. See 110.20 (foreign nationals), 114.2(c) (corporations and labor 

organizations) and 115.2 (federal contractors).

2. Questionable Contributions

If a committee receives a contribution of questionable legality, it must follow the procedures described in 

this section.5 103.3(a) and (b).

Return or deposit contribution

When receiving a contribution of questionable legality, a committee must, within 10 days of the treasurer’s 

receipt, take one of two steps:

• Return the contribution to the donor without depositing it; or

• Deposit the contribution. 103.3(b)(1).

Be prepared to make refund

If it decides to deposit the questionable contribution, the committee must make sure that the funds are not 

spent because they may have to be refunded. To ensure this, the committee may either maintain sufficient 

funds in its regular campaign depository or establish a separate account used solely for the deposit of 

possibly illegal contributions. 103.3(b)(4).

Document the possibility of illegal contribution

The committee must keep a written record noting the reason why a contribution may be prohibited and 

must include this information when reporting the receipt of the contribution. 103.3(b)(5). See also Chapter 

11, Section 2, “Recording Receipts,” under the subheading “Possibly Illegal Contributions.”

Seek evidence of legality

Within 30 days of the treasurer’s receipt of a possibly prohibited contribution, the committee must make 

at least one written or oral request for evidence that the contribution is legal. Evidence of legality includes, 

for example, a written statement from the contributor explaining why the contribution is legal, or an oral 

explanation that is recorded by the committee in a memorandum. 103.3(b)(1) and AO 1995-19 (IndianAmerican Leadership Investment Fund).

Confirm legality or refund contribution

Within these 30 days, the committee must either:

• Confirm the legality of the contribution; or

• Refund the contribution. 103.3(b)(1).

5 Note that procedures for handling contributions that exceed the contribution limits or the campaign’s net debts outstanding are 

described in Chapter 4, Sections 7 and 8.
37

Prohibited Contributions

Disgorge prohibited contribution discovered late

If a committee deposits a contribution that appears to be legal and later discovers that it is prohibited 

(based on new information not available when the contribution was deposited), the committee must 

disgorge the contribution within 30 days of making the discovery. 103.3(b)(2). For example, if the 

committee finds out that a corporation reimbursed employees for their contributions to the committee (and 

had thus made corporate contributions and contributions in the name of another).

Contributor known

If the identity of the original contributor is known, the committee must refund the funds to the source of 

the original contribution. 103.3(b)(2). Alternatively, the committee may pay the funds to the U.S. Treasury. 

AO 1996-05 (Kim); but see Fireman v. United States, 44 Fed. Cl. 528 (1999).6 To do so, send the funds to:

Department of the Treasury

Bureau of the Fiscal Service

PO Box 1328

Parkersburg, WV 26106-1328

Attn: Agency Cash Branch, Avery 3G

The committee should include a cover letter that explains that the funds being sent represent potential 

violations of the Federal Election Campaign Act and requests that the funds be placed in the “general fund 

account.”

Contributor unknown

If, however, the identity of the original contributor cannot be determined or is in question, the committee 

may disburse the funds to a governmental entity (federal, state or local), or to a qualified charitable 

organization described in 26 U.S.C. §170(c). AOs 1995-19 (Indian-American Leadership Investment Fund) 

and 1991-39 (D’Amato).

Prohibited in-kind contribution

If the prohibited contribution was an in-kind contribution, the committee should disgorge an amount equal 

to the value of the contribution to the appropriate party.

Insufficient funds

If the committee does not have sufficient funds to disgorge the contribution when the illegality is 

discovered, the committee must use the next funds it receives. 103.3(b)(2).

Reporting

For instructions on reporting disgorged contributions, see Chapter 13, Section 25.

6 In Fireman, the Court of Federal Claims ruled that a contributor of illegal contributions has a right to have the contributions refunded 

to him rather than disgorged to the U.S. Treasury.
38

Chapter 5
39

CHAPTER 6

Other Reportable Receipts

This chapter describes campaign receipts that are not considered contributions and, therefore, are not 

subject to contribution limits. Nevertheless, all receipts must be reported by the campaign.

1. Bank Loans

Conditions

A candidate or his or her campaign committee may obtain a loan, including a line of credit, from a bank, 

provided that the loan:

• Bears the bank’s usual and customary interest rate for the category of loan involved;

• Is evidenced by a written instrument;

• Is subject to a due date or amortization schedule; and

• Is made on a basis which assures repayment.

100.82(a).

If a loan fails to meet any of these conditions, then a prohibited contribution from the lending institution 

results.

Methods of assuring repayment

A loan is made on a basis which assures repayment if it is obtained using one or more of the following 

authorized methods of securing the loan:

Traditional methods

A committee may use one of the following traditional methods of securing the loan, or a combination of the 

two:

Collateral. A loan may be secured using assets of the candidate or the committee, such as real estate, 

personal property, cash on deposit, certificates of deposit and stocks. The fair market value of the 

assets must, on the date of the loan, equal or exceed the amount of the loan and any senior liens. The 

committee must ensure that the bank has established a “perfected security interest” in the collateral 

(that is, has taken steps to legally protect its interest in the collateral in the event that the committee 

defaults on the loan). 100.82(e)(1)(i).

Note that if a candidate obtains a loan using assets jointly owned with his or her spouse, the amount of 

the loan may not be greater than the candidate’s share of the property (usually one half); otherwise, a 

contribution from the spouse results. 100.52(b)(4). (See Chapter 4, Section 9, under the subheading, 

“Assets Jointly Held with Spouse” for a narrow exception to this rule.)

Guarantees or endorsements. An endorsement or guarantee of a bank loan is considered a 

contribution by the endorser or guarantor and is thus subject to the law’s contribution limits and 

prohibitions. 100.52(b)(3) and 100.82(e)(1)(ii).

Pledge of future receipts

If the committee pledges its future receipts as security for the loan, then the amount loaned by the bank 

may not exceed a reasonable estimate of anticipated receipts, based on documentation provided by the 

candidate or committee (such as cash flow charts or fundraising plans). 100.82(e)(2)(i) and (ii). Future 

receipts might include, for example, anticipated contributions or interest income.
40

Chapter 6

The committee must also set up a separate account for the receipt of funds pledged for the repayment of 

the loan. The account may be established with either the lending institution or a different depository. If the 

account is established at a depository other than the lending institution, then the committee must execute an 

assignment of the account’s funds to the lending institution and notify the depository of the assignment. The 

loan agreement must require the committee to deposit the pledged funds into the account established for this 

purpose. 100.82(e)(2)(iii) and (iv).

Other methods of assuring repayment

The Commission may, on a case-by-case basis, approve methods of assuring repayment other than those 

previously described. 100.82(e)(3). See, for example, AO 1994-26 (Cunningham). A committee should 

request an advisory opinion from the Commission before entering into a loan agreement that relies on 

alternative sources of repayment.

Schedule C-1/C-P-1

When a committee obtains a loan from a bank or other permissible lending institution (or the candidate 

obtains one on behalf of his or her committee), the committee must file Schedule C-1 (or Schedule C-P-1 for 

Presidential candidates) with the report covering the period in which the loan was obtained. 104.3(d)(1).

If the loan is obtained by the committee (rather than by the candidate), the treasurer must sign the schedule 

and attach a copy of the loan or line of credit agreement. See Chapter 13. Both Schedule C-1 and Schedule 

C-P-1 (for Presidential candidates) include a statement to be signed by an officer of the lending institution 

certifying that the information provided by the committee is accurate and that the terms and conditions of 

the loan comply with FEC rules.

2. Brokerage Loans and Other Lines of Credit Obtained by Candidate

Candidates may use funds derived from an advance on their brokerage account, credit card account or other 

line of credit to finance their campaigns, if the extension of credit is:

• In accordance with applicable law;

• Under commercially reasonable terms; and

• Made by persons who make such loans in the normal course of their business.

100.83(a).

The candidate’s authorized committee has the option of repaying loans derived from a candidate’s brokerage 

account or other line of credit directly to the lending institution or to the candidate. 100.83(d). All such 

loans to the committee derived by these methods must be reported by the committee. 100.83(e). The 

committee must report the loan from the candidate as a receipt and repayment of the loan to the candidate as 

a disbursement. 104.3(a)(3)(vii) and (b)(2)(iii)(A). See Chapter 13, Section 23.

3. Overdrafts

If a bank honors a check written by a political committee with insufficient funds in its checking or savings 

account, no contribution from the bank results as long as the overdraft:

• Is made on an account subject to automatic overdraft protection;

• Is subject to a definite interest rate which is the usual and customary rate; and

• Is subject to a definite repayment schedule.

100.82(d).
41

Other Reportable Receipts

An overdraft that does not meet these conditions is a prohibited contribution. 100.82(d); 114.2. Note that if 

the overdraft protection is based on a line of credit extended by the bank, draws on that line of credit must 

be disclosed on Schedule C-1.

4. Investment Income

Interest earned on investments, such as interest earned on invested funds and dividends earned on 

securities, are not considered contributions. Such funds, however, must be transferred back into the main 

campaign depository before being disbursed by the campaign. Additionally, tax laws apply. If a committee 

receives interest from a bank it must list that bank on the committee’s Form 3. See 103.3(a); AOs 1999-08 

(Specter), 1997-06 (Hutchison), 1986-18 (Bevill) and 1980-39 (Fluor Public Affairs Committee), as well as 

Appendix G, “Compliance with other laws.”

5. Offsets to Operating Expenditures

Offsets to operating expenditures, such as returns by vendors of deposits, reimbursements for expenses 

shared by committees, refunds and rebates, are not considered contributions. Note, however, that rebates 

to campaigns must be offered in the ordinary course of business and on the same terms and conditions as 

those offered to nonpolitical entities. Otherwise, the rebate may be considered a contribution—a prohibited 

contribution if a corporation pays the rebate. See, for example, AOs 2004-37 (Waters) (see responses to 

questions 2 and 4), 1996-02 (Compuserve), 1994-10 (Franklin National Bank), 1987-24 (Hyatt) and 1986-

22 (WREX-TV).

6. Legal and Accounting Services

The value of legal and accounting services provided without charge in accordance with the guidelines 

described in section 2 of the next chapter is not a contribution. 100.86; 114.1(a)(2)(vii). See, e.g. AO 2012-

16 (King; Pierce Atwood LLP).
42

Chapter 6
43

CHAPTER 7

Sources of Support

1. Contributions

Contributions are the most common source of campaign support. Earlier chapters explain the Federal 

Election Campaign Act’s (the Act) limits and prohibitions on contributions. See Chapter 3, Section 2, 

“Types of Contributions,” and Chapter 4, Contribution Limits.” Remember that all contributions are 

reportable. See Chapter 13.

2. Free Legal and Accounting Services

Any entity (e.g., a committee, a corporation, a union, a partnership) may provide a campaign with free legal 

and accounting services as long as:

• The services are provided only for the purpose of ensuring the campaign’s compliance with the Act;

• The entity paying for the service is the regular employer of the individual performing the service;

• The employer does not hire additional employees to render the services or to free regular employees to 

perform the service; and

• The campaign reports the value of the service (the amount paid by the employer), as well as the name 

of each person who performed the service and the date the service was provided.

100.86, 100.146 and 114.1(a)(2)(vii). See AO 2006-22 (Wallace).

For more information on reporting free legal and accounting services, see Chapter 13, Section 9.

Use of equipment

This exemption covers only the services provided to ensure compliance. The employer cannot donate 

equipment, such as computers, to the campaign without making a contribution (a prohibited contribution 

if the employer is an incorporated entity). However, the use of the employer’s resources, such as computer 

equipment, necessary to enable the employee to provide the service is not considered a contribution by the 

employer. AOs 1989-13 (IBM) and 1980-137 (Richardson).

Volunteer services

If an individual personally volunteers legal or accounting services without compensation, the work is 

considered personal volunteer activity, and the restrictions in this section do not apply. (See “Volunteer 

Activity, Personal services.”)

3. Volunteer Activity

Personal services

An individual may volunteer personal services to a campaign without making a contribution as long as the 

individual is not compensated by anyone for the services. 100.74. Volunteer activity is not reportable.

Example: An attorney, working as a volunteer (i.e., he receives no compensation from anyone for his 

volunteer services), writes policy papers for the campaign.
44

Chapter 7

If volunteers are, in fact, paid by any person for their services, then the activity is no longer considered 

volunteer activity. If the payment is made by someone other than the campaign itself, then an in-kind 

contribution results, and the campaign must report it. 100.54. (Exception: “Free Legal and Accounting 

Services,” in Section 2.) See AOs 2007-08 (King), 1982-04 (Apodaca) and 1980-42 (Hart).

Foreign national as campaign volunteer

Although foreign nationals may not make contributions or expenditures in connection with any federal, 

state, or local election (see Chapter 5, Section 1), an individual who is a foreign national may participate 

in campaign activities as an uncompensated volunteer. In doing so, the volunteer must be careful not 

to participate in the decision-making process of the campaign. The Act and Commission regulations 

specifically prohibit foreign nationals from participating in the decisions of any person involving electionrelated activity. 52 U.S.C. §30121; 110.20(i). See AO 2004-26 (Weller). For example, a foreign national 

volunteer may attend committee events and campaign strategy meetings but may not be involved in the 

management of the committee. 110.20(i); see AOs 2014-20 (Make Your Laws PAC), 2007-22 (Hurysz), 

2004-26 (Weller) and 1987-25 (Otaola).

Incidental volunteer activity at corporate/labor facilities

Generally, if an individual provides services to a campaign during paid working hours, the employer makes 

a contribution to the campaign. See 100.54. However, an employee, stockholder or member of a corporation 

or labor organization may make occasional, isolated or incidental use of corporate/labor organization 

facilities for his or her own individual volunteer activities on behalf of a campaign. “Incidental use” is 

considered the use of facilities for no longer than one (1) hour per week or four (4) hours per month. 

114.9(a)(2) and (b)(2). For example, an employee may use an office phone to make calls that pertain to 

political volunteer work. If the volunteer activity is limited to “incidental use” of the facilities, the volunteer 

does not have to reimburse the organization for use of the facilities (only for any increased overhead or 

operating costs).

When use of the facilities exceeds “incidental use,” the volunteer must reimburse the organization the usual 

and normal rental fee within a commercially reasonable time. The reimbursement is considered an in-kind 

contribution from the volunteer and must be reported by the benefiting campaign committee. 100.52(d) 

and 114.9(a)(3) and (b)(3). For information on the use by a volunteer of an employer’s computer and 

internet access, see “Internet volunteer activity.”

Note that if any person (including an employee, stockholder or member) uses the facilities of a corporation 

or union to produce campaign materials, reimbursement is required regardless of how much time is spent 

on the activity. 114.9(c). For information on a campaign’s use of corporate or labor facilities, see Section 9, 

“Use of Corporate/Labor Transportation and Facilities,” later in this chapter.

Use of real or personal property: activities in home, church, community room

Individuals, in the course of volunteering personal services, may use their homes—or the recreation room 

of the residential complex where they live—for campaign-related activities without making a contribution. 

A nominal fee paid by an individual volunteer for the use of a recreation room is not considered an in-kind 

contribution to the campaign and is not, therefore, reportable. For rules concerning the use of a home 

computer, see “Internet volunteer activity.”

Volunteers may use a church or community room for campaign activities as long as the facility is regularly 

used for noncommercial purposes by members of the community, without regard to political affiliation. 

Again, a nominal fee paid by an individual volunteer for the use of the room is not a contribution. 100.75 

and 100.76.
45

Sources of Support

Food, drink, invitations for home, church or community room event

When holding a campaign-related activity in his or her home, church or community room, an individual 

may spend up to $1,000 per candidate, per election for food, beverages and invitations for the event 

without making a contribution. (For example, two individuals living together may spend up to $2,000 per 

candidate, per election.) Any amount spent in excess of $1,000, however, must be reported by the campaign 

as an in-kind contribution. 100.77. If an individual co-hosts an event held in someone else’s home, any 

expenses paid by the nonresident co-host are considered contributions to the campaign benefiting from the 

event. AO 1980-63 (Wirth).

Internet volunteer activity

General exception

An uncompensated individual or group of uncompensated individuals may engage in certain voluntary 

internet activities for the purpose of influencing a federal election without restriction. These exempted 

internet activities would not result in a contribution or an expenditure under the Act and would not 

trigger any registration or reporting requirements with the FEC. This exemption applies to individuals 

acting with or without the knowledge or consent of a campaign or a political party committee. 100.94 and 

100.155. Exempted internet activities include, but are not limited to, sending or forwarding electronic mail, 

providing a hyperlink to a website, creating, maintaining or hosting a website and paying a nominal fee for 

the use of a website, and any other form of communication distributed over the internet. See e.g., AO 2018-

13 (OsiaNetwork); AO 2011-14 (Utah Bankers Association).

Use of employer’s computer and internet access

A corporation or a labor organization may permit its employees, shareholders, officials and members 

to use its facilities for individual volunteer internet activity, without making a prohibited contribution. 

The individual volunteer must comply with the corporation’s or labor organization’s internal policies for 

computer and internet use, and must complete the normal amount of work for which the employee is 

paid, or is expected to perform. Also, the activity must not increase the overhead or operating costs of the 

organization, and the activity must not be coerced. The organization may not condition the availability of 

the internet or the computer on their being used for political activity or for support for or opposition to any 

particular candidate or political party. 114.9(a) and (b). (For rules on communications by a corporation or 

labor organization using a computer or the internet, see Section 8, “Corporate/Labor Exceptions,” later in 

this chapter.)

Not exempt: paid web communications

If an individual or group of individuals pays a fee to place a communication on another person or entity’s 

website, the communication is considered general public political advertising, and thus qualifies as a 

public communication.1 100.26. As such, it may require a disclaimer, and/or reporting, and may count as a 

contribution and/or expenditure. See Appendix D, “Communications.”

4. Travel Cost Exemptions

Unreimbursed travel expenses

The exemptions described in this section apply only to an individual’s payments for his or her own travel 

expenses; if an individual uses personal funds to pay the travel expenses of another, an in-kind contribution 

results. 100.93(b). For the general rules concerning campaign travel, including the rules for using noncommercial transportation, see Chapter 10, Section 4, “Campaign Travel.”

1 At the time of this publication, the Commission was considering proposals to amend the definition of “public communication” 

and its regulations concerning disclaimers on certain internet communications. The proposed rules on Internet Communication 

Disclaimers and Definition of ‘‘Public Communication’’ and Technological Modernization are available on FEC.gov. Any updates to 

these rules will be announced and posted there.
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Chapter 7

$1,000 transportation exemption

An individual (including the candidate, a paid staff member or a volunteer) may voluntarily spend up to 

$1,000 for unreimbursed transportation expenses on behalf of the campaign without making a contribution. 

However, when an individual’s payments for such transportation expenses exceed $1,000 per candidate, 

per election, the payments are considered contributions, unless they are reimbursed by the candidate’s 

committee in a timely manner (see next section). 100.79(a)(1).

Volunteer’s exemption for meals and lodging

A campaign volunteer may spend unlimited amounts for his or her own meals and lodging without making 

a contribution, as long as the expenses are incidental to volunteer activity. 100.79(b).

Reimbursed travel expenses

When the candidate or an individual working on behalf of the candidate pays any other travel expense, no 

contribution will result if the committee reimburses the individual within the following time limits:

• If the expense was paid with cash or a personal check, within 30 days from the date the expense was 

incurred.

• If the expense was paid with a credit card, within 60 days of the closing date on the credit card billing 

statement where the charge first appears.

Outside of these time limits, the payments are in-kind contributions. 116.5(b); AO 2003-31 (Dayton). See 

Chapter 13, Section 16, “Reporting Travel Expenses” for reporting rules. For reimbursement for noncommercial travel see Chapter 10, Section 4, “Campaign Travel.”

5. Vendor Discounts

Food and beverages for campaigns

A vendor of food or beverages (even if incorporated) may sell food and beverages to a campaign at a 

discount. The amount charged must at least equal the vendor’s cost for the items. If the value of the 

discount—the difference between the normal charge and the amount paid by the campaign—does not 

exceed $1,000 per candidate, per election, the discount is not considered a contribution. Discounts 

exceeding $1,000, however, are in-kind contributions and must be reported as such. A corporate vendor 

may not exceed the $1,000 discount limit since corporate contributions are prohibited. 100.78 and 114.1(a)

(2)(v).

Discounts in the ordinary course of business

Discounts given in the ordinary course of business and on the same terms and conditions offered to a 

vendor’s other (non-political committee) customers do not result in contributions. See, e.g., AOs 2004-

18 (Lieberman), 1989-14 (Anthony’s Pier 4). In a recent example, the Commission determined that a 

corporate vendor may offer its cybersecurity services to federal candidates and political committees at the 

same “low or no cost” tier that it offers to all qualified customers without making an impermissible in-kind 

contribution. The vendor must offer the services in the ordinary course of business, on the same terms and 

conditions and at the same rate that it offers to non-political clients. AO 2019-12 (Area 1 Security).

6. Support from Other Campaigns

This section describes was in which campaigns may assist one another without making a contribution. For 

the rules on campaign-to-campaign contributions, see Chapter 4, Section 1, “Contributions from other 

candidates.”
47

Sources of Support

Shared expenses

Campaigns may share common expenses (e.g., rent for a shared headquarters or printing for a brochure that 

promotes each campaign) without a contribution resulting, as long as each committee pays its attributed 

portion of the costs. If one committee pays a bill, the other committees involved in the expense must 

reimburse that committee for their portion of the expense within a reasonable period of time to avoid a 

contribution. See AOs 2007-24 (Burkee/Walz), 2004-37 (Waters) and 2004-36 (Risley). Payments by 

nonfederal campaigns for shared expenses involving certain public communications must be made from 

funds that are subject to the limitations, prohibitions and reporting requirements of the Act. 300.71.

“Coattail” support in campaign materials

Under the “coattail” provision of the Act, a federal candidate may be mentioned in campaign materials 

produced by another federal candidate’s campaign or by the campaign of a nonfederal candidate. The 

committee making the expenditure must report it, but the candidate named in the ad has no reporting 

responsibility. The payment for the materials is not a contribution to the referenced federal candidate 

provided that these guidelines are met:

• The materials must be limited to items such as pins, bumper stickers, handbills, brochures, posters and 

yard signs;

• The materials must be distributed by volunteers (for example, by hand) or by mail using lists developed 

by the candidate’s campaign (but not by direct mail); and

• The materials may not be distributed through public political advertising such as broadcast media, 

newspapers, magazines, billboards or direct mail (a mailing by a commercial vendor or made from a 

commercial list).

The portion of the cost allocable to a federal candidate must be paid from funds subject to the limits 

and prohibitions of the Act, even if a nonfederal campaign pays for the materials. 100.88(a) and (b) and 

100.148.

Example: A U.S. House campaign may produce a yard sign that includes the name of a U.S. Senate 

candidate without allocating a portion of the cost as an in-kind contribution to that candidate (as long as the 

guidelines are met).

Endorsements and solicitations by federal candidates

A public communication in which a federal candidate endorses, or solicits funds for, another candidate 

for federal or nonfederal office does not result in a contribution to the endorsing (or soliciting) 

candidate unless the communication promotes or supports the endorsing (or soliciting) candidate or 

attacks or opposes his opponent in the election. 109.21(g). For more information, see Appendix D, 

“Communications.” See also Appendix E for further information on soliciting funds for other candidates.

Example: Candidate X, a candidate for the U.S. Senate, appears in a commercial for Candidate Y, a candidate 

for county prosecutor. In the commercial, Candidate X states, “Candidate Y is one of the best courtroom 

prosecutors we’ve ever had in this country. Vote for Candidate Y!” Candidate X makes no mention of her 

own campaign and does not attack or oppose any of the candidates she’s running against.

As long as the commercial neither promotes or supports Candidate X nor attacks or opposes her opponents, 

the cost of the commercial will not result in an in-kind contribution to Candidate X’s campaign.
48

Chapter 7

7. Party Support

In addition to making contributions, party committees may support a candidate through other activities 

as described in this section. These other activities are reportable by the political party committee but 

not by the campaign of the candidate receiving the support. Note that some of these activities may 

trigger additional reporting responsibilities or funding provisions for the party committee. For detailed 

information, see Chapter 7 of the Campaign Guide for Political Party Committees.

Coordinated party expenditures

The Act creates a special exception to the contribution limits for certain party activities supporting 

candidates. 52 U.S.C. §30116(d).2 The national party committee and the state party committee each have 

an additional special contribution limit for coordinated party expenditures made in connection with the 

general election campaigns of U.S. House and Senate candidates. 109.32(b).

Although these expenditures may be coordinated with a campaign, the party committee must actually 

make the expenditure on behalf of the campaign; money given directly to the candidate’s campaign is not a 

coordinated party expenditure.

Coordinated party expenditure limits

The party’s national committee has a coordinated spending limit for each U.S. Senate and House nominee 

in the general election. See 109.32(b). The national committee may designate (in writing) the party’s 

national senatorial committee or national congressional committee to spend its allowance with respect to a 

particular nominee, but those committees do not have separate spending limits. 109.32(b) and 109.33; see 

also AO 1976-108 (Cleveland). The national committee may also designate a state or local party committee 

to make its expenditures. 109.33(a).

A state party committee has a separate coordinated spending limit for each Senate and House general 

election nominee seeking election in that state. The state committee may designate (in writing) another 

party committee to spend its allowance with respect to a particular nominee. 109.32(b) and 109.33(a).

Although local party committees have no separate coordinated spending allowance, they may be designated 

in writing by either the national committee or the state committee to make coordinated party expenditures. 

109.33(a) and (b)(1). When making coordinated party expenditures, party organizations that are not 

federal political committees must nevertheless use funds that are permissible under the Act. 102.5(b).

Coordinated party expenditure limits for Senate and House candidates are calculated as follows:3

Senate candidate: State voting age population x 2 cents, multiplied by the Cost of Living Adjustment 

(COLA); or $20,000 multiplied by the COLA, whichever is greater.

House candidate:4 $10,000 multiplied by the COLA, or, in states with only one representative, the same 

as the Senate limit.

2 In the past, coordinated party expenditures were often called “441a(d) expenditures” because they were provided for in 2 U.S.C. 

§441a(d) of the Act. In September, 2014, the Office of Law Revision Counsel to the United States House of Representatives made 

editorial reclassifications to the United States Code to create a new Title 52, Voting and Elections which recodifies the Act (and this 

provision) from Title 2 to Title 52.

3 The Cost of Living Adjustment (COLA) has a considerable effect on party spending limits. For example, the spending limit for a 

House candidate running in an election in 2021 is $52,500 (or $105,000 for House candidates in states with only one representative).

4 The limit applies to candidates for Delegate (American Samoa, District of Columbia, Guam, Northern Mariana Islands, U.S. Virgin 

Islands) and Resident Commissioner (Puerto Rico). 109.32(b)(2)(ii).
49

Sources of Support

The Commission publishes the dollar amounts of the coordinated party expenditure limits in the Federal 

Register, the FEC Record and on the Commission’s website. 110.17(e).

Coordinated party expenditures vs. in-kind contributions

When making either coordinated party expenditures or in-kind contributions, a party committee 

purchases goods or services for the benefit of a campaign. The party committee may decide whether to 

treat an expenditure made on behalf of the candidate as a coordinated party expenditure or as an in-kind 

contribution. 109.37(b). (As previously noted, monetary contributions given directly to the campaign do 

not qualify as coordinated party expenditures.)

Despite their similarity, coordinated party expenditures differ from in-kind contributions in several ways:

• Coordinated party expenditures may be made in connection with the general election only (although 

they may be made during the primary period—see 109.34), whereas in-kind contributions may be made 

for any election.5

• Coordinated party expenditures count against the special spending limits, whereas in-kind 

contributions count against the committee’s per candidate, per election limits on contributions (e.g., 

$5,000).

• Coordinated party expenditures are reported by the party committee only, whereas in-kind 

contributions and party coordinated communications are reported by both the party committee and the 

recipient campaign.

Party independent expenditures

Party committees may make independent expenditures on behalf of, or in opposition to, candidates. Such 

expenditures are not subject to contribution or coordinated party expenditure limits.6

Permissible sources

Since independent expenditures expressly advocate the election or defeat of federal candidates, they must 

be financed with funds from the party’s federal account. For more information regarding independent 

expenditures, see Section 11, and Appendix D, “Communications.”

Exempt party activities

Two types7 of grassroots activities—preparation, display and distribution of campaign materials and 

slate cards—undertaken by state and local party committees in support of specific federal candidates are 

unlimited because they are exempt from the definition of contribution. Although they are exempt from 

contribution limitations, such activities often qualify as federal election activity (FEA) and thus may be 

subject to certain funding restrictions. Moreover, payments made by an unregistered party organization 

for such materials count towards the organization’s FEC registration threshold. For more information on 

exempt activities, FEA and party committee registration thresholds, see the Campaign Guide for Political 

Party Committees.

Campaign materials

A state or local party committee or organization may prepare and distribute campaign materials such as 

pins, bumper stickers, handbills, brochures, posters or yard signs. The payments for such items are not 

considered contributions or expenditures if the following conditions are met:

5 A post general runoff does not constitute a general election triggering an additional coordinated party expenditure allowance.

6 See FEC v. Colorado Republican Federal Campaign Committee, 518 U.S. 604 (1996).

7 There is a third type of exempt activity for registration and GOTV activity conducted by a state or local party committee on behalf 

of the Presidential and Vice-Presidential nominees of that party. 100.89. For the conditions and details regarding this type of exempt 

activity, see the Campaign Guide for Political Party Committees.
50

Chapter 7

• The activity is conducted on behalf of the party’s nominees for the general election.

• The materials are distributed by volunteers, not through public advertising such as broadcast media, 

newspapers, magazines or billboards or by direct mail (that is, a mailing by a commercial vendor or 

from commercial lists).

• The party committee does not use materials purchased by the national party committee or money 

transferred from the national party committee specifically to purchase the materials.

• The party committee does not use funds designated by a donor for a particular candidate.

• A payment from a state or local candidate to help pay for the materials does not exceed his or her share 

of the expenses.

100.87; See AOs 2010-01 (Nevada State Democratic Party) and 2008-06 (Virginia Democrats).

Slate cards and sample ballots

A state or local party committee or organization may prepare and distribute a slate card, sample ballot, 

palm card or other printed list naming candidates for any public office. The payments are not considered 

contributions or expenditures on behalf of any federal candidate listed as long as the following conditions 

are met:

• The list names at least three candidates running for election to any public office for which an election is 

held in the state.

• The list is not distributed through public advertising such as broadcast media, newspapers, magazines 

or billboards. Note, however, that it may be distributed by direct mail (that is, a mailing by a 

commercial vendor or from a commercial list).8 100.80 and 100.140.

• The content is limited to the identification of each candidate (pictures may be used), the office or 

position currently held, the office sought and party affiliation. The list must exclude any additional 

biographical data on candidates and their positions on issues as well as statements on party philosophy. 

Certain voting information, however, may be given, such as time, place and instructions on voting a 

straight party ticket. AO 1978-89 (Withers).

See AO 2008-06 (Virginia Democrats).

Sources of funds

Many local party organizations are not registered political committees under the Act and some may, under 

state law, accept donations that would be prohibited or excessive under the Act. These funds may not be 

used to pay for exempt party activities. Instead, the party must use funds that are permissible under federal 

law. 100.80 and 100.87(b); 100.140 and 100.147(b); 102.5(b).

Reporting

Campaign committees are not required to report exempt party activities. If exempt party activities are 

conducted by a federally registered party committee, the party committee must report them. As previously 

stated, exempt activities may trigger federal registration and reporting obligations for a local party 

organization. 100.5(c).

8. Corporate/Labor Exceptions

Although corporations (including incorporated trade associations and membership organizations) and 

labor organizations are generally prohibited from using their treasury funds to make contributions in 

connection with federal elections,9 they are permitted to:

8 See the Explanation and Justification at 45 Fed. Reg. 15080, 15081-15082 (March 7, 1980) available on FEC.gov.

9 They may, however, fund independent expenditures, contribute to political committees established solely to make only independent 

expenditures (e.g., Super PACs), contribute to the non-contribution accounts of Hybrid PACs, and establish separate segregated funds 

(SSFs). See Citizens United v. FEC, 558 U.S. 310 (2010); SpeechNow.org v. FEC 599 F.3d 686 (D.C. Cir. 2010) (en banc), and Carey v. 

FEC, 791 F.Supp.2d 121 (D.D.C. 2011).
51

Sources of Support

• Sponsor communications to their “restricted class” that contain express advocacy and may be 

coordinated with a candidate; and

• Sponsor election-related communications to other employees and/or the general public as long as they 

are not coordinated with a candidate, a candidate’s authorized committee, a party committee or any of 

their agents. (See Citizens United v. FEC);

• Establish separate segregated funds (popularly referred to as PACs), which can support federal 

candidates (114.1(a)(2)(iii));

• Provide certain free legal and accounting services to a campaign (see Section 2);

• Provide vendor discounts on food and beverages (see Section 5);

• Allow employees, stockholders and members to make incidental use of their facilities for volunteer 

campaign work (see Section 3).10

This section focuses on the first two items.

Restricted class

A corporation’s restricted class consists of its executive and administrative personnel, its stockholders and 

the families of those two groups. A labor organization’s restricted class consists of its members, executive 

and administrative personnel and the families of those two groups. A membership organization’s restricted 

class generally includes the executive and administrative personnel of the organization, the organization’s 

members and the families of those two groups.11 114.1(j)

Coordination with the candidate

An expenditure is coordinated if it is made in cooperation, consultation or concert with, or at the request 

or suggestion of, a candidate, a candidate’s authorized committee, or their agents, or a political party 

committee or its agents.12 109.20(a). FEC regulations provide for a three-part test to determine whether 

a communication is coordinated. See 109.21 and Appendix D, “Communications.” An expenditure that 

is coordinated between a candidate or the candidate’s campaign and a third party is considered an inkind contribution to the candidate, which the candidate must report as a contribution received and an 

expenditure made. 104.13(a), 109.20(b) and 109.21(b). Because the Act prohibits corporations and labor 

organizations from making contributions to campaign committees, it is important to avoid coordination 

with corporations and labor organizations regarding communications outside the restricted class except to 

the extent permitted under FEC regulations, as described in the next section.

Communications to restricted class

When a corporation or labor organization communicates with its restricted class, it may issue express 

advocacy communications and solicitations for candidates. It may also coordinate its communications with 

a candidate.13 Communications to the restricted class include, but are not limited to the examples listed in 

this section. See generally 114.3.

10 For information on a campaign’s use of corporate/labor facilities, see Section 9, this chapter.

11 If a member is incorporated, a membership organization or trade association would communicate with the personnel of the 

member corporation with whom they normally conduct business. See the Campaign Guide for Corporations and Labor Organizations for 

more information.

12 For the purposes of 11 CFR part 109 only, “agent” is defined at 11 CFR 109.3.

13 While this coordination does not transform the restricted class communication into an in-kind contribution, it may provide 

evidence that could jeopardize the independence of future communications to those outside the restricted class by the organization or 

its SSF. 114.2(c).
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Chapter 7

Candidate appearances before the restricted class

Location of appearance

The corporation or labor organization may allow a candidate to appear at a meeting, convention, via a 

teleconference or at some other function of the corporation or labor organization. 114.3(c)(2)(i) and AO 

2007-14 (ABC/NFIB/NRA).

Express advocacy

Both the candidate and the corporation or labor organization may expressly advocate the election or defeat 

of the candidate, other candidates or the party. See 114.3(a) and (c).

Coordination with the candidate

A corporation or labor organization may confer with the candidate on the structure, format and timing of 

the appearance.14 114.3(a)(1); 114.4(b)(1)(vii).

Solicitations

The candidate may solicit and accept contributions from the restricted class before, during or after the 

appearance. 114.3(c)(2)(ii). This includes giving out telephone numbers and addresses, and leaving 

campaign materials and mailing envelopes at the appearance site.15 The corporation or labor organization 

may also suggest that its restricted class make contributions to a candidate, but may not collect any 

contributions before, during or after the meeting. 114.3(c)(2)(iii).

In addition to soliciting contributions to be sent directly to the candidate, a corporation or labor 

organization may solicit contributions earmarked for a particular candidate. These earmarked contributions 

must be collected by and forwarded through the SSF of the corporation or labor organization and must be 

considered contributions both to and from the SSF. The contribution will count, therefore, against the limits 

of both the contributor and the SSF. 114.2(f)(2)(iii). For information about the solicitation and collection 

of earmarked contributions, see Appendix A.

Presence of people outside of the restricted class

The corporation or labor organization may allow, to a limited degree, the attendance of the following 

individuals who are outside of the restricted class at the appearance:

• Employees who are outside the restricted class but who are necessary to administer the meeting;

• Other guests who are being honored, are speaking or are participating in the event; and

• News media (see “Allowing Media Coverage”). 114.3(c)(2)(i) and (iv).

Appearances by other candidates or party representatives

The corporation or labor organization may grant or deny other candidates and parties the opportunity to 

appear, as the organization desires. 114.3(c)(2)(i).

Allowing media coverage

If the corporation or labor organization allows more than one candidate for the same office to appear and 

permits the media to cover the appearance of one candidate, it must permit media coverage of the other 

candidate(s) for that office as well. Similarly, if one party’s representative is permitted media coverage, then 

an appearance by any other party’s representative must also be permitted media coverage. 114.3(c)(2)(iv).

14 However, coordination with the candidate may compromise the independence of future communications (such as independent 

expenditures or electioneering communications) to individuals beyond the restricted class by either the corporation, labor 

organization or its SSF. See 114.2(c), 114.3(a)(1) and 109.21.

15 See the Explanation and Justification for 114.3(c)(2) at 60 Fed. Reg. 64266 (December 14, 1995), available on FEC.gov.
53

Sources of Support

Appearances before all employees and their families

Who may attend

A corporation or labor organization may sponsor candidate appearances that are attended by all members of 

the restricted class (including their families), as well as all other employees and their families, other honored 

guests, speakers, participants and the news media (if invited). 114.4(b)(1) and (e). See AO 2007-14 (ABC/

NFIB/NRA).

Location of appearance

The corporation or labor organization may allow the appearance at a meeting, at a convention or at some 

other function of the corporation or labor organization. 114.4(b)(1) and (2). Alternatively, the appearance 

may take the form of a teleconference. AO 2007-14 (ABC/NFIB/NRA).

Express advocacy

The candidate may expressly advocate his or her election, but the corporation or labor organization may 

not do so in conjunction with a candidate appearance, nor may it encourage its employees to do so. Such 

communications to an audience beyond the restricted class will result in a prohibited contribution to the 

candidate. 114.4(b)(1)(v) and (b)(2)(ii).

Coordination with the candidate

The corporation or labor organization may coordinate with the candidate concerning the timing, structure 

and format of the appearance, and on the candidate’s position on issues. Coordination regarding the 

campaign’s plans, projects and needs, however, will result in a prohibited in-kind contribution. 109.21, 

114.2(c) and 114.4(b)(1)(vii).

Solicitations

A corporation (including its SSF or any employee) or labor organization (including its SSF, any official, 

member or employee) may not solicit, direct or control contributions in conjunction with any candidate 

appearance before those outside the restricted class. 114.4(b)(1)(iv) and (b)(2)(i).

While attending the event, the candidate may solicit but may not accept contributions before, during or after 

the appearance. The candidate may, however, leave envelopes and campaign materials for members of the 

audience. 114.4(b)(1)(iv) and (b)(2)(i).

Equal opportunity

The organization also must allow other candidates for the same office to appear, if they request to do so. The 

following guidelines apply:

• If a candidate for the House or Senate is allowed to make an appearance, all other candidates for that seat 

must be given a similar opportunity upon request. 114.4(b)(1)(i).

• If a Presidential or Vice Presidential candidate is allowed to make an appearance, all candidates for that 

office meeting the pre-established objective criteria for candidate debates under 110.13(c) must be given 

a similar opportunity upon request. 114.4(b)(1)(ii).

• If representatives of a political party are allowed to make an appearance, representatives of all political 

parties that either had a candidate on the ballot in the last general election, will have a candidate on the 

ballot in the next general election or are actively engaged in placing a candidate on the ballot in the next 

general election must be given a similar opportunity upon request. 114.4(b)(1)(iii).

• Candidates should be provided with similar amounts of time and similar locations as other candidates are 

provided. 114.4(b)(1)(vi).

Publications

A corporation or labor organization may distribute election related publications (e.g., print, broadcast, video, 

e-mail and web-based) to its restricted class.
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Chapter 7

Distribution of publications to restricted class

Express advocacy

A corporation or labor organization may distribute publications to its restricted class on any subject. This 

includes publications expressly advocating the election or defeat of a clearly identified candidate or a 

party’s candidate. 114.3(a). See “Endorsements” in this section.

Coordination with candidate

The corporation or labor organization may discuss campaign issues at length with the candidate; however, 

discussion concerning how to contour a communication for the benefit of the campaign would constitute 

coordination and may jeopardize the independence of future corporate/labor organization communications 

to individuals beyond the restricted class. 109.21 and 114.2(c). See also AO 1996-01 (Trial Lawyers of 

America).

Solicitation

The publication may solicit contributions for a candidate or a party. The rules for soliciting contributions 

from the restricted class through a publication are the same as those for soliciting during a candidate 

appearance before the restricted class. See “Candidate appearances before the restricted class” in this 

chapter. 114.2(f)(4)(ii).

Content

The views communicated in the publication must be those of the corporation or labor organization and 

must not be a republication or reproduction of the candidate’s campaign materials including broadcasts and 

written or graphic materials. The corporation or labor organization may, however, use brief quotations from 

candidate materials and speeches that demonstrate the candidate’s position as part of the corporation’s or 

labor organization’s expression of its own views. 114.3(c)(1)(ii).

Endorsements

A corporation or labor organization may announce its candidate endorsement at an appearance by a 

candidate before, or in a publication sent to, its restricted class (no more than a de minimis number of 

copies of the publication that includes the endorsement may be distributed beyond the restricted class). 

These communications may be coordinated with candidates. 114.4(c)(6)(iii); 114.3(a). For examples, 

see AOs 1997-22 (Business Council of Alabama), 1997-16 (ONRC Action), 1996-21 (Business Council of 

Alabama) and 1996-01 (Trial Lawyers of America).

Communications to those outside the restricted class

Candidate appearances

A corporation or labor organization may pay for a candidate or a candidate’s representative to appear before 

the general public in the following situations:

• Officeholder/professional (i.e., noncampaign-related) appearances;

• Public debates; and

• Public appearances at educational institutions.

Officeholder/professional appearance at corporation or labor organization

Under certain circumstances, a corporation or labor organization may sponsor an appearance by a 

candidate before the general public. For example, the Commission has permitted the following appearances:

• Incumbent officeholders giving a speech to a nonprofit organization regarding its main issue (AO 1996-

11 (NRL)); and

• A non-incumbent, who had in prior speeches to college and university audiences discussed his ideas 

regarding current statutes and future legislation, giving a college lecture on a topic that reflected his 

career as a state legislator (AO 1992-06 (Duke)).
55

Sources of Support

In these advisory opinions, the Commission noted these important points:

• The speaker did NOT appear in his capacity as a federal candidate but rather as a current federal 

officeholder or as a lecturer;

• The speaker could speak about issues of interest to the sponsoring organization, including legislative 

issues, but was required to avoid referring to the campaign;

• Neither the speaker nor the organization would expressly advocate the election or defeat of a clearly 

identified candidate;

• Neither the speaker nor the organization would solicit contributions before, during or after the event; 

and

• Any contribution from the organization’s political committee to the speaker’s political committee 

would not be in consideration for the speaker’s appearance.

Payment of travel expenses

A corporation or labor organization may pay the speaker’s travel expenses as long as no part of the trip is 

campaign related. If any campaign related activity is conducted at a stop, the entire stop is campaign related 

and travel expenses must not be paid by the sponsoring organization. AO 1996-11 (NRL).16

Public debates

Sponsorship

A tax-exempt nonprofit organization (a 501(c)(3) or 501(c)(4)) that does not endorse, support, or oppose 

candidates or parties may stage candidate debates. 110.13(a)(1) and 114.4(f)(1).

Candidate debates may also be staged by a broadcaster, a bona fide newspaper, a magazine or other 

periodical publication as long as they are not owned or controlled by a political party, committee, or 

candidate. 110.13(a)(2) and 114.4(f)(2).

Corporate/labor donations permitted

A corporation or labor organization may donate funds to a tax-exempt nonprofit organization that does not 

endorse, support, or oppose any candidate or party to defray the cost of staging a candidate debate. 114.4(f)

(1) and (3).

Debate structure

The debate must include at least two candidates and must be structured so that it does not promote or 

advance one candidate over another. 110.13(b).

Candidate selection

The organization staging the debate must select the candidates based on pre-established objective criteria. 

For primary elections, the organization may restrict candidates to those seeking the nomination of one 

party. For general elections, the staging organization may not use nomination by a particular party as the 

sole objective criterion. 110.13(c).

Appearance at educational institutions

Candidates or party representatives may make appearances at educational institutions (any school, college 

or university, including both an incorporated nonprofit tax exempt private school and an unincorporated 

16 In AO 1996-11 (NRL), the corporation sponsoring the appearances of two officeholders who were running for re-election could 

not pay the officeholders’ travel expenses because the organization had knowledge that the officeholders’ campaigns were planning 

campaign-related events at the site of the appearance. Payment of their travel expenses would have constituted a prohibited corporate 

contribution.
56

Chapter 7

tax exempt public school).17 The institution may make its facilities available at either the usual and normal 

cost for campaign events, or at a discount or for free for academic events. If the institution makes its 

facilities available at a discount or for free, the institution must:

• Make reasonable efforts to ensure that the appearance constitutes a speech, question and answer 

session, or similar communication and not a campaign appearance or event;

• Not expressly advocate the election or defeat of any federal candidate or candidates of any political 

party in conjunction with the appearance; and

• Not favor any candidate or party in allowing the appearance. See 110.12(a)-(b) and 114.4(c)(7)(i)-(ii).

Other election related communications

A corporation or labor organization may prepare and distribute other election-related communications 

(e.g., print, broadcast, video, e-mail and web-based) to the general public. A non-exhaustive list of possible 

communications is provided in the Campaign Guide for Corporations and Labor Organizations.

These communications may contain express advocacy but must not be coordinated with any candidates or 

political parties (except as provided by law). In addition, the communications must not solicit contributions 

for a candidate or party. Either of these actions would result in a prohibited contribution. See 114.4(c)(1), 

114.2(f). Finally, if any of these communications meet the definition of an independent expenditure or 

electioneering communication (see Sections 11 and 12), then they must be reported as such.

9. Use of Corporate/Labor Facilities and Resources

When using the facilities and resources of a corporation (including an incorporated trade association 

or membership organization) or labor organization, a campaign must pay the organization according to 

the rules described in this section. Otherwise, the use may result in a prohibited contribution from the 

corporation or labor organization.

Facilities

If a campaign uses the facilities of a corporation or labor organization, the campaign must reimburse 

the organization within a commercially reasonable time and at the usual and normal rental charge. Use 

of facilities may include, for example, the use of telephones, typewriters or office furniture. 114.9(d). 

If another political committee or an individual reimburses a corporation or labor organization for 

the campaign-related use of its facilities, the payment is considered an in-kind contribution from 

that committee or individual to the campaign. (In the case of a political committee sponsored by the 

organization providing the facilities, it is also advisable that payment be made to the organization in 

advance in order to avoid a prohibited contribution from the organization.) Note, however, that employees, 

stockholders and members of a corporation or labor organization may make incidental use of an 

organization’s facilities, subject to the corporation or labor organization’s own rules, for volunteer work 

without having to reimburse the organization (except for any increased overhead), as explained in Section 3 

of this chapter. 114.9(a) and (b).

Meeting rooms

Usual and normal rental rate

Candidates and political parties may, at the discretion of the organization, rent a corporation or labor 

organization’s meeting rooms at the usual and normal rate, provided reimbursement is made within a 

commercially reasonable time. 114.9(d).

17 Tax exempt nonprofit institutions are advised to review the Internal Revenue Service requirements regarding the effect of political 

activity and continuing nonprofit status.
57

Sources of Support

Provided by organization’s political committee

As with other facilities, if the organization’s political committee pays for the room as an in-kind 

contribution, it is advisable that payment be made in advance to avoid a prohibited contribution from the 

organization.

For free or at a discount

A candidate may be able to use the rooms for free or at a discount under the following conditions:

• The corporation or labor organization customarily makes its meeting rooms available to civic and 

community groups;

• The corporation or labor organization makes the rooms available to other candidates upon request; and

• The corporation or labor organization makes the rooms available to the candidates on the same terms 

given to other groups (i.e., for free or at a discount if those are the terms offered to other groups).

114.13.

Use of corporate/labor name or trademark

A corporation or a labor organization may not use the corporation’s names, trademarks or service marks to 

facilitate the making of contributions to a federal political committee, and a federal political committee may 

not knowingly accept or receive such facilitated contributions. For example, a campaign may not recognize 

the corporate (or labor) employers of individual contributors in connection with a fundraising event. These 

restrictions do not apply to the use of a name as part of the name of a political committee. 114.2(d) and (f). 

See AO 2007-10 (Reyes).

10. Fundraisers for Candidates

Restricted class events

Under the exemptions at 114.3(c)(2) permitting candidate appearances before the restricted class 

(summarized in Section 8 of this chapter), the corporation or labor organization may allow a candidate 

to solicit its restricted class at an event without the related costs for the event counting as a contribution. 

The candidate may also collect funds at the appearance. However, corporate or labor organization staff 

are prohibited from collecting funds for the campaign, with a limited exception discussed in the next 

paragraph. 114.2(f) and 114.3(c)(2)(ii) and (iii).

Collection of funds

An exception to the general prohibition on corporate or labor organization staff’s collection of funds at a 

candidate’s fundraising event exists in cases where the fundraiser is a restricted-class only event and the 

funds collected are treated not only as contributions to the candidate, but also as contributions both to and 

from the SSF of the corporation/labor organization. 114.2(f)(2)(iii) and (4)(iii). In this case, the event 

may not raise funds in excess of the SSF’s candidate contribution limit ($5,000 for a multicandidate PAC). 

Alternatively, the campaign may collect the funds.

Events beyond the restricted class

Event sponsored by corporate/labor SSF

The organization’s SSF may sponsor fundraising events for candidates and invite outside individuals and 

political committees. 114.5(i). All related costs paid for by the SSF, including staff time, mailing, room 

rental and catering charges, may count as an-kind contribution to the candidate, depending on whether the 

event is coordinated with the candidate or campaign. 109.20(b) and 100.52(d). Note that, as with other 

uses of corporate/labor facilities, the SSF must pay in advance for any use of corporate/labor staff, food 

service or mailing lists. Additionally, it is advisable that the SSF pay for rooms and equipment in advance to 

avoid a prohibited contribution from the organization.
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Chapter 7

Use of corporate/labor staff, food services and mailing lists for events beyond the restricted 

class

A corporation or labor organization may only allow its food services and mailing lists to be used for 

candidate fundraisers if it receives payment in advance at the fair market value for the goods or services. 

114.2(f)(1) and (2). Likewise, a corporation or labor organization may direct its personnel to work on 

these fundraisers, so long as employees are not coerced into providing on-the-job fundraising services 

if they do not wish to perform them. In all cases, advance payment by a source that may legally make a 

contribution or expenditure (such as the campaign or the organization’s SSF) is required in order to avoid a 

prohibited contribution by the organization. FEC regulations specifically require advance payments for:

• The services of corporate or labor personnel directed to carry out candidate fundraising activities as 

part of their job;

• The use of the organization’s list of clients, customers, vendors or other persons outside the restricted 

class for purposes of soliciting contributions or distributing invitations; and

• The use of catering or other food services arranged for or provided by the corporation or labor 

organization.

114.2(f)(2)(i)(A), (C) and (E).

Note, however, that if a corporation is providing the services (such as catering or personnel) in its ordinary 

course of business as a commercial vendor, payment does not have to be made in advance as long as: (1) 

the payment is at the usual and normal charge; and (2) the payment schedule conforms to normal business 

practice. Otherwise, a prohibited contribution results. 100.52(d)(1) and (2); 114.2(f)(1); 116.3; see also, 

for example, AOs 1994-33 (VITEL) and 1991-18 (New York Democrats).

Collection of funds

As with restricted-class only events, corporate or labor organization staff may not collect contributions 

at an event that is coordinated, unless the funds collected are treated not only as contributions to the 

candidate, but also as contributions both to and from the SSF of the corporation/labor organization. 

114.2(f)(2)(iii) and (4)(iii). Alternatively, the campaign may collect the funds.

Reporting

If the campaign makes the advance payment for the costs of the event, it must report the cost as a campaign 

expenditure. If the advance payment is made by any other source, such as the corporation or labor 

organization’s SSF or an individual, the campaign must report it as an in-kind contribution received, where 

the event’s costs are required to be treated as an in-kind contribution. 104.3(a) and (b).

11. Independent Expenditures

An independent expenditure is an expenditure for a communication that expressly advocates the election 

or defeat of a clearly identified candidate and which is not made in coordination with any candidate or his 

or her campaign or political party. 100.16, 109.21 and 109.37. Independent expenditures are not subject 

to any amount limitations but may be subject to reporting requirements. (The campaign of a candidate 

benefiting from an independent expenditure has no reporting obligation.) See Citizens United v. FEC and 

AOs 2010-11 (Commonsense Ten) and 2010-09 (Club for Growth).

Appendix D provides detailed information on independent expenditures. The appendix may be reproduced 

and distributed by a campaign to anyone who requests FEC guidelines on independent spending. Campaign 

staff should pay special attention to the section “Coordinated communications” which explains when the 
59

Sources of Support

independence of an expenditure is compromised through contact with a campaign and thus results in an 

in-kind contribution, subject to contribution limits, to the campaign. If a corporation or labor organization 

funds the coordinated expenditure, it results in a prohibited contribution.

12. Electioneering Communications

Any broadcast, cable or satellite communication that is publicly distributed within 30 days of a primary or 

60 days of a general election, refers to a clearly identified federal candidate and is targeted to the relevant 

electorate is an electioneering communication. 100.29(a).

If a registered political committee makes an electioneering communication, it must report it as it reports an 

expenditure or independent expenditure under the Act. 104.20(b).

Coordination of electioneering communications

If a communication is considered coordinated under the Commission’s three-part test, it results in an inkind contribution subject to contribution limitations, source prohibitions and reporting. To avoid receiving 

an illegal excessive or prohibited contribution, campaigns should avoid certain interactions with those 

making electioneering communications. See 109.21(d) and Appendix D, Section 2 for more information.
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Chapter 7
61

CHAPTER 8

Expenditures and Other Uses of Campaign Funds

The Federal Election Campaign Act (the Act) places certain restrictions on the use of campaign funds, as 

explained in this section.1

For reporting purposes, it is important to understand the term “expenditure,” because expenditures count 

toward the threshold that determines whether an individual is a candidate under the Act. 100.3(a). An 

expenditure is a purchase, payment, distribution, loan, advance, deposit or gift of money or anything of 

value made to influence a federal election. 100.111(a).

“Disbursement” is a broader term that covers both expenditures and other kinds of payments (those not 

made to influence a federal election). All disbursements must be reported by the campaign.

1. Permissible Uses of Campaign Funds 

Campaign-related expenses

The Act allows campaign funds to be used for purposes in connection with the campaign to influence the 

federal election of the candidate. 52 U.S.C. §30114(a); 113.2.

Operating expenditures

Payments for day-to-day expenses, such as staff salaries, rent, travel, advertising, telephones, office supplies 

and equipment, fundraising, etc., are permissible operating expenditures. Interest paid on a loan is also 

considered an operating expenditure. AO 1991-09 (Hoagland).

Certain other expenses are considered to be permissible operating expenditures on a case-by-case basis, 

including meal, travel, vehicle and legal expenses.2 For example, if a campaign pays for the candidate’s travel 

and subsistence in connection with his or her campaign activities, those payments are also considered 

operating expenditures. Generally, as long as such expenses would not exist irrespective of the candidate’s 

campaign or duties as a federal officeholder, they are considered permissible. See Section 2, “Case-by-case 

determination of personal use,” for more information.

Loan repayments

The repayment of both the principal and the interest of a loan owed by the committee are permissible 

expenses. Repayments of the principal are not considered to be a “payment” for the purposes of the 

definition of expenditure, and thus are itemized separately on the FEC report. 100.111(c). Repayments 

of the interest on a loan are considered operating expenditures for reporting purposes. See Chapter 13, 

Section 22, “Reporting Loans,” for information on reporting loan repayments.

Transfers to other authorized committees

Funds may be transferred between authorized committees of the same candidate (for example, from a 

previous campaign committee to a current campaign committee) without limit as long as the committee 

making the transfer has no net debts outstanding. 110.3(c) and 116.2(c)(2). See, for example, AO 1987-04 

1 Note that the use of campaign funds is also addressed in House and Senate rules, over which the Commission has no jurisdiction (see 

Appendix G).

2 However, using campaign funds to pay for a candidate’s living expenses is prohibited. See 113.1(g)(1)(ii); “Personal Use of 

Campaign Funds.”
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Chapter 8

(Glenn). See Chapter 9, “Transfers,” and Chapter 13, Section 26, “Reporting Transfers between Authorized 

Committees” for more information.

Alternatively, a candidate may redesignate a former campaign committee as the principal campaign 

committee of his or her current campaign and use the excess funds of the previous campaign in the current 

campaign. AO 1980-30 (Askin).

Refunds of contributions

Campaigns may refund any contribution but must refund (or otherwise disgorge) a contribution that is 

from a prohibited source or in excess of the contribution limits. See Chapter 5, Section 2, “Questionable 

Contributions,” for more information. For information on reporting refunds, see Chapter 13, Section 25, 

“Reporting Refunds, Returns, Bounced or Unchashed Checks and Disgorged Contributions.”

In-kind contributions

Any in-kind contribution received by a committee must be reported as an operating expenditure (even 

though money has not been expended by the committee) in addition to being reported as a contribution 

received. 104.13(a). This reporting adjustment allows the committee to balance its cash on hand. For more 

information and an example of reporting in-kind contributions, see Chapter 13, “Completing FEC Reports.”

Written agreements to make expenditures

A written agreement to make an expenditure, such as a media contract, constitutes an expenditure. 100.112. 

For information on reporting expenditures and debts incurred, see Chapter 13, “Completing FEC Reports.”

Ballot initiatives and other nonfederal communications

A campaign may support or oppose ballot initiatives as permissible campaign-related expenses. For 

example, payments for ads in which a candidate endorses a ballot initiative on an issue with which he or she 

is closely associated are expenditures in connection with the campaign. AOs 2006-04 (Tancredo) and 2004-

29 (Akin). A campaign may also make donations to committees that support or oppose ballot initiatives 

under state election laws. Such donations are considered expenditures under the Act. See AO 2004-29 

(Akin). Special rules apply to a federal candidate or officeholder’s fundraising for such organizations, see 

Appendix E, Section 1.

A campaign may also make expenditures for communications that expressly advocate for both the federal 

candidate and nonfederal candidates. The Commission concluded in AO 2014-03 (Lindsey for Congress) 

that a campaign’s expenditures for advertisements that support the federal candidate as well as nonfederal 

candidates who share the federal candidate’s policy positions and values further the federal candidate’s own 

candidacy and are “in connection with” a federal election. 

Non-campaign related expenses

Additionally, campaign funds may be used for the following purposes that are not related to the candidate’s 

campaign for federal office: 

• To defray the ordinary and necessary expenses incurred in connection with an individual’s duties as a 

federal officeholder,3 such as:

– Travel expenses for a federal officeholder and his or her accompanying spouse and children, provided 

that the travel is undertaken to participate in a function that is directly connected to the officeholder’s 

bona fide official responsibilities. 113.2(a)(1). See, for example, AOs 2005-09 (Dodd) and 1997-02 

(Skaggs / LaHood);

3 House and Senate rules may apply; see Appendix G.
63

Expenditures and Other Uses of Campaign Funds

– Winding down costs of a federal officeholder’s office for a period of six months after leaving office. 

113.2(a)(2). See, for example, AOs 1996-44 (Wilson) and 1996-14 (de la Garza) (House and Senate 

rules may apply); see AOs 2000-37 (Udall) and 1996-45 (Roybal-Allard); and see Appendix G);

• Donations to charities (organizations defined in 26 U.S.C. §170(c) of the Internal Revenue Code).4

113.2(b). See, for example, AO 2005-06 (McInnis);

• Unlimited transfers to any national, state or local party committee. 113.2(c). See, for example, AO 

2004-22 (Bereuter);

• Donations to state and local candidates, subject to the provisions of state law. 113.2(d). See 52 U.S.C. 

§30114(a)(5); and

• Any other lawful purpose, unless expressly prohibited by the Act. 113.2(e). See 52 U.S.C. §30114(a)(6). 

(Prohibited purposes are summarized in the next section.)

Contributions to other federal and nonfederal candidates

A federal candidate committee may contribute up to $2,000 per election to the committee of another 

federal candidate. 102.12(c)(2) and 102.13(c)(2). 

Donations from federal candidate committees to state, local or foreign candidates are permissible uses of 

campaign funds but are subject to the relevant state or foreign laws. See 113.2(d), 300.62; AO 2015-06 

(Maxine Waters). 

For information on reporting contributions and donations to other candidates, see Chapter 13, Section 19.

2. Prohibited Uses of Campaign Funds

Certain air travel

Title VI, Section 601 of the Honest Leadership and Open Government Act of 20075 (HLOGA) significantly 

restricts the use of campaign funds for air travel by federal candidates and officeholders.6 In general, 

expenditures from campaign funds for non-commercial air travel are prohibited unless they are in 

accordance with 100.93. 113.5. See Chapter 10, Section 4, “Campaign Travel” for further information.

Personal use of campaign funds

Using campaign funds for personal use is prohibited. 52 U.S.C. §30114(b)(1) and 113.1(g). Commission 

regulations provide a test, called the “irrespective test,” to differentiate legitimate campaign and 

officeholder expenses from personal expenses. Under the “irrespective test,” personal use is any use of 

funds in a campaign account of a candidate (or former candidate) to fulfill a commitment, obligation or 

expense of any person that would exist irrespective of the candidate’s campaign or responsibilities as a 

federal officeholder. 113.1(g). More simply, if the expense would exist even in the absence of the candidacy 

or even if the officeholder were not in office, then the personal use ban applies. Conversely, any expense 

that results from campaign or officeholder activity falls outside the personal use ban.

Example: A candidate may not make tuition payments with campaign funds, unless the costs are associated 

with training campaign staff. See 113.1(g)(1)(i)(D). 

4 Campaign funds may not be converted to personal use. Commission regulations state that donations of campaign funds to a 

charitable organization do not constitute the personal use of campaign funds unless the candidate (former or current) receives 

compensation from the donee organization before the organization has expended, for purposes unrelated to the candidate’s personal 

benefit, the entire amount donated by the campaign. 113.1(g)(2). See Section 2.

5 Pub. L. No. 81, 121 Stat.735.

6 The provisions of HLOGA also apply to nonconnected committees (known as “leadership PACs”) sponsored by candidates for the 

House of Representatives.
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Chapter 8

What is not personal use

In addition to the “irrespective test,” Commission regulations include other uses of funds that do not 

constitute personal use and thus are permissible uses of campaign funds. 113.1(g) and 113.2.

Charitable donations

Gifts to charity are not considered personal use expenses as long as neither the candidate nor any member 

of the candidate’s family receives compensation from the charitable organization before it has expended 

the entire amount donated. Note that the amount donated must have been used for purposes that do not 

personally benefit the candidate. 113.1(g)(2). See also AOs 2005-06 (McInnis), 1997-01 (Bevill), 1996-40 

(Hancock) and 1994-20 (Charlie Rose).

Transfer of campaign assets

The sale or transfer of a campaign asset (see Chapter 14, “Winding Down the Campaign”) to either the 

candidate or a third party does not constitute personal use as long as the transaction is made at the fair 

market value. 113.1(g)(3).

Gifts

On special occasions, campaign funds may be used to purchase gifts or make donations of nominal value to 

persons other than the members of the candidate’s family. 113.1(g)(4).

Candidate salary

The candidate may receive a salary from his or her campaign committee only under the following 

conditions:

• The salary must be paid by the principal campaign committee;

• The salary must not exceed the lesser of the minimum annual salary for the federal office sought or the 

earned income that the candidate received during the year prior to becoming a candidate;

• Individuals who elect to receive a salary from their campaign committees must provide income tax 

records and additional proof of earnings from relevant years upon request from the Commission;

• Payments of salary from the committee must be made on a pro-rata basis (i.e., a candidate may not 

receive a whole year’s salary if he or she is not a candidate for an entire twelve-month period);

• Incumbent federal officeholders may not receive a salary payment from campaign funds; and

• The first payment of salary shall be made no sooner than the filing deadline for access to the primary 

election ballot in the state in which the candidate is running for office, or, in those states that do not 

conduct primaries, on January 1 of each even-numbered year.

Salary payments may continue until the date when the candidate is no longer considered a candidate for 

office or until the date of the general election or general election runoff. For special elections that occur in 

odd numbered years, payments may continue from the date that the special election is set until the date of 

the special election. 113.1(g)(1)(i)(I).

Automatic personal use

The regulations list some expenses that are automatically considered to be personal use. Based on these 

rules, the following paragraphs discuss what kinds of expenses the campaign can and cannot pay for.

Household food items and supplies

The candidate cannot use campaign funds to pay for food purchased for daily consumption inside the home 

or supplies needed to maintain the household. The campaign may, however, pay for food and supplies 

for fundraising activities and campaign meetings (even when they take place in the candidate’s home). 

113.1(g)(1)(i)(A).
65

Expenditures and Other Uses of Campaign Funds

Funeral, cremation and burial expenses

Campaign funds cannot be used to cover expenses related to deaths within the candidate’s family. They 

may, however, be used to cover funeral, cremation and burial expenses for a candidate or campaign worker 

whose death arises out of, or in the course of, campaign activity. 113.1(g)(1)(i)(B).

Clothing

The campaign cannot pay for attire for political functions (for example, a new tuxedo or dress), but it can 

pay for clothing of de minimis value that is used in the campaign, such as T-shirts or caps imprinted with a 

campaign slogan. 113.1(g)(1)(i)(C).

Tuition payments

Campaign funds may not be used for tuition payments unless the payments are associated with training 

campaign staff. 113.1(g)(1)(i)(D). In AO 1997-11 (Roybal-Allard), the Commission allowed a federal 

officeholder to use campaign funds to cover her costs for a Spanish immersion class that she took to better 

communicate with her constituents.

Mortgage, rent or utility payments

The campaign may not pay for mortgage, rent or utilities for the personal residence of the candidate or the 

candidate’s family even if part of the residence is being used by the campaign. 113.1(g)(1)(i)(E). 

For example, a campaign committee may not rent space in the candidate’s home, but it may rent part of an 

office building owned or leased by the candidate for use in his or her campaign, as long as it pays no more 

than the fair market value for the space. AO 1995-08 (Stupak). See also AO 2000-02 (Hubbard).

However, the Commission has allowed the use of campaign funds to pay for home security enhancements 

made in response to threats to an officeholder’s safety. In these cases, the security upgrades were not 

considered personal use because the threats and need for security upgrades would not exist irrespective 

of the officeholders’ candidacy or duties as an officeholder. AOs 2017-07 (Sergeant at Arms), 2011-17 

(Giffords), 2011-05 (Terry) and 2009-08 (Gallegly). Campaign funds may also be used to pay for security 

measures to protect an officeholder’s personal electronic devices and accounts from cyber threats that 

result from the officeholder’s role as an elected official. AO 2018-15 (Wyden). 

In addition, the campaign may pay for long distance calls made for campaign purposes from the candidate’s 

residence or the residence of his or her family.

Investment expenses

The campaign may not pay for investment expenses such as acquiring securities on margin unless all of 

the investment and its proceeds are used for the purpose of influencing the candidate’s election for federal 

office or for one of the permissible non-campaign uses of funds discussed in Section 1.

Entertainment

The campaign may not pay for admission to sporting events, concerts, theater and other forms of 

entertainment. Campaign funds may be used, however, if the entertainment is part of a specific officeholder 

or campaign activity. They may not be used for a leisure outing at which the discussion occasionally focuses 

on the campaign or official functions.7 113.1(g)(1)(i)(F). 

Dues, fees and gratuities

Campaign funds may not be used to pay for dues to country clubs, health clubs, recreational facilities or 

other nonpolitical organizations unless the payments are made in connection with a specific fundraising 

event that takes place on the organization’s premises. See, for example, AO 1995-26 (Murkowski).

7 See the Explanation and Justification for the final rules, 60 Fed. Reg. 7866, February 9, 1995 available at FEC.gov.
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Chapter 8

However, campaign funds may be used for membership dues in an organization that may have political 

interests. 113.1(g)(1)(i)(G).

Example: A candidate or officeholder may use campaign funds to pay for a membership in a civic or 

community group in his or her district in order to maintain political contacts with constituents or the 

business community.8

Salary payments to candidate’s family

Campaign funds may be used to make salary payments to members of the candidate’s family only if:

• The family member is providing a bona fide service to the campaign; and

• The payments reflect the fair market value of those services. 113.1(g)(1)(i)(H). See also AOs 2001-10 

(Jackson) and 1992-04 (Cortese).

Any salary payments to family members in excess of the fair market value constitute personal use.

Case-by-case determination of personal use

For other expenses not mentioned in the previous section, the Commission will determine, on a case-bycase basis through the advisory opinion process, whether the expense is one that would exist irrespective 

of the candidate’s campaign or duties as a federal officeholder and would be considered a personal use 

expense. For example, the Commission addresses payments for meals, childcare, travel, vehicles, mixed-use 

and legal expenses on a case-by-case basis. 113.1(g)(1)(ii).

Meal expenses

Campaign funds may be used to pay for meals during face-to-face fundraising events. By contrast, a 

candidate may not use campaign funds to take his or her family out to dinner. 113.1(g)(1)(ii)(B).

Childcare expenses

Campaign funds may be used to pay for a candidate’s childcare expenses that are incurred as a direct result 

of campaign activity. AOs 2019-13 (MJ for Texas), 2018-06 (Liuba), 1995-42 (McCrery).

Travel expenses

Campaign funds may be used to pay the costs of travel to an activity that is related to the campaign or to 

the candidate’s duties as a federal officeholder. (Note, however, that 2007 changes to the statute mandate 

specific conveyances and payments. See “Certain Air Travel” in this chapter, and Chapter 10, Section 4 for 

more information.) Thus, campaign funds may be used to pay for the costs of travel for a candidate (and 

the candidate’s spouse and minor children) to functions directly related to the campaign or those directly 

connected to the individual’s official responsibilities as a federal officeholder. 113.2(a)(1); see AO 2005-

09 (Dodd). The regulations, however, prohibit the use of campaign funds for personal expenses collateral 

to travel—either campaign or officeholder—unless personal funds are used to reimburse the committee. 

113.1(g)(1)(ii)(C). See, for example, AOs 2002-05 (Hutchinson), 2000-37 (Udall) and 1996-19 (Walsh). 

See also “Mixed Use” for trips that involve both official/campaign and personal travel.

Vehicle expenses

Campaign funds may be used to pay for a vehicle that is used for campaign-related purposes, assuming 

that the costs related to the personal use of the vehicle are de minimis, that is, such costs are insignificant 

in relation to the overall vehicle use. AO 2001-03 (Meeks); 113.1(g)(1)(ii)(D). See also “Mixed Use” for 

vehicle use that involves both official/campaign and personal travel.

8 From the Explanation and Justification for the final rules, 60 Fed. Reg. 7867, February 9, 1995 available FEC.gov.
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Expenditures and Other Uses of Campaign Funds

Mixed use

In the event of travel or vehicle expenses that commingle personal and campaign or officeholder activity, 

the beneficiary of the personal use expenses must reimburse the committee within thirty days for the 

entire amount associated with the personal activities (the amount over and above what the cost would have 

been had the trip/vehicle use been solely for campaign/officeholder-related purposes). The reimbursement 

does not constitute a contribution. See, for example, AOs 1992-12 (LaRocco) and 1984-59 (Russo). The 

committee must maintain logs of the expenses to help the Commission determine on a case-by-case basis 

what portion was for personal use rather than for campaign-related activity or officeholder duties. 113.1(g)

(8). AO 2001-03 (Meeks).

Legal expenses

Using the “irrespective test” summarized in the previous section, the Commission decides on a case-by-case 

basis through the advisory opinion process whether legal expenses are considered “personal use” and thus 

are expenses that a candidate may not pay for using campaign funds. 113.1(g)(1)(ii)(A).

Relating to campaign or officeholder activity

In several advisory opinions, the Commission has said that campaign funds may be used to pay for up to 

100 percent of legal expenses related to campaign or officeholder activity, where such expenses would not 

have occurred had the individual not been a candidate or officeholder.

Examples:

• Legal expenses incurred in seeking ballot access in an upcoming congressional election (AO 2018-09 

(Clements));

• Litigation expenses where the candidate/officeholder was the plaintiff, provided he derived no financial 

benefit from court awards (AO 1997-27 (Boehner));

• Litigation expenses where the candidate/officeholder was the defendant and the litigation arose 

directly from campaign activity or the candidate’s status as a candidate (AOs 2009-10 (Visclosky), 

2003-17 (Treffinger) and 1995-23 (Shays));

• Expenses incurred in connection with investigations pertaining to the candidate/officeholder’s role as 

a candidate or officeholder (AOs 2009-12 (Coleman), 2005-11 (Cunningham), 1998-01 (Hilliard) and 

1997-12 (Costello));

• Expenses incurred in connection with investigations by the House or Senate pertaining to any activity 

conducted by the candidate/officeholder (AOs 2009-12 (Coleman), 2008-07 (Vitter) and 1998-01 

(Hilliard));

• Expenses incurred in responding to press inquiries pertaining to any of the previous (AOs 2009-12 

(Coleman), 2008-07 (Vitter), 2006-35 (Kolbe), 2005-11 (Cunningham), 2001-09 (Kerrey for U.S. 

Senate), 1998-01 (Hilliard) and 1997-12 (Costello));

• Use of campaign funds to post a deposit with which to pay opponent’s attorney fees pending the 

candidate’s appeal in a lawsuit arising directly from candidacy (AO 2013-11 (Miller)); and

• Litigation expenses arising from litigation involving former and current staff members of the 

candidate/officeholder, which relate to the candidate’s campaign and duties as a federal officeholder 

(AO 2009-20 (Visclosky)).

Relating to other activity

In specific situations, the Commission has concluded that campaign funds may be used to pay for up to 50 

percent of legal expenses that do not relate directly to allegations arising from campaign or officeholder 

activity (e.g. activity prior to becoming a candidate or officeholder or activity of a business owned by the 

candidate/officeholder) if the candidate or officeholder is required to provide substantive responses to 

the press regarding the allegations of wrongdoing. See, for example, AOs 2005-11 (Cunningham), 1998-01 
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Chapter 8

(Hilliard) and 1997-12 (Costello). However, the Commission did not allow campaign funds to be used to 

pay the legal expenses of voters who brought a lawsuit concerning special election scheduling because such 

expenses would exist irrespective of the candidate’s campaign for federal office. AO 2018-03 (Committee to 

Elect Michael Gilmore).

Salary, compensation and other payments made on behalf of candidates

General rule

Generally, when a third party (not the candidate or the candidate’s committee) pays for personal use 

expenses, the third party makes a contribution, subject to the restrictions and limitations of the Act. 

113.1(g)(6).

Exceptions

No contribution will result, however, if the payment would have been made irrespective of the candidacy. 

For example, a third party may make the following payments on behalf of a candidate without making a 

contribution:

• Payments to a legal expense trust fund established under House and Senate rules (see 113.1(g)(6)(i));

• Payments for personal living expenses made from funds that are the candidate’s personal funds, 

including an account the candidate holds jointly with a family member (see 100.153, and 113.1(g)(6)

(ii)); and

• Payments that began prior to candidacy. For example, if the candidate’s parents had been making 

college tuition payments for the candidate’s children, the parents could continue to do so during the 

campaign without making a contribution. See 100.153 and 113.1(g)(6)(iii).

Salary or compensation paid to candidate

Compensation paid to a candidate by a third party as a continuation of payments made prior to candidacy 

(for example, payments of salary) are not considered contributions as long as such payments:

• Result from bona fide employment independent of the candidacy;

• Are exclusively in consideration of the services provided as part of this employment; and

• Represent pay not in excess of that normally received for such services. 113.1(g)(6)(iii). See also AOs 

2006-13 (Spivack) and 2004-17 (Klein).

Promotion of candidate’s books

Generally, the expense of marketing a book would exist irrespective of a candidate’s campaign, and thus 

a campaign cannot ordinarily use its funds to pay such an expense. In limited situations, however, the 

Commission has permitted the use of campaign funds to promote a candidate’s book, as follows:

• A campaign could purchase bulk copies of the candidate’s book where the purchase is solely for the 

purpose of distributing books to campaign contributors and supporters, and the candidate would not 

receive any royalties attributable to the purchase. AOs 2014-10 (Farr), 2014-06 (Ryan).

• A campaign could incur de minimis costs to post on its website material promoting the book’s release 

and linking to an online bookseller. AO 2011-02 (Brown), 2006-07 (Hayworth).

• A campaign could incur costs for planning book-related events and handling press and public inquiries 

where the candidate donates royalties to charitable organizations and thus does not personally gain 

from the use of campaign assets to promote the book. AO 2006-18 (Granger).

See also AO 2008-17 (KITPAC), however, where the Commission concluded that payments to a co-author 

by the principal campaign committee would constitute personal use.
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CHAPTER 9

Transfers

This chapter describes the different types of transfers that authorized committees may receive and 

make. Transfers of funds and assets between federal committees authorized or established by the same 

candidate are generally unlimited because the committees are considered affiliated committees. However, 

an authorized committee of a federal candidate may not accept any transfers of funds or assets from a 

committee established by the same candidate for a nonfederal election. See Section 3.

1. Transfers between Candidate’s Committees for Same Office

In the same election

Funds and assets may be transferred without limit between a candidate’s principal campaign committee 

and the candidate’s other authorized committees for the same office during the same election. However, an 

authorized committee may not transfer funds to another authorized committee of the same candidate if the 

transferring committee has net debts outstanding. 110.3(a)(1)(i) and 116.2(c)(2).

Between primary and general election campaign in same election cycle

Funds that went unused in the primary election may be transferred without limit to a candidate’s general 

election campaign. 110.3(c)(3).

In different elections

Funds and assets may be transferred without limit between committees authorized by a candidate for the 

same office in different elections as long as the transferring committee does not have net debts outstanding. 

110.3(c)(4) and 116.2(c)(2). Note that, for the purposes of the contribution limits, contributions 

transferred from the previous campaign to the current campaign must be aggregated with contributions by 

the same contributors to the current campaign only if the transferred contributions were originally made:

• After the previous election was held; or

• After the candidate withdrew or otherwise ceased to be a candidate in the previous election.1

110.3(c)(4)(iii) and (iv).

See Chapter 4, Section 5, for information on how to determine the date when a contribution is made. Other 

rules also apply to contributions that a committee receives after an election; see Chapter 4, Section 4, 

“Designated and Undesignated Contributions.”

2. Transfers between Committees of Candidate Seeking More Than One 

Office

In the same election cycle

When an individual seeks election to more than one federal office during the same election cycle or 

overlapping election cycles, he or she must establish separate principal campaign committees and must 

1 An individual ceases to be a candidate in an election as of the earlier of the following dates: the date on which the candidate publicly 

announces that he or she will no longer be a candidate in that election for that office and ceases to conduct campaign activities 

with respect to that election; or the date on which the candidate is or becomes ineligible for nomination or election to that office by 

operation of law. 110.3(c)(4)(iv).
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Chapter 9

maintain completely separate campaign organizations. 110.8(d)(1). Contributors also have separate limits 

with respect to the separate campaigns of the same candidate. Special transfer rules apply to transfers 

between these committees. 

Examples:

• Candidate A runs for both the House and the Presidency in the 2024 primary election (as permitted by 

state law).

• Candidate B begins the 2022 election cycle as a House candidate, but later begins a campaign for a 

Senate seat in 2022.

Prohibited while “actively seeking” more than one office

No transfers of funds or assets may be made between a candidate’s separate campaign committees while 

the candidate is “actively seeking” more than one office at the same time. 110.3(c)(5) and 110.8(d)(2). In 

the previous examples, Candidate A would be prohibited from transferring funds because he was “actively 

seeking” two offices at the same time.

Additional rules prohibit any transfers to or from a campaign account of a Presidential candidate who 

has accepted public financing, regardless of the timing or amount of the transfer. 110.3(c)(5)(iii). This 

restriction would apply to Candidate A if he received public funds for his Presidential campaign. See AO 

1995-03 (Gramm ’96).

Definition of no longer “actively seeking”

Under FEC rules, a candidate is no longer “actively seeking” nomination or election to a particular office 

once he or she:

• Becomes ineligible for nomination or election to that office by operation of law;

• Publicly announces that he or she is withdrawing from one race and ceases to campaign for that 

election, other than fundraising to retire outstanding debts;

• Has filed a termination report (see Chapter 14, Section 1, “Terminating the Committee”); or

• Has notified the Commission in writing that his or her campaign will conduct no further activities with 

respect to that election, other than fundraising to retire outstanding debts. 110.3(c)(5)(i).

Guidelines for transfers when no longer “actively seeking” multiple offices

Once a candidate is no longer “actively seeking” election to more than one federal office, transfers between 

the two campaigns are permissible, within the following guidelines:

• The transferor committee’s available funds should be viewed as those contributions most recently 

received that add up to the amount of the transfer from cash on hand.

• The transferor committee must be able to demonstrate that such cash on hand contains sufficient funds 

at the time of the transfer that comply with the limitations and prohibitions of the Act to cover the 

amount transferred.

• Contributions transferred must be aggregated with any contributions made by the same contributor 

to the committee receiving the transfer. Amounts that would cause a contributor to exceed his or her 

per election contribution limit must be excluded from the transfer, i.e., the funds available for transfer 

would be reduced by such amounts.

110.3(c)(5)(ii).

By taking these steps, Candidate B in the previous example could transfer funds between her two 

campaigns once she was no longer “actively seeking” two offices at the same time. Note that the recipient 

committee will need to identify the contributors whose contributions are included in the transfer by using 

memo entries.
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Transfers

In different election cycles

When an individual seeks different offices in different election cycles, surplus funds from the earlier 

campaign that remain after the general election may be transferred to the later campaign without 

aggregating the contributions of the original contributor to the two committees.

Any funds transferred must not be composed of contributions that would be in violation of the Act. Also, 

the transferring committee must be able to demonstrate that its cash on hand contains sufficient funds at 

the time of the transfer that comply with the limitations and prohibitions of the Act to cover the amount 

transferred. 110.3(c)(4).

Example: Candidate X runs for the House in 2022, and for the Senate in 2024. Any surplus funds for the 

2022 House campaign that remain after the 2022 general election may be transferred to the 2024 Senate 

campaign. The 2024 Senate Committee would not have to disclose those contributors whose contributions 

to the 2022 House Committee were included in the transfer.

3. Transfers from Candidate’s Nonfederal Committee Are Prohibited

A candidate’s authorized (federal) committee may not accept funds or assets transferred from a committee 

established by the same candidate for a nonfederal election campaign. At its option, however, a nonfederal 

committee of the same candidate may refund its leftover funds to its contributors and may coordinate 

arrangements with the federal campaign for a solicitation of those same persons. The full cost of this 

solicitation must be paid by the federal committee. 110.3(d). See also AO 1996-33 (Colantuono).

4. Transfers of Joint Fundraising Receipts

Organizations or committees participating in joint fundraising activity may make unlimited transfers of 

joint fundraising proceeds, provided that no committee or organization receives more than its allocated 

share of the funds raised. 102.6(a)(1)(iii) and 110.3(c)(2). A committee receiving such a transfer must not 

only report the total amount transferred but must also itemize, as necessary, its share of gross proceeds as 

contributions from the original contributors. 102.17(c)(8)(i)(B). For more information, see Appendix C.

5. Transfers to Party Committee

Campaign committees may make unlimited transfers to any national, state or local party committee. 

113.2(c). They may also transfer excess recount funds to a recount account of a national party committee. 

See AO 2019-02 (Nelson for Senate).

6. What is NOT a Transfer

While each of the previous sections discusses transfers between committees, not all receipts or 

disbursements to other committees are transfers. The following are not transfers:

• Contributions to or from other candidates (federal or nonfederal);

• Contributions to or from PACs; and

• Contributions from party committees, although an authorized committee may make unlimited transfers 

to party committees. 113.2(c).

These transactions must not be reported as transfers. For information on reporting, see Chapter 13, 

“Completing FEC Reports”.
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Chapter 9
73

CHAPTER 10

Conducting the Campaign

This chapter outlines the rules that apply to three areas of campaign activity: fundraising, advertising 

and travel. It also details the rules that apply to disclaimer notices for communications by an authorized 

committee.

1. Fundraising

Fundraising notices

Certain statements by the campaign must be present on solicitations, as follows:

Authorization notice

When a campaign solicits contributions through public communications, or on a campaign website, it must 

include a clear and conspicuous notice on the solicitation stating that it was authorized and paid for by the 

campaign. For example: “Paid for by the Sam Jones for Congress Committee.” 110.11(a)(1) and (b)(1). See 

“Disclaimer Notices” later in this chapter for more information.

“Best efforts” rules

When making solicitations, committees and their treasurers must make “best efforts” to obtain, maintain 

and report the name, address, occupation and employer of each contributor who gives more than $200 in an 

election cycle. In order to show that the committee has made “best efforts,” solicitations must specifically 

request that information and inform contributors that the committee is required by law to use its best 

efforts to collect and report it. This request must be clear and conspicuous. 104.7(b). For details, see 

Chapter 11, Section 5, “Treasurer’s Best Efforts.”

IRS notice requirements

Section 6113 of the Internal Revenue Code requires political committees whose gross annual receipts 

normally exceed $100,000 to include a special notice on their solicitations to inform solicitees that 

contributions are not tax deductible. There are substantial penalties for failure to comply with this 

provision. Contact the IRS for more information (see Appendix G, Section 4, “Tax laws,” for contact 

information).

Fundraising on the internet

Campaign committees may solicit contributions over the internet as long as the solicitation includes the 

proper disclaimers. See 110.11, and “Disclaimer Notices,” later in this chapter; see also 104.7(b)(1) and 

Chapter 11, Section 5 on “Treasurer’s Best Efforts” for a discussion of obtaining contributors’ information. 

Committees may satisfy these requirements by online confirmation that the contribution complies with the 

federal limits and prohibitions and is not from a prohibited source. See, e.g., AOs 2011-13 (DSCC), 2007-30 

(Dodd), 1995-09 (NewtWatch).

Committee treasurers are also responsible for examining all contributions received for evidence of illegality 

and compliance with contribution limits. 103.3(b).

Joint fundraising

Campaigns may engage in joint fundraising with other committees. 102.17. For the rules that govern this 

special activity, see Appendix C.
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Chapter 10

Transmitting contributions

Forwarding contributions

Every person who receives contributions for a campaign must forward them to the treasurer of the 

candidate’s authorized committee within 10 days of receipt. The date of receipt is the date the person 

acting as a conduit obtains possession of a contribution. 102.8(a). See also Appendix A, “Earmarked 

Contributions.”

Forwarding records

A person receiving contributions for a campaign must also forward the following recordkeeping 

information along with the contributions:

• For contributions exceeding $50, the amount, date of receipt and the contributor’s name and address.

• For contributions exceeding $200, the complete identification of the contributor (full name and mailing 

address, occupation and employer), as well as the amount and date of receipt of the contribution.

102.8(a).

Timely forwarding of recordkeeping information to the recipient campaign committee is essential for 

proper reporting and disclosure, especially of last-minute earmarked contributions received during the 48-

Hour Notice period. For more information about filing 48-Hour Notices, see Chapter 12, Section 3, “When 

to Report”.

No commingling

Campaign receipts must not be commingled with personal funds of any individual, such as by depositing 

contributions in a personal account. 102.15.

Accepting contributions

General rule

A campaign is prohibited from knowingly accepting any contributions from prohibited sources. 52 U.S.C. 

§30116(f), 110.9, 110.20(g), 114.2(d).The treasurer of a political committee is responsible for examining 

all contributions to make sure they are not illegal (i.e., prohibited or excessive). See “Questionable 

Contributions,” Chapter 5, Section 2. 103.3(b).

Contributions from unregistered organizations

When campaigns accept contributions from groups that are not political committees registered with the 

FEC (such as state PACs, unregistered local party committees or nonfederal campaigns), they must make 

sure that the funds are permissible under the Act. See 300.61. This is important because campaign laws in 

some states permit nonfederal political groups to accept funds that would violate the limits and prohibitions 

of the Act. To avoid a possible violation of the Act, a campaign must be certain that an unregistered group 

making a contribution:

• Can demonstrate through a reasonable accounting method that it has sufficient federally permissible 

funds to cover the amount of the contribution or expenditure at the time it is made; or

• Has established a separate account containing only funds permissible under the Act.

102.5(b). See also AOs 1982-38 (Moynihan) and 2007-26 (Schock).

When itemizing a contribution from an unregistered organization in its report, a campaign should note 

that the contribution contains only federally permissible funds. Contributions from such unregistered 

organizations are subject to the $2,900 per election limit.1 110.1(b). These organizations should be aware, 

1 As noted in Chapter 4, Section 1, this limit is indexed for inflation and adjusted in odd-numbered years.
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Conducting the Campaign

however, that making contributions to federal campaigns and political committees may trigger their own 

registration as a federal political committee. State political action committees sponsored by corporations, 

labor organizations or trade associations, in particular, must register as federal separate segregated funds 

within 10 days of the decision to make a contribution to a federal candidate. Additional requirements 

regarding their solicitations also apply. See 100.5(b) and 102.1(c); see also AOs 2003-29 (Fraternal Order 

of Police), 1985-18 (Michigan Auto Club PAC) and 1982-40 (Ohio Farm Bureau Federation).2 Contributions 

by other types of unregistered organizations (for example, local party organizations or committees not 

sponsored by an incorporated entity or labor organization) count against the $1,000 per year aggregate 

registration threshold. See 100.5(a) and (c), 102.1(d).

Depositing funds

Within 10 days of receiving a contribution (or any receipt of money), the treasurer must deposit it in the 

campaign depository. 103.3(a). See Chapter 5, Section 2, “Questionable Contributions,” for information on 

depositing or returning questionable contributions.

Accounting for primary and general election contributions

If, before the primary election, a campaign receives contributions designated for the general election, 

it must use an acceptable accounting method to distinguish between primary contributions and general 

election contributions. Commission regulations suggest two accounting methods that are acceptable:

• Maintaining separate accounts for each election; or

• Maintaining separate books and records for each election.

102.9(e).

If the candidate does not advance to the general election, all general election contributions received by the 

committee must be refunded, redesignated or reattributed. See AO 1986-17 (Green).

2. Disclaimers

Disclaimer notices inform the public of who pays for certain communications, and whether or not a 

communication has been authorized by a candidate or candidate’s committee. Disclaimers must be 

presented in a clear and conspicuous manner to give the reader, observer, or listener adequate notice of the 

identity of the person or political committee that paid for the communication. 110.11(c)(1). See AO 2017-

05 (Great America PAC).

Disclaimer notices are required for any public communication made by a political committee, electronic 

mail of more than 500 substantially similar communications sent by a political committee, and all websites 

of political committees available to the general public.3 110.11(a)(1).

Public communications

A public communication is a communication made by means of:

• Any broadcast, cable or satellite communication;

• Newspaper;

2 Authorized committees may want to refer state political action committees of corporations, labor organizations and trade 

associations to these citations. These state committees are advised to register a federal separate segregated fund with the FEC before 

soliciting or making any contributions in connection with a federal election.

3 At the time of this publication, the Commission was considering proposals to amend the definition of “public communication” 

and its regulations concerning disclaimers on certain internet communications. The proposed rules on Internet Communication 

Disclaimers and Definition of ‘‘Public Communication’’ and Technological Modernization are available on FEC.gov. Any updates to 

these rules will be announced and posted there.
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• Magazine;

• Outdoor advertising facility;

• Mass mailing (more than 500 pieces of substantially similar mail within any 30-day period);

• Telephone bank (more than 500 substantially similar telephone calls within any 30-day period);

• An advertisement placed for a fee on another person’s website; or

• Any other form of general public political advertising.4 100.26, 100.27 and 100.28.

Any public communication made by a political committee, even those that do not contain a solicitation or 

express advocacy, must include a disclaimer. 52 U.S.C. §30120(a); 110.11(a)(1).

Wording of disclaimer notice

Authorized and financed by campaign

If the candidate or campaign authorizes and finances a covered communication (including any solicitation), 

the notice must state that the communication was paid for by the authorized committee. Additional 

requirements apply for print, television and radio ads (see “Special rules for printed communications” and 

“Special rules for television and radio ads”).

Example: “Paid for by the Sam Jones for Congress Committee.” 110.11(b)(1).

Authorized but not financed by campaign

If a covered communication, including any solicitation, is authorized by the candidate or campaign but paid 

for by another person, the communication must identify the person who paid for it and state that it was 

authorized by the candidate or campaign. Additional requirements apply for print, television and radio ads.

Example: “Paid for by the XYZ Committee and authorized by the Sam Jones for Congress Committee.” 

110.11(b)(2).

Not authorized or financed by campaign

If a covered communication, including any solicitation, is paid for by another person and not authorized by 

the candidate or campaign, the communication must state that it was not authorized by any candidate or 

candidate’s committee, identify the entity that paid for the communication and provide at least one of the 

following: the payor’s permanent street address, telephone number, or website address. 110.11(a) and (b)

(3). See AO 2017-05 (Great America PAC). Additional requirements apply for print, television and radio ads 

(see Appendix D, Section 7).

Example: “Paid for by the XYZ PAC (www.xyzpac.org) and not authorized by any candidate or candidate’s 

committee.”

This type of notice must be used on independent expenditures and electioneering communications that are 

not authorized by a candidate or a candidate’s campaign. 110.11(b)(3), (c)(4) and (d)(3).

Party coordinated communications on behalf of candidate

A party committee that pays for a communication that is a coordinated party expenditure must identify 

the party committee as the payor in the disclaimer. Prior to the date the party’s candidate is nominated, it 

is sufficient for the party committee to state who has paid for the communication. After the nomination, 

the disclaimer must state that it was paid for by the party committee and authorized by the candidate. 

110.11(d)(1) and (2).

4 The term “general public political advertising” does not include any internet communication except for a communication placed for a 

fee on another person’s website.
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Conducting the Campaign

Preemption of state law

An authorization notice does not have to comply with state or local disclaimer laws if the communication is 

made only with respect to federal candidates and elections. 108.7. See for example, AO 1986-11 (Mueller). 

However, state or local laws governing the placement or location of signs on roads are not superseded by 

federal law. See AO 1981-27 (Archer).

Clear and conspicuous placement of disclaimer notice

A disclaimer notice must be clearly and conspicuously displayed. A notice is not clearly and conspicuously 

displayed if the print is difficult to read or if the placement is easily overlooked. 110.11(c)(1).

Special rules for printed communications

In printed communications, the disclaimer must be contained within a printed box set apart from the 

contents of the communication. The print of the disclaimer must be of sufficient size to be “clearly 

readable” by the recipient of the communication, and the print must have a reasonable degree of color 

contrast between the background and the printed statement. 110.11(c)(2). Black text in 12-point font on 

a white background is one way to satisfy this requirement for printed material measuring no more than 24 

inches by 36 inches.

Multiple-paged document

A disclaimer need not appear on the front page or cover of a multiple-paged document, as long as the 

disclaimer appears within the communication. 110.11(c)(2)(iv).

Package of materials

Each communication that would require a disclaimer if distributed separately must still display the 

disclaimer when included in a package of materials. 110.11(c)(2)(v). For example, if a campaign poster is 

mailed with a solicitation for contributions, a separate disclaimer must appear on the solicitation and the 

poster.

Special rules for television and radio ads

Authorized by candidate’s committee – the “stand by your ad” provision

In addition to the requirements noted under “Wording of Disclaimer Notice,” radio and television 

communications (or any broadcast, cable or satellite transmission) that are authorized or paid for by 

a campaign require additional language. For such ads, the candidate must deliver an audio statement 

identifying himself or herself and stating that he or she has approved of the communication. For example: “I 

am [candidate’s name], a candidate for [federal office sought], and I approved this advertisement.”5

In a television ad, the disclaimer must be conveyed by:

• A full-screen view of the candidate making the statement; or

• A voiceover by the candidate with an image of the candidate occupying no less than 80% of the vertical 

screen height.

110.11(c)(3). See also AO 2007-33 (Club for Growth PAC).

Additionally, television communications must contain a clearly readable written statement of approval, 

similar to what is spoken, that appears at the end of the communication for a period of at least four seconds 

with a reasonable degree of color contrast between the background and the disclaimer statement (e.g., black 

text on white background). The written statement must occupy at least four percent of the vertical picture 

height. 110.11(c)(3)(iii).

5 Under the Communications Act, administered by the Federal Communications Commission, candidates must also satisfy other 

requirements in order to be entitled to the lowest unit charge. See 47 U.S.C. §315(b) and AO 2004-43 (Missouri Broadcasters).
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When disclaimer not required

A disclaimer is not required when:

• It cannot be conveniently printed (e.g., pens, bumper stickers, campaign pins, campaign buttons and 

similar small items);

• Its display is not practicable (e.g., wearing apparel, water towers and skywriting); or

• The item is of minimal value, does not contain a political message and is used for administrative 

purposes (e.g., checks and receipts). 110.11(f); See also AOs 2010-19 (Google), 2004-10 (Metro 

Networks) and 2002-09 (Target Wireless).

3. Rates for Political Advertisements

Rates charged by newspapers and magazines for campaign advertising must be comparable to those charged 

for noncampaign advertisements. 110.11(g). Rates charged for radio and television advertisements are 

regulated by the Federal Communications Commission. See Appendix G.

4. Campaign Travel

This section explores rules for travel payments. Generally, campaigns may pay for campaign-related 

travel as operating expenditures. As explained in Chapter 7, “Sources of Support,” an in-kind contribution 

generally results from the source of payment for the travel unless an exemption for individual travel 

applies or the campaign pays for its own campaign travel. 100.93. See Chapter 7, Section 4, “Travel Cost 

Exemptions,” for details on when payments for campaign travel by individuals are considered exempt.

Commercial transportation

If a campaign uses an aircraft that is operated for commercial air service, such as a commercial airline or 

charter service, or another means of commercial transportation, the campaign must pay the usual and 

normal charge for that service to avoid receiving an in-kind contribution from the service provider. See 

100.52(a) and (d).

Non-commercial air travel

The Honest Leadership and Open Government Act of 2007 (HLOGA) (Pub. L. No. 110-81, 121 Stat. 

735) amended the Act to restrict campaign-related travel on non-commercial aircraft. Under HLOGA, 

candidates for the U.S. House of Representatives, their authorized committees, and their leadership 

PACs are prohibited from making any expenditure for non-commercial air travel, with an exception for 

travel on government aircraft and on aircraft owned or leased by the candidate or an immediate family 

member of the candidate. 52 U.S.C. §30114(c)(2) and (3).6 HLOGA also specified new reimbursement 

rates that Senate, Presidential and Vice-Presidential candidates and their authorized committees must pay 

when making expenditures for flights aboard non-commercial aircraft. Rules governing the use of noncommercial aircraft by “campaign travelers” are described in the next sections.

Commission regulations define the term “campaign traveler” as any individual traveling in connection with 

an election for federal office on behalf of a candidate or political committee, and candidates who travel on 

behalf of their own campaigns. The term campaign traveler also includes any member of the news media 

traveling with a candidate. Candidates are only considered campaign travelers when they are traveling in 

connection with an election for federal office. This term does not include Members of Congress when they 

engage in personal travel or any other travel that is not in connection with an election for federal office. 

100.93(a)(3)(i).

6 The provisions of HLOGA also apply to nonconnected committees sponsored by candidates for the House of Representatives 

(“leadership PACs”).
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Conducting the Campaign

Presidential, Vice-Presidential and Senate candidate travel

Candidates for President, Vice-President and the Senate pay the pro rata share of the fair market value 

on non-commercial flights. 100.93(c)(1). The pro rata share is determined by dividing the fair market 

value of the normal and usual charter fare or rental charge for a comparable aircraft of comparable size by 

the number of campaign travelers flying on behalf of each candidate on the flight.7 The pro rata share is 

calculated based on the number of candidates represented on a flight, regardless of whether the individual 

candidate is actually present on the flight. A candidate is represented on a flight if a person is traveling on 

behalf of that candidate or the candidate’s authorized committee.

Travel on behalf of leadership PACs of Senate, Presidential and Vice-Presidential candidates

For non-commercial travel on behalf of leadership PACs of Senate, Presidential and Vice-Presidential 

candidates, the reimbursement for that travel is the responsibility of the committee on whose behalf the 

travel occurs. The reimbursement rates are as follows:

• The lowest unrestricted and non-discounted first-class airfare in the case of travel between cities served 

by regularly scheduled first-class commercial airline service;

• The lowest unrestricted and non-discounted coach airfare in the case of travel between a city served 

by regularly scheduled coach commercial airline service, but not regularly scheduled first-class 

commercial airline service, and a city served by regularly scheduled coach commercial airline service 

(with or without first-class commercial airline service); or

• The normal and usual charter fare or rental charge for a comparable commercial aircraft of sufficient 

size to accommodate all campaign travelers and security personnel, if applicable, in the case of travel to 

or from a city not served by regularly scheduled commercial airline service 100.93(c)(1).

To avoid the receipt of an in-kind contribution, the committee must reimburse the service provider no later 

than seven calendar days after the date the flight began. 100.93(c).

Travel on behalf of House candidates and House leadership PACs

House candidates, individuals traveling on behalf of House candidates, their authorized committees, or the 

leadership PACs of House candidates are generally prohibited from engaging in non-commercial campaign 

travel on aircraft.8 100.93(c)(2). This prohibition cannot be avoided by payments to the service provider, 

even if the payments derive from the personal funds of a House candidate.

Travel on behalf of other committees

The reimbursement rate structure for campaign travelers who are traveling on behalf of political party 

committees, separate segregated funds (SSFs), nonconnected committees and certain leadership PACs is the 

same reimbursement rate structure described under the section “Travel on behalf of Leadership PACs of 

Senate, Presidential and Vice-Presidential Candidates.”

Aircraft owned or leased by candidate or immediate family

Expenditures are allowed for travel aboard aircraft that are “owned or leased” by a candidate or a 

candidate’s immediate family, including an aircraft owned or leased by any entity in which the candidate 

or a member of the candidate’s immediate family has an ownership interest provided that 1) the entity 

is not a public corporation, and 2) the use of the aircraft is not more than the candidate’s or immediate 

family member’s proportionate share of ownership allows. 100.93(g). However, if the candidate seeks to 

avoid receiving an in-kind contribution from the service provider (candidates, members of their immediate 

7 The term “comparable aircraft” means an aircraft of similar make and model as the aircraft that actually makes the trip, with similar 

amenities as that aircraft. The Commission’s regulations interpret HLOGA to include helicopters when determining “comparable 

aircraft.” 100.93(a)(3)(vi). See also Campaign Travel, 74 Fed. Reg. 63953-54 (Dec. 7, 2009), available on FEC.gov.

8 This prohibition does not apply when the travel would be considered an expenditure by someone other than the House candidate, 

the House candidate’s authorized committee or the House candidate’s leadership PAC (for example, if the House candidate were 

traveling on behalf of a Senate candidate instead of on behalf of his or her own campaign).
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family or entities in which either owns an interest) for the candidate’s use of the aircraft, the candidate 

must reimburse the service provider. Although federal candidates may make unlimited contributions 

to their campaigns, such contributions must be reported by their authorized committees. 110.10. 

Contributions from all other persons, including family members, are subject to the applicable amount limits 

and source prohibitions. 110.1.

In instances where the candidate uses the aircraft within the limits of a shared-ownership arrangement, 

the candidate’s committee must reimburse the candidate, the candidate’s immediate family member or the 

administrator of the aircraft for the applicable rate charged to the candidate, immediate family member, or 

corporation or other entity through which the aircraft is ultimately available to the candidate. Alternatively, 

the candidate’s committee may treat this amount as a personal contribution from the candidate if the 

candidate is the owner or lessee. House candidates are prohibited from exceeding the candidate’s 

proportional share of ownership interest in the aircraft. For Senate, Presidential and Vice-Presidential 

candidates, the reimbursement rate would be based upon the pro rata share of the charter rate where the 

proportional share of the ownership interest is exceeded. 100.93(c)(1).

In instances where a candidate or a candidate’s immediate family member wholly owns the aircraft, the 

candidate’s authorized committee must reimburse the pro rata share per campaign traveler of the costs 

associated with the trip.9 100.93(g)(1)(iii).

Repayment must be made by the candidate’s committee in accordance with the normal business practices 

of the entity administering the shared-ownership or lease agreements.

Other non-commercial transportation

For non-commercial travel via other means, such as limousines and all other automobiles, trains and 

buses, a political committee must pay the service provider the normal and usual fare or rental charge for 

a comparable commercial conveyance of sufficient size to accommodate all campaign travelers, including 

members of the news media traveling with a candidate and security personnel, if applicable. Payment for 

the travel must be made within 30 days from the receipt of the invoice, but no more than 60 days following 

the date the travel commenced. 100.93(d).

Government conveyances

Candidates and representatives of political committees may make campaign travel via governmental 

conveyances, such as government aircraft, subject to specific reimbursement requirements. Candidates, 

their authorized committees or House candidate leadership PACs must reimburse the federal, state or local 

government entity providing the aircraft at either of the two following rates:

• “Per candidate campaign traveler” reimbursement rate, which is the normal and usual charter fare or 

rental charge for a comparable aircraft of sufficient size to accommodate all of the campaign travelers. 

The pro rata share is calculated by dividing the normal and usual charter fare or rental charge by 

the number of campaign travelers on the flight that are traveling on behalf of candidates, authorized 

committees or House candidate leadership PACs, including members of the news media, and security 

personnel. No portion of the normal and usual charter fare or rental charge may be attributed to any 

other passengers, except for members of the news media and government-provided security personnel, 

as provided in 100.93(b)(3). 100.93(e)(1)(i); or

• “Private traveler reimbursement rate,” as specified by the governmental entity providing the aircraft, 

per campaign traveler. 100.93(e)(1)(ii).

9 Such costs include, but are not limited to, the cost of fuel and crew and a proportionate share of annual and recurring maintenance 

costs. 100.93(g)(1)(iii).
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For campaign travelers who are traveling on government aircraft, but are not traveling with or on behalf of a 

candidate or candidate’s committee, the reimbursement must be equal either to the lowest unrestricted and 

non-discounted first-class commercial airline service that is geographically closest to the military airbase 

or other location actually used, or, for all other travel, the applicable rate from among the rates specified in 

100.93(c)(3). 100.93(e)(2).

Members of the news media who are traveling with a candidate on government aircraft and security 

personnel not provided by a government entity must be included in the number of campaign travelers for 

the purposes for identifying a comparable aircraft of sufficient size to accommodate all campaign travelers.

A political committee must reimburse the governmental entity providing the conveyance within the time 

frame specified by the governmental entity. 100.93(e)(1).

Reporting and recording travel costs

Payments for campaign-related travel are generally reported as operating expenditures when they are paid 

with campaign funds or by an individual from personal funds. 106.3(a) and (b)(1). Special rules apply, 

however, when the candidate or another individual uses his or her personal funds to pay for travel expenses 

and is later reimbursed. See Chapter 13 for more information.

The campaign must keep in its records an itinerary showing the departure and arrival cities and the dates 

of departure and arrival; a list of all passengers on such trip, along with a list of which passengers are and 

are not campaign travelers or security personnel; and the commercial fare or rental charge available for a 

comparable conveyance of sufficient size. 100.93(j).

Mixed travel

When a candidate makes a trip involving both campaign and noncampaign stops, only the travel costs 

related to the campaign are expenditures. If, however, a candidate conducts any campaign activity at a given 

stop, that stop is considered campaign related, unless the campaign activity is merely incidental. In no case, 

however, may campaign funds be used for non-travel expenses that are not related to official or campaignrelated activity. See AO 2002-05 (Hutchinson).

Example: If a candidate makes a noncampaign speech at a civic association luncheon and, on the way out, 

chats with a few attendees about his campaign in response to their questions, the conversation does not 

convert the appearance into a campaign-related event. On the other hand, if a candidate flew into a city 

for a trip that involved both personal vacation days and days spent campaigning, an incremental approach 

to paying for the trip would be required, to avoid the campaign paying the lodging, subsistence and 

sightseeing expenses on the vacation days—an expense that would be considered an impermissible personal 

use of campaign funds. Because of the non-incidental nature of the campaign days, the airfare would be 

considered a campaign-related expense.

Expenditures for campaign-related stops are calculated on an actual cost-per-mile basis, starting at the point 

of origin of the trip, including each campaign-related stop, and ending at the point of origin. 106.3(b)(2) 

and (3).

As explained in Chapter 8, campaign funds may be used for mixed use travel; however, the committee 

must be reimbursed within 30 days for the entire amount associated with the personal activities (the 

amount over and above what the cost would have been had the trip/vehicle use been solely for campaign/

officeholder-related purposes). 113.1(g)(1)(ii)(C). Individuals other than candidates must allocate their 

mixed campaign and noncampaign travel expenses on a reasonable basis. 106.3(c)(1).
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Example: A candidate travels by plane from Philadelphia to Las Vegas for a campaign speech. While in 

Nevada, the candidate travels by plane from Las Vegas to Reno for a personal trip. The candidate then 

flies back to Philadelphia from Reno. To determine the candidate’s campaign-related travel expenses, the 

committee must create a fictional itinerary from Philadelphia to Las Vegas and back. Thus the campaign 

would derive the cost-per-mile of campaign travel from the commercial rate for a round-trip flight from 

Philadelphia to Las Vegas, and the candidate must reimburse the committee for the difference in costs 

between the fictional trip and the actual trip. See the Explanation and Justification for 113.1 at 60 FR 7869 

(February 9, 1995).

On February 6, 2002, the Commission adopted an interpretive rule to clarify that the travel allocation and 

reporting requirements of 11 CFR 106.3(b) do not apply to the extent that a candidate10 pays for certain 

travel expenses using funds authorized and appropriated by the federal government. 67 FR 5445 (February 

6, 2002). Candidates should consult with the House Committee on Ethics or the Senate Select Committee 

on Ethics regarding the use of appropriated funds for travel expenses.

Travel to and from Washington, DC

Costs for travel between Washington, DC, and the state or congressional district in which an individual is a 

candidate are not reportable unless paid for by the campaign (or another political committee) in connection 

with campaign-related travel. 106.3(d). Consult the House and Senate rules for further guidance; see 

Appendix G.

10 This interpretive rule does not apply to Presidential or Vice-Presidential campaigns that are covered by the Presidential Campaign 

Fund Act. 26 U.S.C. §9001 et seq.
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CHAPTER 11

Keeping Records

In order to comply fully with the reporting requirements of the Federal Election Campaign Act (the Act), 

a committee must keep detailed records. The recordkeeping requirements for a committee’s receipts and 

disbursements are explained in this chapter.

1. Record Retention

Treasurers of authorized committees (and other political committees) are responsible for keeping copies 

of each statement and report, together with original back-up records, for three years after the report or 

statement is filed. 102.9(c); 104.14(b)(2) and (3).

2. Recording Receipts

With respect to receipts, the Act requires that records be kept for contributions and disbursements. 52 

U.S.C. §30102(c)-(d). The treasurer of a political committee shall keep these records and copies of all 

reports filed for three years after the report is filed. 52 U.S.C. §30102(d).

Total contributions

Records must show figures for total contributions received using any acceptable accounting method. 

102.9(a).

Identifying contributors

Contributions of $50 or less

In advisory opinions, the Commission has recommended two possible accounting methods that satisfy 

recordkeeping requirements for contributions of $50 or less:

• Keep the same information required for identifying contributions that exceed $50 (amount, date of 

receipt and contributor’s name and mailing address); or

• In the case of small contributions collected at a fundraiser (such as gate receipts, cash contributions), 

keep records of the name of the event as well as the date and the total amount of contributions received 

on each day of the event. AOs 1981-48 (Muskegon County Republican Party) and 1980-99 (Republican 

Round-Up Committee).

These amounts are reported under the category “unitemized contributions from individuals.” See Chapter 

13.

Contributions exceeding $50

Records must identify each contribution of more than $50 by:

• Amount;

• Date of receipt; and

• Contributor’s name and mailing address.

102.9(a)(1).

Furthermore, political committees must maintain either a full-size photocopy or digital image of each check 

or written instrument by which a contribution of more than $50 is made. 102.9(a)(4).
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Contributions aggregating over $200

For each contribution that exceeds $200, either by itself or when added to the contributor’s previous 

contributions made during the same calendar year, records must identify that contribution by:

• Amount;

• Date of receipt; and

• Contributor’s full name and mailing address, occupation and employer.

If a person has already contributed an aggregate amount of over $200 during a calendar year, each 

subsequent contribution, regardless of amount, must be identified in the same way. 102.9(a)(2).

Contributions to authorized committees are aggregated on a calendar-year basis for recordkeeping 

purposes, but are aggregated on a per election basis for purposes of monitoring contribution limits, and on 

an election-cycle basis for reporting purposes. See 102.9(a)(2), 104.3(a)(4), 110.1(b) and 110.2(b) and 

Chapter 4 of this guide.

Contributions by text message

Recipient committees are solely responsible for ensuring that contributions sent by text messages are 

lawful under the Act and Commission regulations. Committees should work with the text messaging 

application provider or connection aggregator to collect the name, address, occupation and employer of 

individuals making contributions that aggregate over $200 in a calendar year, and must return or refund 

any contribution that comes from a prohibited source. For more information on contributions by text, see 

AOs 2012-17 (Red Blue T LLC, ArmourMedia, Inc., and m-Qube, Inc.), 2012-26 (Cooper for Congress, 

ArmourMedia, Inc., and m-Qube, Inc.), 2012-28 (CTIA), and 2012-30 (Revolution Messaging, LLC).

Designated, redesignated and reattributed contributions

A committee must retain the written copies of contributors’ designations, redesignations and reattributions. 

102.9(f). Also, for any contributions presumptively redesignated or reattributed, the committee must retain 

any writings from contributors that accompany the contribution and any notices sent from the committee 

to the contributor. 110.1(l)(4)(ii). Records of redesignations obtained electronically may be retained in 

a database in a manner consistent with the recordkeeping requirements for signed written redesignations 

under 110.1(l).1

Contributions from political committees

Records must identify each contribution from a political committee, regardless of amount, by:

• Amount;

• Date of receipt; and

• Name and address of the political committee. 102.9(a)(3).

Possibly illegal contributions

As noted in earlier chapters, when a committee has reason to question the legality of a contribution, it 

has specific time frames in which to clarify whether the contribution is permissible. While investigating 

a contribution, the committee must keep a written record noting the basis of concern for each deposited 

contribution which:

• Requires a written redesignation and/or reattribution from the contributor (see Chapter 4). (For 

presumptive redesignations and reattributions, see “Designated, Redesignated and Reattributed 

Contributions”); or

• Requires confirmation that it is not from a prohibited source (see Chapter 5).

103.3(b)(1) and (5).

1 For more information about electronic redesignations, see the FEC’s Interpretive Rule on Electronic Redesignations (76 FR 16233 

(March 23, 2011)) atFEC.gov.
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Keeping Records

See Chapter 5, Section 2, “Questionable Contributions,” for more information on the committee’s 

responsibility to determine the legality of possibly illegal contributions.

Acceptable accounting method

If a committee receives contributions designated for use in the general election, prior to the primary 

election, then the committee must use an acceptable accounting method to distinguish between 

contributions received for the primary election and contributions received for the general election. 

Acceptable accounting methods include designating separate accounts for each election, or establishing 

separate books and records for each election. 102.9(e)(1).

The committee’s records must demonstrate that, prior to the primary election, recorded cash on hand was 

at all times greater than or equal to the sum of general election contributions received minus the sum of 

general election disbursements made. 102.9(e)(2).

Date of receipt

General rule

A contribution’s date of receipt is the date on which the person receiving the contribution on behalf of the 

committee obtains possession of it. 102.8(a). This is the date used for recordkeeping and reporting.2

The date of receipt may be earlier than the date the committee treasurer receives the money, since a person 

collecting contributions (other than an authorized agent) has 10 days (or 30 days for contributions of $50 

or less) in which to forward them to the treasurer. 102.8(a).

Contributions charged on credit cards

When 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. The 

treasurer should retain a copy of the authorization form in the committee’s records. See AOs 1995-09 

(NewtWatch) and 1990-04 (American Veterinary Medical Association).

Contributions sent by text message

The date of receipt for contributions sent by text message is the date the contributor “opts-in,” or confirms 

that he or she intends to make the contribution, and certifies his or her eligibility. AO 2012-17 (Red Blue T 

LLC, ArmourMedia, Inc., and m-Qube, Inc.).

In-kind contributions

The date of receipt for an in-kind contribution is the date the goods or services are provided to the 

committee, even if the contributor pays the bill for the goods or services after they are provided. See 

110.1(b)(6).

(For information on how to determine the value of an in-kind contribution, see Chapter 3, Section 2.)

Deposit of receipts

Once the treasurer (or authorized agent) receives a contribution or other receipt, he or she must deposit it 

within 10 days. Contributions not deposited within 10 days must be returned to their donors. 103.3(a)

2 Compare with the date contribution is made, which is the date a contributor relinquishes control over a contribution 110.1(b)(6). 

This date determines the election limit against which an undesignated contribution counts. See Chapter 4, Section 5.
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3. Recording Disbursements

Check and cash disbursements

Disbursements must be made by check or similar draft drawn on an account maintained at the committee’s 

designated depository. 102.10 and 103.3(a); See also AOs 1993-04 (Cox) and 1982-25 (Sigmund).

However, the committee may maintain a petty cash fund for small disbursements. A written record of 

petty cash disbursements must be kept if a petty cash fund is maintained. Payments from petty cash to one 

person for any one purchase or transaction may not exceed $100. 102.11.

Regardless of whether a disbursement is made by check or from a petty cash fund, the required 

recordkeeping information must be maintained. 

Recording disbursements

All disbursements

The committee must keep a record of each disbursement, including:

• Amount;

• Date;

• Name and address of payee;3 and

• Purpose, a brief but specific description of why the disbursement was made, such as “dinner expense” 

or “postage.”4

102.9(b)(1).

Disbursements exceeding $200

For each single disbursement that exceeds $200, the committee must keep a receipt, invoice or canceled 

check (in addition to the previous information). 102.9(b)(2).

Advances for travel and subsistence

When a committee advances $500 or less to the candidate, staff members or volunteers for travel 

expenses—including transportation, food and lodging—the committee must retain:

• The expense voucher or other expense account documentation; and

• The canceled check made out to the individual receiving the payment.

102.9(b)(2)(i)(B).

When a committee advances more than $500 for travel and subsistence expenses, the committee must 

obtain and retain:

• A receipt (or invoice) from the person providing goods or services in excess of $200 per transaction to 

the person requesting the advance;

• A cancelled check from the person requesting the advance showing payment to the person providing 

goods or service; or

• A monthly credit card billing statement or customer receipt from the person requesting the advance, 

and that person’s cancelled check showing payment of such bill.

AO 1984-08 (Duncan).

3 Except in the case of travel advances of $500 or less, the payee is the person providing the goods or services to the committee. In the 

case of such travel advances, the payee is the person receiving the advance. 102.9(b)(2)(i)(A) and AO 1984-08 (Duncan).

4 A list of acceptable/unacceptable descriptions of “purpose” was published in a Policy Statement at 75 FR 887 (January 9, 2007). This 

notice and an updated list of unacceptable “purpose” statements are available on FEC.gov.
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Keeping Records

Credit card transactions

For credit card transactions, the committee must retain:

• A monthly billing statement; or

• The customer receipt for each transaction; and

• The canceled check used to pay the credit card account.

102.9(b)(2)(ii).

Credit union checks or share drafts

Carbon copies of share drafts or checks drawn on credit union accounts may be used as records, provided 

the monthly account statement (showing that the draft or check was paid by the credit union) is also 

retained. 102.9(b)(2)(iii).

Best efforts to document disbursements

If a treasurer fails to receive a receipt, invoice or canceled check (required for disbursements exceeding 

$200), he or she can demonstrate his or her best efforts to obtain the information by making at least one 

written effort per transaction to obtain a duplicate copy of the needed documentation. 102.9(d).

4. Recording Debts and Loans

Although the Act does not contain specific recordkeeping requirements for debts and loans owed by (or to) 

the campaign, committees are required to keep detailed records of transactions required to be disclosed on 

the committee’s FEC reports. See 104.14(b). 

5. Treasurer’s Best Efforts

Committees and their treasurers must make best efforts to obtain and maintain (and ultimately report) 

the information required by law with respect to itemized receipts and disbursements. When reporting 

information is incomplete, the committee and the treasurer will be in compliance with the law if they can 

demonstrate that they used “best efforts” in trying to obtain, maintain and report the needed information. 

102.9(d) and 104.7(a). The criteria for making “best efforts” vary, depending on the type of transaction.

Contributor information

If an individual who has contributed more than $200 during the election cycle fails to provide the required 

recordkeeping information (i.e., name, mailing address, occupation and employer), the committee must 

be able to show that it made “best efforts” to obtain, maintain and report that information. To demonstrate 

“best efforts,” the committee must be able to show that it requested the information—first, in the 

solicitation materials that prompted the contribution and, second, if the information is not obtained, in a 

follow-up request. 104.7(b)(1) and (2). Furthermore, if the requested information is not received until after 

the contribution has been reported, the committee must report the information using one of the procedures 

described under “File Amendments if Necessary.” 104.7(b)(4).

Solicitation materials5

To satisfy the “best efforts” standard, the solicitation must include a statement explaining that the campaign 

is required to use its best efforts to obtain and report certain information from the contributor. This 

statement is referred to as the “best efforts” notification. Examples include:

5 Any contribution which is reported by a committee with all required contributor information will meet the reporting requirements, 

whether or not the committee asked for the information or used the language specified under “Solicitation Materials.” See the 

Explanation and Justification published with the final rule, 58 Fed. Reg. 57725, 57727 (October 27, 1993) on FEC.gov.
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“Federal law requires us to use our best efforts to collect and report the name, mailing address, 

occupation and name of employer of individuals whose contributions exceed $200 in an election cycle;” 

or

“To comply with Federal law, we must use our best efforts to obtain, maintain and submit the name, 

mailing address, occupation and name of employer of individuals whose contributions exceed $200 per 

election cycle.”

104.7(b)(1)(i)(B).

The request for the information and the best efforts notification must be clear and conspicuous. If 

the solicitations include response materials, the best efforts notice and the request for the contributor 

information must be placed on these materials. The notice will not be considered to be “clear and 

conspicuous” if:

• The notification is printed in smaller type than the solicitation and response materials;

• The printing is difficult to read; or

• The notification is placed where it can be easily overlooked. 104.7(b)(1)(ii).

Follow-up request within 30 days

If the contributor does not provide sufficient reporting information when making a contribution, the 

committee must make at least one request for the information after the contribution is received. This 

follow-up request must be made for any contribution that exceeds the $200 threshold and lacks the 

necessary information. See “Contributions Aggregating over $200” in Section 2 of this chapter.

The request must be made within 30 days of receipt of the contribution; it may not include an additional 

solicitation or material on any other subject, but it may thank the contributor. The follow-up request may 

be made orally or in writing, but a written request must be accompanied by a pre-addressed postcard or 

envelope for the response. Oral requests must be documented in a memorandum. 104.7(b)(2). A political 

committee may also use e-mail to request missing contributor information. AOs 1999-17 (Bush Exploratory 

Committee) and 1995-09 (NewtWatch). Committees must retain records of follow-up requests. 102.9(d).

Use of information from prior records

If the contributor does not respond to the follow-up request, but the committee possesses the information 

in its contributor records, fundraising records or prior reports filed during the same two-year election cycle, 

then the committee must use that information when disclosing the contribution. 104.7(b)(3).

File amendments if necessary

If requested information about a contribution is received after the contribution has been disclosed on a 

report, the committee must either:

• File a Schedule A with its next regularly scheduled report, containing memo entries listing all 

contributions for which new contributor information has been received; or

• File amendments to the original reports.

In either case, the entries must cross-reference the prior reports to which they relate. However, the 

committee is only required to submit the information for contributions received during the current twoyear election cycle. 104.7(b)(4)(ii). See Chapter 13, Section 32, “Filing Amendments,” for instructions on 

filing amendments.
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Filing Reports

1. Who Reports

Principal campaign committee

The principal campaign committee must file periodic reports on financial activity until the committee has 

retired any debts,1 filed a termination report and received notification from the FEC that the committee’s 

termination report has been accepted. 102.3(b) and 104.1(a). See Chapter 14, Section 1.

Treasurer’s duties

A committee treasurer is responsible for signing and filing timely, complete and accurate reports and 

statements. 104.14(d). See Chapter 2, Section 3 for a complete summary of the treasurer’s duties. 

Treasurers are considered in compliance with the Federal Election Campaign Act (the Act) when they have 

made their “best efforts” to obtain, maintain and report required information. If a treasurer is unable to 

obtain information after making his or her best efforts, that fact should be noted on the report where the 

information is incomplete. See Section 3, “When to Report,” later in this chapter and Section 5, “Treasurer’s 

Best Efforts,” in Chapter 11.

When filing electronically, a committee treasurer must verify that all electronically filed documents have 

been examined by the treasurer and are accurate and complete to the best of that person’s knowledge. In 

order to verify electronically filed documents, the treasurer must either:

• Obtain a personal password (which serves as the treasurer’s electronic signature) from the FEC 

(available through the electronic filing office at 202/694-1307 or online at FEC.gov); or

• File on a compact disc (CD) and include, as a separate file, a digitized copy of a signed certification, or a 

signed certification on paper along with the CD. (For specific instructions on how to file electronically 

using a CD, see the Electronic Filing section of the FEC website,

104.18(g).

For more information on electronic filing, see Section 5 in this chapter.

Other authorized committees

Only principal campaign committees file reports and statements with the Federal Election Commission. 

Other authorized committees of the candidate file along with the principal campaign committee, as 

explained in Section 2. Joint fundraising committees must file reports according to special rules. See 

Appendix C.

Candidate does not report campaign activity

Apart from filing a Statement of Candidacy (FEC Form 2), a candidate has no personal reporting obligation 

under the Act. If a candidate receives contributions, obtains loans for campaign activity or makes 

disbursements, he or she is acting as a campaign agent. The transactions are reported by the principal 

campaign committee. 101.2 and 102.7(d).

1 Neither the committee seeking to terminate nor any other authorized committee of the same candidate may have any outstanding 

debts or obligations. 102.3(b).
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Candidate must file personal financial reports

Under the Ethics in Government Act, candidates for federal office must file personal financial reports. See 5 

U.S.C. App. 4 §§ 101-111. House candidates file such reports with the Clerk of the House of Representatives 

and Senate candidates file those reports with the Secretary of the Senate. Candidates for President and Vice 

President (except the incumbent President and Vice President) file their personal financial disclosure forms 

with the FEC, and the Commission is the agency responsible for public disclosure of those forms. However, 

detailed review and approval of those forms is the responsibility of the Office of Government Ethics. See 

Appendix G.

2. Where to File Reports

Filing with the Federal Election Commission

Principal campaign committees of House, Senate and Presidential candidates file reports and statements 

with the Federal Election Commission, 1050 First Street, NE, Washington, DC 20463. 52 U.S.C. 30102(g); 

105.1

Committees may also be required to file reports and statements with the filing office of the state in which 

the committee has headquarters, unless that state received a waiver from the requirement to maintain 

copies of FEC statements and reports. 108.1. As of 2021, all 50 states, American Samoa and the U.S. Virgin 

Islands have been granted waivers from the Commission.2

Filing with the principal campaign committee

Authorized committees of a campaign other than the principal campaign committee submit their reports 

and statements to the principal campaign committee. The principal campaign committee, in turn, files 

these reports and statements, along with its own, with the appropriate federal and state offices. When filing 

reports of receipts and disbursements (FEC Form 3), the principal campaign committee must also file a 

consolidated report (FEC Form 3Z), which summarizes information included in its own report and those 

filed by other authorized committees. See 102.1(b) and 104.3(f). Note that only authorized committees of 

the current campaign need to be included in the consolidated report.

3. When to Report

This section summarizes filing requirements applicable to all authorized committees of House and Senate 

campaigns. Presidential committees file reports according to a different schedule than the one presented 

in this section. See 104.5(b). The FEC sends more detailed reporting information to treasurers by e-mail 

shortly before reports are due. (For this reason, it is especially important to list a current e-mail address 

on the committee’s FEC Form 1.) Additionally, the FEC Record, the FEC’s online newsletter, publishes 

reporting announcements, as does the FEC’s “Dates and Deadlines” website.

Committee treasurers must file reports on time as the Commission does not have legal authority to 

grant extensions. Also, authorized campaign committees must continue to file quarterly reports even if 

their candidate is no longer active (for example, if the candidate retires, withdraws, loses the primary or 

otherwise drops out of the race before the general election). Generally, committees must continue to file 

reports until the committee completes the termination process (see Chapter 14).

2 Copies of reports for House and Senate candidates running for federal office in Guam, Northern Mariana Islands or Puerto Rico must 

be filed with the appropriate office in those territories. Presidential committees must file a copy of each report in Guam, Northern 

Mariana Islands or Puerto Rico if the campaign makes an expenditure in those territories during the reporting period. 108.1 and 108.2.
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Filing Reports

Quarterly reports

Once an individual has become a candidate, his or her principal campaign committee (and other authorized 

committees) must file quarterly reports. 104.5(a). Quarterly reports cover activity through the end of the 

calendar quarter and are due on April 15, July 15 and October 15. The fourth quarterly report—called the yearend report—is due on January 31 of the following year. The Commission may waive a quarterly report if a preelection report is due during the period beginning on the 5th day and ending on the 15th day after the close of 

the calendar quarter. 104.5(a)(1)(iii). (See next section for information on additional election year reporting.)

Election year reporting

Election years are years in which regularly scheduled federal elections are held (even-numbered years).

Pre-election reports

In addition to quarterly reports, a committee must file pre-election reports:

• A pre-primary report must be filed before the election in which the candidate seeks nomination.

• A pre-general report must be filed if the candidate runs in the general election.

• A pre-runoff report must be filed when a candidate is involved in a runoff election. (Note: this may be 

either a primary or a general election.)

A pre-election report is due 12 days before the election and covers activity through the 20th day before the 

election. If sent by registered or certified mail, priority mail with a delivery confirmation, express mail with 

a delivery confirmation, or overnight delivery service with an online tracking system, the report must be 

postmarked no later than the 15th day before the election.3 104.5(a)(2)(i).

Authorized committees must file appropriate pre- and post-election reports even if the candidate is unopposed 

or if the election is not held. AO 1986-21 (Owens).

Post-general election reports

There is no requirement for post-primary reports, but a committee must file a post-general report if the 

candidate runs in the general election. A post-general election report covers activity through the 20th day after 

the election and is due 30 days after the election. 104.5(a)(2)(ii). Committees filing the post-general report 

must include the Post-Election Detailed Summary Page. See Chapter 13, Section 30, for more information. 

(Committees of campaigns not running in the general election include this form with the year-end report 

following the election.)

Last-minute contributions (48-hour notice)

Campaign committees must file special notices regarding contributions of $1,000 or more received less than 

20 days but more than 48 hours before 12:01 a.m. of the day of any election in which the candidate is running. 

104.5(f). (These are called “48-hour notices.”) This rule applies to all types of contributions to any authorized 

committee of the candidate, including:

• Contributions from the candidate;

• Loans from the candidate and other non-bank sources; and

• Endorsements or guarantees of loans from banks. See Chapter 3, Section 2.

Visit FEC.gov for a list of 48-hour notice periods.

3 In several instances, the Commission has been asked to determine a state’s primary date for purposes of the Act. In those states in which 

a party caucus or convention has authority to select a nominee (Virginia) or has authority to select a nominee and is held in addition to 

a primary (Connecticut and Utah), pre-election reports must be filed for the caucus or convention. See AOs 2004-20 (Farrell), 1992-25 

(Owens), 2000-29 (Louisiana Congressional Delegation) and “Party Caucus or Convention” in Chapter 4. See also, the Commission’s 

Interpretive Rule on the Date of Political Party Nominations of Candidates for Special Primary Elections in New York, and FEC v. Citizens 

for Senator Wofford, No. 1: CV-94-2057, slip op.at 8-10 (M.D. Pa. Sept. 27, 1995) (holding that state party convention constituted a 

“primary election” under the Act and Commission regulations even though state law required the party to file a subsequent certificate of 

nomination with the state.)
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Committees filing electronically must file their 48-hour notices electronically. See Section 5, “Electronic 

Filing.” Paper-filing committees may file their 48-hour notices using FEC Form 6. Alternatively, a paperfiling committee may file online using the FEC’s web-based forms, or may use its own paper or stationery 

for the notice, provided that it contains the following information:

• The candidate’s name and the office sought;

• The identification of the contributor; and

• The amount and date of receipt of the contribution.

Committees filing paper forms may fax the notice to 202/219-0174. The committee should keep fax 

receipts of all transmissions.

The FEC must receive the notice within 48 hours of the committee’s receipt of the contribution. The 

committee must itemize all last-minute contributions in the committee’s next scheduled report. 52 U.S.C. 

§30102(g); 104.5(f). See reporting example in Chapter 13, Section 17.

For information on when to report last-minute contributions received as part of a joint fundraising transfer, 

see Appendix C, Section 13.

Special elections

Filing dates for special elections are published on the FEC’s website, in the FEC Record and in the Federal 

Register. The Commission also notifies the principal campaign committees of candidates who are on the 

ballot in a special election. If a regularly scheduled report is due within 10 days of the date a special election 

report is due, the Commission may waive the regular report. 104.5(h).

Nonelection year reporting

Nonelection years are years in which there is no regularly scheduled federal election (odd-numbered 

years). Authorized campaign committees must continue to file quarterly reports, even during nonelection 

years. See “Quarterly reports,” above.

Meeting the filing deadline

By registered mail, certified mail, priority mail with delivery confirmation, express mail with 

delivery confirmation or overnight delivery

If a statement or report is sent by registered mail, certified mail or overnight mail with an online tracking 

system,4 it is considered filed on the date of the U.S. postmark. (Note the special rule for pre-election 

reports, above.) 100.19. The committee should retain evidence that it delivered the report to the U.S. Postal 

Service or the overnight delivery service, in the event of a delivery failure.

By first class mail

If a statement or report is sent by first class mail, it is considered filed on the date it is received by the FEC. 

52 U.S.C. §30102(g); 100.19(b)(2) and 104.5(e). The risk of timely delivery is on the filer.

By electronic filing

An electronic report is considered “filed” when it is received and validated by the Commission’s computer 

system on or before 11:59 p.m. (Eastern Time) on the filing date. Incomplete or inaccurate reports that do 

not pass the FEC’s validation program will not be considered filed. The Commission will notify the filer that 

the report has not been accepted. 100.19(c) and 104.18(e)(2).

4 Overnight mail is often used to refer to priority mail having a delivery confirmation, express mail having a delivery confirmation, or 

an overnight delivery service with an online tracking system.
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Filing Reports

By CD

While most electronic filers find it more convenient to file through the internet, the Commission also 

accepts properly formatted electronic reports on CDs either hand delivered or sent by other delivery 

means, such as the U.S. Postal Service. It is important to note that all mail sent to the FEC through the U.S. 

Postal Service undergoes special processing which might damage the information on a CD. For specific 

instructions on how to file electronically using a CD, see the Electronic Filing section of the FEC website.

Mandatory electronic filing

Some committees must file electronically (See Section 5, “Electronic Filing”). If a committee required to 

file electronically files a paper report instead of an electronic report, the report will be considered not filed. 

The committee may be subject to the Commission’s enforcement process for nonfilers and may have its 

name published as a nonfiler. See 104.18(a)(2).

4. Administrative Fines for Late Filers and Nonfilers

The Administrative Fine Program, which is based on amendments to the Federal Election Campaign Act,

5

assesses civil money penalties for violations involving:

• Failure to file reports on time;

• Failure to file reports at all;

• Failure to file 48-hour notices.

If the Commission finds “reason to believe” (RTB) that a committee violated the law, the Commission 

will notify the committee in writing of its finding and the amount of the civil money penalty. 111.32. 

The committee will have 40 days to either pay the civil money penalty or submit a written challenge to 

the Commission action. If the committee challenges the finding, it will be reviewed by an independent 

reviewing officer who was not involved in the RTB finding. After the Commission considers the reviewing 

officer’s recommendation and the committee’s response, if any, the Commission will determine whether 

the committee violated 52 U.S.C. §30104(a) and, if so, will assess a civil money penalty based on the 

schedules of penalties. The committee will then have 30 days to pay the penalty or seek court review of the 

case.6 See 111.34 and 111.35.

Respondents must demonstrate one of the following situations in their challenge:

• The RTB filing is based on factual errors;

• The RTB civil money penalty is improperly calculated; or

• They could not file due to reasonably unforeseen circumstances beyond their control, and they filed the 

late report within 24 hours after those circumstances ended (also called the “best efforts” defense).

Excuses involving negligence, illness, inexperience, unavailability of committee staff or treasurer, failure to 

know filing dates, failure to use Commission software properly, delays caused by vendors or failure of the 

committee’s computers, software or internet service provider do not qualify for the “best efforts” defense. 

111.35(c) and (d).

5 Pub. L. No. 106-58, 106th Cong., § 640, 113 Stat. 430, 476-77 (1999); Commission authority extended in Pub. L. No. 106-67, 107th 

Cong., § 642, 115 Stat. 514, 555 (2001); in Pub. L. No. 108-199, 108th Cong., § 639, 118 Stat 3 (2004); in Pub. L. No. 109-115, § 721, 

119 Stat. 2396, 2493-2494 (2006); in Pub. L. No. 113-72, § 721, 119 Stat. 2396, 2493-2494 (2013); and in Pub. L. No. 115-386, §1(a), 

132 Stat. 5161 (2018).

6 For more information on the Administrative Fine Program, see 11 CFR 111.30 to 111.46 and the Commission’s website at FEC.gov.
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5. Electronic Filing

Campaign committees of House, Senate and Presidential candidates must file all reports and statements 

electronically if their total contributions or total expenditures exceed, or are expected to exceed, $50,000 in 

a calendar year. 104.18(a).7

Committees that are required to file electronically, but that file on paper or fail to file, may be subject to 

enforcement action as nonfilers. 104.18(a)(2). See the previous section, “Administrative Fines for Late 

Filers and Nonfilers.”

Because electronic filing is more efficient and cost effective than paper filing, the FEC encourages 

campaign committees that do not meet the $50,000 threshold requirement to voluntarily file their reports 

electronically. Note, however, that voluntary electronic filers must continue to file electronically for the 

remainder of the calendar year unless the Commission determines that extraordinary and unforeseeable 

circumstances make continued electronic filing impractical. 104.18(b).

Methods of electronic filing

Most committees filing electronically find it convenient to do so via an internet connection with a 

password. Committees may, however, submit their electronic reports on CDs, either hand delivered or 

sent by other means such as the U.S. Postal Service. Electronic filers must file all their reports, notices, 

designations and statements electronically, and the reports must adhere to the FEC’s electronic filing 

specifications requirements.8 104.18(d).

Calculating the threshold

Committees should use the following formulas to determine whether their total expenditures or total 

contributions are over $50,000 per calendar year:

 Total Contributions Received9

- Refunds of Contributions

= Total Contributions

or

 Total Operating Expenditures

+ Contributions Made

= Total Expenditures

Have reason to expect to exceed the threshold

Once committees actually exceed the $50,000 yearly threshold they have “reason to expect to exceed” the 

threshold in the following two calendar years. 104.18(a)(3)(i). Consequently, committees must continue to 

file electronically for the next two calendar years (January through December).

Exception

A campaign committee that met or exceeded the $50,000 threshold and began filing electronically is not 

required to file electronically for the following two calendar years if it meets all three of the following 

requirements:

7 As of September 21, 2018, Senate candidates are subject to the FEC’s electronic filing requirements if they meet the electronic filing 

threshold.

8 The FEC offers a free Windows-based software system that committees can use for electronic filing. To download the FECFile 

software, visit FEC.gov.

9 Including the outstanding balance of any loans made, guaranteed or endorsed by the candidate or other person.
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Filing Reports

• Has $50,000 or less in net debts outstanding on January 1 of the year following an election;

• Anticipates terminating prior to the next election year; and

• Supports a candidate who has not qualified for the next election and does not intend to become a 

candidate in the next election.

104.18(a)(3)(i).

Note that such committees must finish filing electronically for the calendar year in which they exceeded the 

threshold.

Committees with no history

New committees with no history of campaign finance activity on which to base their expectations have 

reason to expect to exceed the $50,000 yearly threshold if:

• The committee receives contributions or makes expenditures that exceed one-quarter of the threshold 

amount in the first calendar quarter of the calendar year (i.e., exceeds $12,500 by the end of March); or

• The committee receives contributions or makes expenditures that exceed one-half of the threshold 

amount in the first half of the calendar year (i.e., exceeds $25,000 by the end of June).

104.18(a)(3)(ii).

Verification requirements

The political committee’s treasurer must verify the electronically filed reports by submitting either:

• A signed, written certification along with the CD; or

• A digitized copy of the signed certification as a separate file in an electronic (i.e., not transmitted by 

CD) submission.

The signed verification must certify that the treasurer or assistant treasurer has examined the submitted 

report, and that, to the best of his or her knowledge, the report is true, correct and complete. 104.18(g).

Obtaining a password

Requesting a password

Only the committee’s treasurer or assistant treasurer of record (as listed on the committee’s Statement of 

Organization) can obtain an electronic filing password. Committees may obtain or change their password

online at FEC.gov.

An entity or person(s) other than a political committee can obtain an electronic filing password by emailing 

a password request letter to the Electronic Filing Office. For more information and further instructions, 

visit FEC.gov.

Lost or forgotten password

If a treasurer loses or forgets the electronic filing password, the treasurer must request a new password.

New treasurers and new e-filers

In some cases, a committee may have a new treasurer who has been neither assigned a password nor has a 

signature on file and, due to the requirement that all filing information be submitted electronically, cannot 

amend the Statement of Organization to indicate the change of position. Under these circumstances, the 

new treasurer must submit a password request letter which contains the sentence “I represent that I am the 

duly appointed treasurer and have authority as such to sign FEC reports for the above committee.” Once a 

password is received, an amended Form 1 must be filed to indicate the change of position.
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Special requirements

The following documents have special signature and submission requirements:

• Schedule C1 (Loans and Line of Credit), including copies of loan agreements; and

• Form 8 (Debt Settlement Plan).

These two forms, in addition to being included in the electronic report, must be submitted on paper or in a 

digitized format (submitted as a separate file in the electronic report). 104.18(h).

6. Public Inspection of Reports

All reports filed by political committees are available for public inspection and copying (for a minimal fee) 

in the FEC’s Public Records Office. They are also available on the Commission’s website.

Copies of reports may also be purchased by mail. For more information, call 800/424-9530 (press 2 when 

prompted) or 202/694-1120.

“Sale or use” restriction

The Act prohibits anyone from selling or using the names and addresses of individual contributors, copied 

from FEC reports, for commercial purposes or for the purpose of soliciting funds. This “sale or use” 

restriction, however, does not apply to the names and addresses of political committees that are listed in 

FEC reports. 52 U.S.C. §30111(a)(4); 104.15; see also AO 2003-24 (NCTFK).

“Salting” reports to detect misuse

When preparing a report to be filed, a committee may “salt” the report with up to 10 fictitious names in 

order to detect impermissible uses of individual contributor information by other organizations. 104.3(e).

Salting can be done by taking a portion of the subtotal for unitemized contributions and allocating it, as 

itemized contributions, among several fictitious contributors. The committee itemizes each fictitious 

contribution on a Schedule A, providing a real address (such as the address of a campaign staff member) 

for each fictitious contributor. The committee must adjust its subtotals for itemized and unitemized 

contributions accordingly on the Detailed Summary Page. If a solicitation or commercial mailing is sent 

to one of the fictitious names, the committee will know that someone has illegally used the names of 

contributors disclosed on its reports. The committee may then file a complaint with the FEC.

When a committee files a report containing fictitious names, a list of the fictitious names should be sent 

under separate cover directly to the FEC’s Reports Analysis Division. The list will be kept confidential.

Sale or use of committee’s contributor list

The sale or use restriction does not prevent a committee from compiling its own list of contributors and 

distributing it to others. Under certain conditions, a committee may donate, sell, trade or rent its own 

contributor list to other committees and organizations. AOs 2002-14 (Libertarian National Committee), 

1982-41 (Dellums) and 1981-53 (Frazier)
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CHAPTER 13

Completing FEC Reports

1. Reporting Forms and Formats

FEC reports are filed either electronically or on paper, as explained in the previous chapter. This section 

explains each format’s requirements. All FEC forms (including schedules and instructions) are available on 

the FEC’s website.

Form 3

FEC Form 3 (or an electronic version) must be used by principal campaign committees and other authorized 

committees of candidates for the U.S. House of Representatives and U.S. Senate to disclose receipts and 

disbursements.1

Form 3 booklet

The Form 3 booklet contains Form 3 (Summary Page and Detailed Summary Page), Schedules A-D and Form 

3Z.

Schedules

Committees may be required to file the following schedules as attachments to Form 3:

• Schedule A—Itemized Receipts

• Schedule B—Itemized Disbursements

• Schedule C—Loans

• Schedule C-1—Loans and Lines of Credit from Lending Institutions

• Schedule D—Debts and Obligations

Form 3Z

If a candidate has more than one authorized committee for the same campaign, the principal campaign 

committee must also file Form 3Z. The one-page form, which consolidates information for the entire 

campaign, contains information taken from the current reports of the principal campaign committee and all 

other authorized committees. The principal campaign committee files Form 3Z along with its own report and 

those of the other authorized committees. 104.3(f).

Requirements for electronic filers

Committees that receive contributions or make expenditures of more than $50,000 in any calendar year, 

or have reason to expect to do so, must file all reports and statements electronically. Committees that are 

required to file electronically, but that file on paper or fail to file, may be subject to enforcement action as 

nonfilers. 104.18(a)(2). See Chapter 12, Section 4, “Administrative Fines for Late Filers and Nonfilers.” 

FECFile software, available free from the FEC, generates Form 1, Form 3 and Form 6. Filers can download 

the software from the FEC’s website. Filers can also use other software as long as it meets FEC format 

specifications. For more information about the electronic filing requirement, see Section 5 of the preceding 

chapter.

1 Presidential campaign committees use FEC Form 3P and its supporting schedules (or an electronic version). Form 3P and instructions

are available on FEC.gov.
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Requirements for paper filers

FEC forms filed on paper should be typed (either on a typewriter or on a computer—see the section 

“computerized forms” for additional information); printing in ink is also acceptable (but not recommended) 

as long as the forms are legible. Because filings will be imaged and photocopied several times before being 

placed on the public record, it is required that committees submit the original report—not a copy—with an 

original signature. 104.14. Committees submitting illegible documents will be required to refile.

Reporting instructions

Instructions for filling out each form and schedule are available on FEC.gov. Although written specifically 

for paper filers, the instructions contain information that is useful for electronic filers as well.

Online web forms

Online filing is available for FEC Form 6 (48-hour notices of last minute contributions) at FEC.gov.

Computerized forms

A committee that files on paper may develop its own computer-produced forms, reduced to the size of FEC 

forms, but it must submit them for approval by the FEC prior to using them. The submission must include 

sample formats of each applicable schedule (with sample data). The proposed format (and accompanying 

cover letter) should be mailed or hand delivered to the attention of the Reports Analysis Division. 104.2(d); 

FEC Directive 37. Note that this is not an option for committees required to file electronically.

How to obtain paper forms

FEC website

All FEC reporting forms and instructions, including Form 1, Form 2 and Form 3, are available on the 

Commission’s website.

2. Special Rules for First Report

When filing the first report due after registering as a political committee, the principal campaign committee 

(and other authorized committees of the campaign) must disclose all financial activity that occurred before 

registration and before the individual became a candidate (including any testing the waters activity), 

beginning with the first date of activity through the end of the current reporting period. 101.2(b), 101.3, 

104.3(a) and (b).

3. Categorizing Receipts

Committees must report receipts under the different categories listed on the Detailed Summary Page of 

Form 3. These categories are:

• Lines 11(a)(i) and (ii), Contributions from Individuals/Persons Other Than Political Committees;

• Line 11(b), Contributions from Political Party Committees;

• Line 11(c), Contributions from Other Political Committees (e.g., PACs);

• Line 11(d), Contributions from the Candidate;

• Line 12, Transfers from Other Authorized Committees;

• Lines 13(a) and (b), Loans;

• Line 14, Offsets to Operating Expenditures; and

• Line 15, Other Receipts.

For detailed information describing each category, see “The Detailed Summary Page” section later in this 

chapter.
99

Completing FEC Reports

For each category, a committee must disclose the total for the current reporting period and the cumulative 

election-cycle total. In addition to reporting these totals, a committee often has to itemize receipts by 

providing supplemental information on supporting Schedule As. 104.3(a)(3) and (4). A committee must 

use a separate Schedule A for each category of receipts that must be itemized, i.e., the committee may 

not mix different categories of receipts on the same schedule. Electronic filers must input all data for 

each contributor or payer separately so that the software can properly generate the required information, 

including the aggregated election-cycle-to-date total. It is recommended that committees filing on paper 

complete the supporting schedules first before transferring totals to the Detailed Summary Page.

4. How to Itemize Receipts

For each receipt to be itemized, the committee must report the:

• Name of source of receipt (i.e., the name of the person who gave something of value or paid money to 

the candidate or the committee);

• Mailing address of source;

• Employer of source (if source is an individual contributor);

• Occupation of source (if source is an individual contributor);

• Election to which a contribution or loan was designated (indicated by checking “primary,” “general” or 

“other” in the election designation box; for more information on designating contributions for a specific 

election, see Chapter 4, Section 4, “Designated and Undesignated Contributions”);

• Date of receipt;

• Amount of receipt; and

• Aggregate election-cycle-to-date total of all receipts (within the same category) from the same source.

100.12, 104.3(a)(4) and 104.8(a).

Note that the date of receipt for both recordkeeping and reporting purposes is the date that the campaign, 

or a person who receives a contribution on behalf of the campaign, first receives a contribution, rather 

than the date on the check or the date of deposit. 102.8(a). (See Chapter 4, Section 5, “Date Contribution is 

Made v. Date of Receipt” for more information.)

If a contributor is self-employed, that should be stated in the “Employer” space on Schedule A. If he or she 

is not employed, the space may be left blank, but the “Occupation” space should still be completed (e.g., 

“unemployed,” “retired,” “homemaker.”) See Chapter 11, Section 5, “Treasurer’s Best Efforts” regarding 

steps that must be taken to obtain information about contributors.

5. When to Itemize Receipts

Some receipts must be itemized regardless of their amount, while others need not be itemized until their 

aggregate election-cycle-to-date total exceeds a threshold dollar value.

Regardless of amount

Within the following four categories of receipts listed on the Detailed Summary Page, every receipt must be 

itemized regardless of amount:

• Contributions from party committees and organizations (including those that do not qualify as political 

committees under the Federal Election Campaign Act (the Act)) (Line 11(b));

• Contributions from other political committees and organizations (including all committees that are 

political committees under the Act) (Line 11(c). (See example 13–1);

• Transfers from affiliated committees (Line 12); and

• Loans (Lines 13(a) and 13(b)).

See 104.3(a)(4)(ii), (iii)(A) and (iv).
100

Chapter 13

Itemization threshold 

exceeded

Within the other categories, 

receipts from each source must be 

itemized if they:

• Exceed $200; or

• Aggregate over $200 when 

added to other receipts (within 

the same category) received 

from the same source during an 

election cycle.

The categories of receipts that are 

subject to this $200 threshold for 

itemization are:

• Contributions from individuals/

persons other than political 

committees;2

• Contributions from the candidate;

• Offsets to operating expenditures; and

• Other receipts. See 104.3(a)(4)(i), (v) and (vi).

Aggregation: election cycle vs. per election

Note that authorized committees must aggregate contributions on a per election basis when monitoring 

contribution limits. See Chapter 4. For purposes of reporting, however, committees aggregate contributions 

and other receipts on an election-cycle basis.

Election cycle

An election cycle begins the day after the general election for a seat or office and ends on the day of the 

next general election for that seat or office. 100.3(b). The length of the election cycle, thus, depends on the 

office sought. The election cycle is two years for House candidates, four years for Presidential candidates 

and six years for Senate candidates. 

To illustrate:

• The two-year election cycle for 2022 House candidates began on November 4, 2020 and ends on 

November 8, 2022;

• The four-year election cycle for 2024 Presidential candidates began on November 4, 2020 and ends on 

November 5, 2024;

• The six-year election cycle for 2026 Senate candidates began on November 4, 2020 and ends on 

November 3, 2026.

Example: Suppose an individual makes two contributions to a principal campaign committee during an 

election cycle.

Primary election contribution– The individual contributes $75 just before the candidate’s primary 

election. Because it is undesignated, the contribution automatically applies to the primary limit. The 

contribution does not exceed $200 and is the contributor’s first contribution to the candidate, so the 

2 Contributions from individuals/persons other than political committees that do not meet the $200 itemization threshold must be 

reported online 11(a)(ii), “Unitemized Contributions.”

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Ellis James for U.S. Senate

543 Stormybrook Street

Great Falls VA 00000

00000001

2,000.00

2,000.00

02 21 2021

X

X

13–1: Contributions from other political committees and organizations
101

Completing FEC Reports

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Ortega, Michael

211 Spruce Street

Clifton VA 00000

260.00

185.00

03 01 2021

X

X

First National Bank Banker

13–2: Aggregation of contributions

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Doe, Jane

626 Pritham Ave.

Springfield VA 00000

2,200.00

1,000.00

02 10 2021

X

X

U.S. House U.S. Representative

13–3: Contributions from candidate’s personal funds

committee includes the amount in its total of unitemized contributions (Line 11(a)(ii) on the Detailed 

Summary Page).

General election contribution– During the following reporting period, but after the primary election, 

the same contributor makes a $185 contribution. This contribution must be itemized since the aggregate 

total of the donor’s contributions for the election cycle ($260) now exceeds the $200 threshold for 

itemization. When itemizing the $185 contribution on Schedule A, the committee checks “General” in 

the election designation box and reports the donor’s aggregate election-cycle total as $260, even though 

$75 applies to the primary and $185 to the general. (See example 13–2.)

6. Reporting Contributions, Loans and Advances from Candidate

Contributions (including loans and 

advances) from the candidate must 

be reported by the campaign as 

follows:

Contributions from 

candidate

Personal funds contributed to the 

campaign are reported on Line 

11(d) as contributions from the 

candidate. (See example 13–3.)

Expenditures by candidate

Campaign expenditures made 

by the candidate from personal 

funds that are not to be 

reimbursed are reported similar 

to in-kind contributions from the 

candidate. See “Reporting In-kind 

Contributions” later in this chapter 

for more information on reporting 

these expenditures by candidates. 

If, on the other hand, a personal 

expenditure by the candidate is 

intended to be reimbursed, it is 

treated as an advance from the 

candidate for reporting purposes. 

See Sections 15 and 16 on reporting 

advances.

Loans from candidate’s 

personal funds

The candidate may loan personal funds to the committee and may charge interest at a commercially 

reasonable rate, provided the committee reports the loan and the interest rate from the outset on Schedule 

C. The committee continues to report the loan until it is repaid. See 110.10, 100.111(b), 116.11, 116.12, and 

AOs 1991-09 (Hoagland) and 1986-45 (Bingaman). See also Section 22 of this chapter, “Reporting Loans.”
102

Chapter 13

Bank loans obtained by candidate for campaign related purposes

If a candidate obtains a bank loan for campaign-related purposes, the committee must report the loan from 

the candidate as a receipt and repayment of the loan to the candidate as a disbursement 104.3(a)(3)(vii)(B) 

and (b)(2)(iii)(A) and 100.82(c). In addition, both the original loan and payments to reduce principal must 

be reported on Schedule C each reporting period until the loan is repaid. Furthermore, a committee that 

obtains a loan from a bank must also file Schedule C-1 with the first report due after the new loan. 104.3(d). 

See also Section 22, “Reporting Loans.”

Contributions intended to be loans

Receipts that are intended as contributions (rather than loans) from the candidate may not later be 

converted into loans. For that reason, the campaign should initially report such transactions as loans to be 

repaid. AOs 2006-37 (Kissin for Congress) and 1997-21 (Firebaugh).

Last-minute contributions or loans from candidate

Contributions or loans from the candidate of $1,000 or more, received less than 20 days but more than 48 

hours before any election in which the candidate is running, must be reported on a “48-Hour Notice.” (See 

“Last-Minute Contributions” in Chapter 12, Section 3 and Section 17 of this chapter.)

7. Reporting Joint Contributions3

Absent written instructions to the contrary, a committee must treat a joint contribution as though the 

individuals participating in the contribution made their contributions separately, and itemize them 

separately on Schedule A as 

required. (See example 13–4.) 

See 110.1(k)(1) and (2). For 

example, if a committee receives 

a $300 check with two signatures 

but with no written attribution, 

the committee attributes the 

contribution equally between the 

donors—$150 to each contributor. 

(Note that the committee must 

record each contribution according 

to the rules set out in Chapter 

11.) If neither contributor has 

previously contributed to the 

committee during the year, the 

committee does not have to itemize 

either contribution; nor does it 

have to itemize the $300 total joint 

contribution. If, on the other hand, 

the $300 check is accompanied by 

a signed statement attributing $250 

to one individual and $50 to the 

other, the $250 contribution must 

be itemized. The $50 contribution 

3 See also Chapter 4 for more information on joint contributions.

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

B.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Amount of Each Receipt this Period

, , .

Memo Item

Memo Item

Doe for Congress Committee

Bigshot, William

555 8th Street

Herndon VA 00000

Bigshot and Co.

500.00

500.00

03 20 2021

X

X

Executive

Bigshot, Keisha

555 8th Street

Herndon VA 00000

Campaign-to-Win, LLC

500.00

500.00

03 20 2021

X

Executive

13–4: Joint contributions
103

Completing FEC Reports

is included in the total of unitemized 13–5: Redesignations

contributions reported on Line 11(a)(ii) 

of the Detailed Summary Page.4

8. Reporting 

Redesignations and 

Reattributions

Receipt of original 

contribution

When itemizing a contribution 

that must first be redesignated 

or reattributed before it is legally 

acceptable, a committee must include 

a statement on Schedule A noting that 

the legality of the contribution is in 

question.5 See 103.3(b)(5).

Receipt of redesignation or 

reattribution

A committee must also comply with 

special procedures when reporting 

the receipt of reattributions and 

redesignations of contributions that 

were originally itemized on previous 

reports. (There is no need to report 

a reattribution or redesignation if 

the original contribution was not 

itemized.6) On the report covering the 

period during which the committee 

received the redesignation or reattribution, the committee must disclose, as a memo entry, information 

on both the original contribution and the redesignation or reattribution. The memo entry appears on a 

Schedule A for the category of contribution involved. (For example, a reattribution would appear with 

other itemized contributions on a Schedule A used for “Contributions from Individuals/Persons other than 

Political Committees.”)

The first part of the memo entry discloses all the information on the contribution as it was originally 

reported on Schedule A. The second part of the memo entry discloses as a negative entry the amount 

of the redesignation or reattribution. The third part discloses information on the contribution as it was 

redesignated or reattributed, including the date the redesignation or reattribution was received and, in the 

case of a redesignation, the election for which the contribution was redesignated. 104.8(d)(2) and (3). (See 

examples 13–5 and 13–6.)

4 As explained in the Explanation and Justification to revised rules on contribution limits, prescribed April 8, 1987, 52 Fed. Reg. 760 

(January 9, 1987).

5 The procedure described in 103.3(b)(5) applies to any contribution that appears to be illegal or that is questionable

6 As explained in the Explanation and Justification to revised rules on contribution limits, prescribed April 8, 1987, 52 Fed. Reg. 760 

(January 9, 1987).

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

    , , .

SUBTOTAL of Receipts This Page (optional) ............................................................................    , , .

TOTAL This Period (last page this line number only) ...............................................................  

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

Receipt For: 

 Primary General

 Other (specify)

A.

Election Cycle-to-Date 

Date of Receipt

Name of Employer Occupation

    , , .

FEC ID number of contributing

federal political committee. C

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

Receipt For: 

 Primary General

 Other (specify)

B.

Election Cycle-to-Date 

Date of Receipt

Name of Employer Occupation

    , , .

FEC ID number of contributing

federal political committee. C

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

Receipt For: 

 Primary General

 Other (specify)

C.

Election Cycle-to-Date 

Date of Receipt

Name of Employer Occupation

    , , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

 12 13a 13b 14 15

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

Amount of Each Receipt this Period

    , , .

Amount of Each Receipt this Period

    , , .

Amount of Each Receipt this Period

    , , .

FEC Schedule A (Form 3) (Revised 05/2016)

Memo Item

Memo Item

Memo Item

Doe for Congress Committee

Bancroft, Carrie

426 9th St.

Annandale VA 00000

James & Smith

5,800.00

5,800.00

12 02 2021

X

X

X Attorney

see year-end 2021

redesignation below

Bancroft, Carrie

426 9th St.

Annandale VA 00000

James & Smith

5,800.00

-2,900.00

01 15 2022

X

X Attorney

redesignation below

Bancroft, Carrie

426 9th St.

Annandale VA 00000

James & Smith

5,800.00

2,900.00

01 15 2022

X

X Attorney

redesignated
104

Chapter 13

Refund of excessive portion

If a committee requests a redesignation 

or reattribution but does not receive 

it within 60 days of the contribution’s 

receipt, the committee must refund the 

excessive portion of the contribution 

within 60 days of the treasurer’s receipt 

of the contribution and disclose the 

refund on its next report. (See Section 

25 of this chapter.) 103.3(b)(3) and 

104.8(d)(4).

9. Reporting Free Legal 

and Accounting Services

An authorized committee may receive 

free legal and accounting services 

provided solely to help the committee 

comply with the Act, as explained 

in Chapter 7. If the value of services 

paid for by one person (the employer) 

exceeds $200 or aggregates over $200 

during an election cycle, the committee 

must itemize the following information 

as a memo entry on a separate Schedule 

A:

• The name of each employee 

performing the services;

• The name and address of the 

employer of the person providing 

the services;

• The amounts paid for the 

services by the employer; and

• The dates the services were 

performed. 100.86 and 

104.3(h).

The Schedule A should be 

clearly labeled as exempt legal or 

accounting services. (See example 

13–7.)

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

    , , .

SUBTOTAL of Receipts This Page (optional) ............................................................................    , , .

TOTAL This Period (last page this line number only) ...............................................................  

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

Receipt For: 

 Primary General

 Other (specify)

A.

Election Cycle-to-Date 

Date of Receipt

Name of Employer Occupation

    , , .

FEC ID number of contributing

federal political committee. C

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

Receipt For: 

 Primary General

 Other (specify)

B.

Election Cycle-to-Date 

Date of Receipt

Name of Employer Occupation

    , , .

FEC ID number of contributing

federal political committee. C

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

Receipt For: 

 Primary General

 Other (specify)

C.

Election Cycle-to-Date 

Date of Receipt

Name of Employer Occupation

    , , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

 12 13a 13b 14 15

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

Amount of Each Receipt this Period

    , , .

Amount of Each Receipt this Period

    , , .

Amount of Each Receipt this Period

    , , .

FEC Schedule A (Form 3) (Revised 05/2016)

Memo Item

Memo Item

Memo Item

Doe for Congress Committee

Richmond, Hortense

40 Shepard Cir.

Centreville MA 00000

see year-end 2021

reattribution below 5,800.00

5,800.00

12 09 2021

X

X

X Space Tech Engineer

Richmond, Hortense

40 Shepard Cir.

Centreville MA 00000

reattribution below 2,900.00

-2,900.00

02 01 2022

X

X Space Tech Engineer

Richmond, Carol

40 Shepard Cir.

Centreville MA 00000

reattributed 2,900.00

2,900.00

02 01 2022

X

X None Retired

13–6: Reattributions

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Thomason, Steve

145 Netherton Rd.

Tysons Corner VA 00000

Accountant

3,000.00

3,000.00

02 19 2022

X

Pierce, James & Dewey X

exempt accounting services 

from 1/5/22 to 2/10/22

X

13–7: Free legal and accounting services
105

Completing FEC Reports

10. Reporting In-Kind 

Contributions

Schedules A and B

When determining whether to 

itemize an in-kind contribution, a 

committee should treat it the same 

as a monetary contribution. The 

only difference is that the amount 

of an in-kind contribution must 

also be included in the committee’s 

total operating expenditures in 

order to avoid inflating cash on 

hand. An in-kind contribution 

must be itemized as an operating 

expenditure on Schedule B only if it 

has to be itemized as a contribution 

on Schedule A. (For information 

on how to value an in-kind 

contribution, see Chapter 3, Section 

2.) (See examples 13–8 and 13–9.)

Unreimbursed 

disbursements by 

candidates

Campaign expenditures made by 

the candidate from personal funds 

that are not to be reimbursed are 

reported as in-kind contributions 

from the candidate. If the candidate 

makes unreimbursed payments 

on behalf of the committee to any 

single vendor that exceed $200 for 

the election cycle, the committee 

must identify the ultimate payee 

(i.e., the vendor) in a separate 

memo entry on Schedule B.7 Each 

memo entry must include the name 

and address of the vendor to which 

payment was made, as well as the 

date, amount and purpose of the 

payment. (See examples 13–10 and 

13–11.)

7 See the Interpretive Rule on Reporting Ultimate Payees of Political Committee Disbursements (July 8, 2013) available on FEC.gov.

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Gold Nugget Corporation PAC

100 Commerce Ave.

Springfield VA 00000

00000000

1,260.00

260.00

02 20 2022

X

X

in-kind: postage

13–8: In-kind contribution (Schedule A)

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

Memo Item

C

Doe for Congress Committee

Gold Nugget Corporation PAC

100 Commerce Ave.

Springfield VA 00000

260.00

02 20 2022

X

X

In-kind: Postage 00000000

13–9: In-kind contribution (Schedule B)

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Gold Nugget Corporation PAC

100 Commerce Ave.

Springfield VA 00000

00000000

1,260.00

260.00

02 20 2022

X

X

in-kind: postage

13–10: Unreimbursed disbursement by candidate (Schedule A)
106

Chapter 13

Advances of personal 

funds

Although an advance of personal 

funds by an individual to purchase 

goods and services (with the 

exception of some travel costs) is 

considered an in-kind contribution, 

special reporting rules apply if 

it is to be reimbursed. For more 

information, see the next sections 

on reporting advances and travel 

expenses.

Reporting appreciated 

goods as contributions

When a committee receives an inkind contribution whose value may 

appreciate over time, such as stock 

or artwork, special reporting rules 

apply:

• Itemize the initial gift, if 

necessary, as a memo entry 

on Schedule A (see “When 

to Itemize Receipts”). 

Under “Amount,” report 

the fair market value of the 

contribution on the date 

the item was received. Do 

not include that amount in 

the total for the appropriate 

contribution Line 11(a), 11(b), 

11(c) or 11(d) on the Detailed 

Summary Page. No itemization 

on Schedule B is necessary. (See 

example 13–12.)

• Once the item is sold, report 

the sale price as a contribution 

on the appropriate line if 

the purchaser is known or as an “other receipt” on Line 15 if the purchaser is unknown. Itemize the 

transaction on Schedule A if necessary. (See example 13–13.) Also, if the purchaser is known, then the 

amount of the purchase, when aggregated with other contributions by the purchaser, must fall within 

the contribution limits.

104.13(b). See also AOs 2000-30 (PAC.com) and 1989-06 (Boehlert).

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

B. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

Category/

Type

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

Amount of Each Disbursement this Period

FEC Identification Number

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

	 ▲	 ▲	 ▲ , , .

Memo Item

Memo Item

C

C

Doe for Congress Committee

Doe, Jane

626 Pritham Ave.

Springfield VA 00000

201.00

04 20 2021

X

X

Fundraising lunch with donors

Starway Cafe

2880 W. Broad St.

Falls Church VA 00000

201.00

04 20 2021

X

Fundraising lunch with donors

Jane Doe

X

Jane Doe

in-kind

13–11: Unreimbursed disbursement by candidate (Schedule B)

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Kane, Sally

211 Spruce Street

Clifton VA 00000

First National Bank

260.00

185.00

09 21 2022

X

X

X

Banker

in-kind: XYZ Corp stock

13–12: Appreciated goods as contributions
107

Completing FEC Reports

11. Reporting Bitcoin 

Contributions

Schedules A and B

Contributions of bitcoins should 

be reported like an in-kind 

contribution. The committee 

should disclose the receipt of 

the contribution on Schedule A 

and also report the bitcoins as 

a disbursement on Schedule B. 

These offsetting entries allow the 

committee’s reported cash-onhand to remain unchanged while 

holding the bitcoins outside of a 

campaign depository. The value of 

a bitcoin contribution is the market 

value of the bitcoins at the time the 

contribution is received.

The line number on Schedule A 

used to report a bitcoin contribution 

depends on who is giving the 

contribution. Use:

• Line 11(a) if the contribution is 

from an individual

• Line 11(b) if it comes from a 

party committee, and

• Line 11(c) if it comes from 

another type of political 

committee, such as a PAC.

It is recommended to include a 

notation or memo text indicating 

the number of bitcoins that the 

committee received and that the 

bitcoins were not liquidated. The 

corresponding entry on Schedule B 

should be reported on Line 17 with 

the same notation or memo text. 

See example 13–14.

Any usual and nominal fees that 

the processor charges should not 

be deducted from the reported 

value of the contribution. The 

committee should report the usual and nominal fees and commissions that it pays to an online processor as 

an operating expenditure. 104.13(a); AO 2014-02 (Make Your Laws PAC).

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Bull Market Brokerage

1212 King Street

Alexandria VA 00000

750.00

750.00

03 31 2021

X

X XYZ Corp stock sold through 

2022 broker. Purchaser unknown

13–13: Sale of appreciated goods as contributions

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

John Contributor

123 First Street

Alexandria

First Bank Teller

$425.00 0.2 Bitcoins not liquidated 2018

$100.00

VA 22314

02 15 2021

X

X

Martha Washington for Congress

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

Memo Item

C

John Contributor

123 First Street

Alexandria

0.2 Bitcoins not liquidated

0.2 Bitcoins received, not liquidated

$100.00

VA 22314

02 15 2021

X

Martha Washington for Congress

13–14: Bitcoin contributions
108

Chapter 13

12. Reporting Recount-Related Donations and Disbursements

A federal campaign may establish a recount fund either as a separate bank account of the candidate’s 

authorized committee or as a separate entity. In either case, the receipts and disbursements for recount 

expenses must be reported on the authorized committee’s reports as “Other Receipts” and “Other 

Disbursements.” See AO 2006-24 (Republican and Democratic Senatorial Committees).

Reporting recount 

donations

A campaign must include amounts 

received for a recount in its total for 

“Other Receipts,” recorded on Line 

15 of the Form 3 Detailed Summary 

Page (or of the Post-Election 

Detailed Summary Page, when 

filing the Post-General report). As 

illustrated in example 13–15, the 

campaign must itemize the donation 

on Schedule A for Line 15 if the 

aggregate receipts from that donor 

exceed $200 for the election cycle.

Reporting recount 

disbursements

A campaign must include amounts 

spent on a recount in its total for 

“Other Disbursements,” recorded 

on Line 21 of the Form 3 Detailed 

Summary Page (or of the PostElection Detailed Summary Page 

when filing the Post-General 

report). As illustrated in the 

following sections, the campaign 

must itemize the disbursements on 

Schedule B for Line 21 if payments 

to the same payee aggregate more 

than $200 for the election cycle. See 

example 13–16. (Note: For purposes 

of aggregation, the election cycle 

begins the day after the general election.)

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Maxwell, Don

123 Voter Lane

Fairfax

GAH Systems, Inc. Teller

$1,250.00 Recount 2022

$1,250.00

VA 00000

06 12 2022

X

X

Dole for Congress

13–15: Recount donation

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

Memo Item

C

Doe for Congress Committee

Jennifer Lopes

234 Main Street

Springfield VA 00000

500.00

06 20 2022

X

Recount Litigation/Staff Salary

Recount 2022 X

13–16: Recount disbursement
109

Completing FEC Reports

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Colonial Communications

1607 Jamestown Road

Jamestown VA 00000

292.50

03 15 2022

X

X

2022

Refund of overpayment on 

3/01/22 292.50

13. Reporting Offsets to 13–17: Offsets to operating expenditures

Operating Expenditures

For each person who provides 

rebates, refunds and other offsets to 

operating expenditures aggregating 

in excess of $200 during the 

election cycle, the committee 

must provide on Schedule A the 

identification of the person, the 

date and amount of each receipt 

aggregating in excess of $200 during 

the election cycle and the aggregate 

election cycle-to-date total. The 

total amount of offsets to operating 

expenditures (including refunds, 

rebates, and returns of deposits) 

should be reported on Line 14 of the Detailed Summary Page. See example 13–17.

14. Reporting Receipt of Refunds of Contributions Made by the 

Committee

Refunds received by a committee for contributions it made to other political committees or candidates 

should be reported on Line 15 of the Detailed Summary Page and itemized on a supporting Schedule A if 

they aggregate over $200 in an election cycle.

15. Reporting Reimbursed Advances of Personal Funds (Non-Travel)

As explained in Chapter 7, when any individual, including a volunteer, a committee staff member or the 

candidate, uses his or her personal funds or personal credit to pay a vendor for a campaign expense and is 

later reimbursed by the committee, special reporting rules apply.

Non-travel advances made and reimbursed within same reporting period

Non-travel advances that are made and reimbursed within the same reporting period are considered 

contributions and must be reported as follows:

• Do not report the original advance unless, at the end of the reporting period, the amount of previous 

contributions in the election cycle from the person making the advance plus the amount of the advance 

minus the amount of the reimbursement is greater than $200 (i.e., previous contributions + the 

advance - the reimbursement > $200). In that case, report the advance as a memo entry contribution on 

Schedule A; and

• Report the reimbursement as an operating expenditure and, if reimbursements to that person exceed 

$200 in the election cycle, itemize it on Schedule B (with a cross-reference to the memo entry on 

Schedule A for the advance, if the advance was itemized). AO 1992-01 (Faulkner).

• If an individual’s payment on behalf of the committee exceeds $200 in an election cycle to any single 

vendor, then the committee must identify the ultimate payee (the vendor) in a separate memo entry on 

Schedule B.8 (See example 13–18.)

8 See the Interpretive Rule on Reporting Ultimate Payees of Political Committee Disbursements (July 8, 2013) available on FEC.gov.
110

Chapter 13

Non-travel advances 

made and reimbursed in 

different reporting periods

Non-travel advances that are to 

be reimbursed in a later reporting 

period must be reported as follows:

• Do not report the original 

advance unless, at the end 

of the reporting period in 

which the advance was made, 

the amount of previous 

contributions in the election 

cycle from the person making 

the advance plus the amount 

of the advance minus the 

amount of the reimbursement is 

greater than $200 (i.e. previous 

contributions + the advance - 

the reimbursement > $200). In 

that case, report the advance as 

a memo entry contribution on 

Schedule A;

• Report the amount of the advance outstanding at the end of the reporting period as a debt on Schedule 

D if it exceeds $500 or has been outstanding for more than 60 days (see example 13–19); and

• Report the reimbursement, once made, as an operating expenditure and, if reimbursements to that 

person exceed $200 in the election cycle, itemize it on Schedule B (with a cross-reference to the memo 

entry on Schedule A for the advance, if the advance was itemized).

See AO 1992-01 (Faulkner).

As mentioned previously, if an individual’s payment on behalf of the committee exceeds $200 in an election 

cycle to any single vendor, then the committee must identify the ultimate payee (the vendor) in a separate 

memo entry on Schedule B.

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

B. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

Category/

Type

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

Amount of Each Disbursement this Period

FEC Identification Number

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

	 ▲	 ▲	 ▲ , , .

Memo Item

Memo Item

C

C

Doe for Congress Committee

Lin, Megan

460 East End Avenue

Philadelphia PA 00000

750.00

01 20 2022

X

X

Reimbursement for Office Supplies

Big Box Office Shop

900 West 79th Street

Philadelphia PA 00000

750.00

01 12 2022

X

Office Supplies

X

13–18: Nontravel reimbursements
111

Completing FEC Reports

SCHEDULE A (FEC Form 3) 

ITEMIZED RECEIPTS 

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee. 

NAME OF COMMITTEE (In Full) 

Full Name (Last, First, Middle Initial) 

Mailing Address 

City State Zip Code 

Receipt For: 

Primary General 

Other (specify) 

A. 

Election Cycle-to-Date 

Date of Receipt 

Name of Employer Occupation 

    , , . 

FEC ID number of contributing 

federal political committee. C 

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the

Detailed Summary Page 11a 11b 11c 11d

 12 13a 13b 14 15 

M M / D D / 

Amount of Each Receipt this Period 

   , , . 

Memo Item 

Y Y Y Y 

Doe for Congress Committee

Allen, Lisa

828 Pine Street

McLean VA 00000

1,000.00

750.00

01 02 2022

X

X

Staff advance: campaign 

poster print job

X ARC Productions Manager

2022

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

B. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

Category/

Type

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

Amount of Each Disbursement this Period

FEC Identification Number

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

	 ▲	 ▲	 ▲ , , .

Memo Item

Memo Item

C

C

Doe for Congress Committee

Allen, Lisa

828 Pine St.

McLean VA 00000

2022

750.00

06 15 2022

X

X

We Print Everything, Inc.

999 Printers Lane

Fairfax

Campaign poster print job

VA 00000

2022

750.00

01 02 2022

X

X

Repayment of staff advance: see below

SCHEDULE D (FEC Form 3)

DEBTS AND OBLIGATIONS

Excluding Loans

(Use separate

schedule(s) 

for each 

numbered line)

NAME OF COMMITTEE (In Full)

A. Full Name (Last, First, Middle Initial) of Debtor or Creditor

Mailing Address

City State Zip Code

Payment This Period

    , , .

Outstanding Balance at Close of This Period

    , , .

Outstanding Balance Beginning This Period

    , , .

Amount Incurred This Period

    , , .

Nature of Debt (Purpose):

PAGE OF

FOR LINE NUMBER: 

(check only one) 9

 10

Doe for Congress Committee

Allen, Lisa

828 Pine Street

McLean VA 00000

750.00

Campaign poster print job

750.00 0.00

0.00

X

13–19: Nontravel staff advances made and reimbursed in different 

reporting periods
112

Chapter 13

16. Reporting Travel Expenses

As explained in Chapter 10, when a committee pays for its own travel expenses, it reports the payment as 

an operating expenditure. In certain situations, the payment may be made by a campaign traveler. In that 

case, no contribution results if the individual is reimbursed by the committee within certain time periods.

Travel expenses reimbursed within 30 or 60 days

As explained in Chapter 7, no contribution results when the committee reimburses an individual for travel 

expenses within the following time periods:

• If the individual paid with cash or a personal check, within 30 days from the date the expense was 

incurred.

• If the individual paid with a credit card, within 60 days of the closing date on the credit card billing 

statement. 116.5(b). (See Chapter 7, Section 4, “Reimbursed Travel Expenses,” for more information.)

Reimbursed within time limit and in same reporting period

When the committee makes a reimbursement within these time limits, the committee reports the advance 

and reimbursement as follows:

• The original advance is not reported; and

• The reimbursement is reported as an operating expenditure on Line 17. AO 1992-01 (Faulkner).

• If an individual’s payment on behalf of the committee exceeds $200 in an election cycle to any single 

vendor, then the committee must identify the ultimate payee (the vendor) in a separate memo entry on 

Schedule B.

Reimbursed within time limit but in later reporting period

If the reimbursement is made within the appropriate time limit but not within the reporting period in 

which the advance was made, the committee must report the advance on Schedule D as a debt if it exceeds 

$500. Once the reimbursement is actually made, the committee reports it as an operating expenditure and 

itemizes it on Schedule B if reimbursements to any one person exceed $200 for the election cycle.

Travel advances not reimbursed within 30 or 60 days

Not reimbursed within time limit but within same reporting period

Travel advances that are not reimbursed within the appropriate 30 or 60 day time limit (116.5(b)) but 

that are reimbursed within the reporting period in which the advance is made are considered in-kind 

contributions. 100.93(i). Such advances must be reported as follows:

• Report the original advance as a memo entry contribution on Schedule A if the total of the advance plus 

any other contributions made by the same person within the election cycle, minus any reimbursements 

made in the reporting period, exceeds $200; and

• Report the reimbursement as an operating expenditure and, if reimbursements to that person exceed 

$200 in the election cycle, itemize it on Schedule B (with a cross-reference to the memo entry on 

Schedule A for the advance—if the advance was itemized).

Not reimbursed within time limit and not within same reporting period

Travel advances that are not reimbursed within the appropriate 30 or 60 day time limit (116.5(b)) and that 

are not reimbursed within the reporting period in which the advance was made must be reported as follows:

• Report the original advance as a memo entry contribution on Schedule A if the total of the advance plus 

any other contributions made by the same person within the election cycle, minus any reimbursements 

made in the reporting period, exceeds $200;
113

Completing FEC Reports

• Report the amount of the advance outstanding at the end of the reporting period as a debt on Schedule 

D if it exceeds $500 or has been outstanding for more than 60 days; and

• Report the reimbursement as an operating expenditure and, if reimbursements to that person exceed 

$200 in the election cycle, itemize it on Schedule B (with a cross-reference to the memo entry on 

Schedule A for the advance—if the advance was itemized).

Special rule for reporting reimbursements (for travel and subsistence advances)

If the total amount reimbursed for 

a travel or subsistence expense is 

$500 or less, the committee should 

report the individual receiving the 

reimbursement as the payee. If the 

total amount exceeds $500 and 

payments to any one vendor used 

for the expenses total over $200 

for the election cycle, additional 

information is required to achieve 

full disclosure. In this instance the 

committee must:

• Report the individual receiving 

reimbursement as payee; and

• Report the payments 

aggregating over $200 to any 

one vendor as memo entries 

on Schedule B. See AO 1996-20 

(Lucas), footnote 3. Each memo 

entry must include the name 

and address of the vendor, as 

well as the date, amount and 

purpose of the payment.9 (See 

example 13–20.)

• If the individual’s payment was made using a personal credit card, the memo entry must include the 

name and address of the vendor that provided the goods or services to the political committee (rather 

than the credit card company that processed the payment).10

17. Reporting Last-Minute Contributions (48-Hour Notice)

As explained in Chapter 12, campaign committees must file a 48-Hour Notice for any contribution of 

$1,000 or more, including in-kind contributions, loans, earmarked contributions, and contributions 

received through joint fundraising representatives, received less than 20 days but more than 48 hours 

before 12:01 a.m. of the day of any election in which the candidate is running. 104.5(f). The FEC must 

receive the notice within 48 hours of the committee’s receipt of the contribution. 52 U.S.C. §30102(g). The 

committee must also itemize these last-minute contributions in the committee’s next scheduled report. 

104.5(f).

Committees filing electronically must file their 48-Hour Notices electronically. Paper-filing committees 

may file their 48-Hour Notices using FEC Form 6 or may file online using the FEC’s web-based forms. 

9 See the Interpretive Rule on Reporting Ultimate Payees of Political Committee Disbursements (July 8, 2013) available on FEC.gov.

10 See the Interpretive Rule on Reporting Ultimate Payees of Political Committee Disbursements (July 8, 2013) available on FEC.gov.

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

B. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

Category/

Type

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

Amount of Each Disbursement this Period

FEC Identification Number

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

	 ▲	 ▲	 ▲ , , .

Memo Item

Memo Item

C

C

Doe for Congress Committee

Patel, Lana

21 East Main, Apt. 3

Hershey PA 00000

550.00

02 15 2022

X

X

Reimbursement for Airline Tickets

Skyway Airlines

301 Airport Way

Philadelphia PA 00000

550.00

01 12 2022

X

Airline Ticket

X

13–20: Travel expense reimbursed within time limit and in same 

reporting period
114

Chapter 13

Paper-filing committees may use their 

own paper or stationery for the notice, 

provided that the notice contains the 

following information:

• The committee’s name and address;

• The candidate’s name and the office 

sought;

• The identification of the contributor, 

including employer and occupation; 

and

• The amount and date of receipt of the 

contribution.

(See example 13–21.)

48-Hour Notices for 

partnership contributions

If a campaign receives a partnership 

contribution of $1,000 or more 

during the 48-Hour Notice period, the 

committee must file a notice for the 

contribution. There is no need to report 

the individual attribution on the 48-Hour 

Notice.

48-Hour Notices for 

contributions received through 

joint fundraisers

If a campaign receives a joint fundraising 

transfer during the 48-Hour Notice 

period, the committee must file notices 

for all contributions of $1,000 or more included as part of the transfer. There is no need to report the transfer 

itself on the 48-Hour Notice.

48-Hour Notices for contributions received through a conduit

If a campaign receives contributions given through a conduit during the 48-Hour period, the committee must 

file the notices for the original contributions of $1,000 or more. There is no need to report the entity serving 

as a conduit on the 48-hour Notice.

18. Categorizing Disbursements

Like receipts, disbursements are divided into several categories on the Detailed Summary Page of Form 3.

These categories are:

• Line 17, Operating Expenditures

• Line 18, Transfers to Other Authorized Committees

• Line 19(a), Repayments of Loans Made or Guaranteed by the Candidate

• Line 19(b), Repayments of All Other Loans

• Line 19(c), Total Loan Repayments

1. NAME OF COMMITTEE IN FULL

ADDRESS (number and street)

CITY STATE ZIP CODE

2. NAME OF CANDIDATE 3. OFFICE SOUGHT (State and District) 4. FEC IDENTIFICATION NUMBER

5. IS THIS AN AMENDMENT? NO, THIS IS A NEW FILING YES, IT AMENDS THE NOTICE FILED ON

A. FULL NAME

MAILING ADDRESS

CITY STATE ZIP CODE

B. FULL NAME

MAILING ADDRESS

CITY STATE ZIP CODE

C. FULL NAME

MAILING ADDRESS

CITY STATE ZIP CODE

D. FULL NAME

MAILING ADDRESS

CITY STATE ZIP CODE

E. FULL NAME

MAILING ADDRESS

CITY STATE ZIP CODE

Name of Employer Date (month, 

day, year)

Name of Employer

Name of Employer

Name of Employer

Name of Employer

Occupation

Occupation

Occupation

Occupation

Occupation

48-HOUR NOTICE OF

CONTRIBUTIONS/LOANS RECEIVED (See Reverse Side for Instructions)

Any information copied from reports and statements filed under the Federal Election Campaign Act may not 

be sold or used by any person for the purpose of soliciting contributions or for commercial purposes other 

than using the name and address of any political committee to solicit contributions from such committee.

SIGNATURE (optional) DATE For further information contact:

Federal Election Commission

1050 First Street, N.E., Washington, DC 20463

Toll Free 800-424-9530, Local 202-694-1100

FEC FORM 6 (Revised 03/2016)

To be used to report all contributions (including loans) of $1000 or more, received within 20 days of the election.

Amount

Date (month, 

day, year)

Amount

Date (month, 

day, year)

Amount

Date (month, Amount

day, year)

Date (month, Amount

day, year)

/ /

Doe for Congress Committee

319 Main Street

Springfield VA 00000

Jane Doe VA-12 C00033000

X

First National Bank

Banker

U.S. House of 

Representatives

Representative

6/1/22

6/1/22

6/2/22

$1,500

$1,000

$25,000 (loan)

Michael Ortega

211 Spruce Street

Clifton VA 00000

Gold Nugget Corporation PAC

100 Commerce Ave.

Springfield VA

Jane Doe

626 Pritham Ave.

Springfield VA

00000

00000

Gottlob Frege 6/2/22

13–21: Last minute contributions (48-hour notice)
115

Completing FEC Reports

• Line 20(a), Refunds of Contributions (made by) Individuals/Persons Other than Political Committees

• Line 20(b), Refunds of Contributions (made by) Political Party Committees

• Line 20(c), Refunds of Contributions (made by) Other Political Committees (such as PACs)

• Line 20(d), Total Contribution Refunds

• Line 21, Other Disbursements

For detailed information describing each category, see “The Detailed Summary Page” section later in this 

chapter.

For each category, a committee must disclose the total for the current reporting period and the electioncycle-to-date total. In addition to reporting these totals, a committee often has to itemize disbursements by 

providing supplemental information on supporting Schedules B. 104.3(b)(2) and (4). A committee must 

use a separate Schedule B for each category of disbursements that must be itemized; the committee may 

not mix different categories of disbursements on the same schedule. Electronic filers must separately enter 

each disbursement when entering data in order to correctly generate the report. Paper-filing committees 

should complete the supporting schedules first so that they may transfer totals from these schedules to the 

Detailed Summary Page.

19. How to Itemize Disbursements

For each disbursement that must be itemized, the committee must include the following information:

• Name of payee;

• Address of payee;

• Purpose of disbursement (a brief description of why the disbursement was made);

• Category/Type of disbursement (numbered categories detailed on the Instructions for Schedule B, 

Itemized Disbursements), (filling in this category is optional);

• Date of disbursement; and

• Amount of disbursement.

104.3(b)(4) and 104.9.

Purpose

For reporting purposes, the “purpose” of disbursement refers to a brief statement or description about the 

reason for the disbursement. The description must be sufficiently specific, when considered within the 

context of the payee’s identity, to make the reason for the disbursement clear. 104.3(b)(4)(i)(A) and (B). 

The Commission has published a 

non-exhaustive list of acceptable 

and unacceptable purpose 

descriptions at FEC.gov.

Election designation

When itemizing a disbursement, 

the committee does not need to 

check the box designating it for 

a particular election (“primary,” 

“general” or “other”), unless the 

entry relates to a contribution to 

another candidate. In that case, 

the committee must indicate the 

election to which it relates. (See 

example 13–22.)

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

Memo Item

C

Doe for Congress Committee

Quick Printing Inc.

567 4th Street

Fair Lakes VA 00000

300.00

01 28 2021

X

Printing Brochures 006

X

2022

13–22: Operating expenditures
116

Chapter 13

Contributions to other candidates

Contributions to other candidates are included in the total for Line 21 (“Other Disbursements”) and are 

itemized on Schedule B for that line if they are made to a federal candidate for any amount or are made to 

a nonfederal candidate and exceed $200 for the election cycle to date. When itemizing a contribution to 

another candidate (either federal or nonfederal, e.g., state or local), the committee must report the purpose 

and indicate the election designation. See 104.3(b)(4)(vi).

Additional information required for contributions to other federal candidates

If the contribution is to a federal candidate, the committee must also itemize:

• The recipient candidate’s name;

• The office sought by checking 

the appropriate box;

• The state and, if applicable, 

congressional district; and

• The election for which the 

contribution was made (by 

checking the appropriate 

box: “primary,” “general” or 

“other”). It is recommended 

that the committee designate 

any contributions it makes. (See 

example 13–23.)

20. When to Itemize 

Disbursements

Regardless of amount

Three categories of disbursements must be itemized regardless of amount:

• Transfers (Line 18);

• Loan Repayments (Lines 19(a) and 19(b)); and

• Contributions to other federal candidates (Line 21)

Refunds of contributions must be itemized only if the incoming contribution had to be itemized on 

Schedule A. See 104.3(b)(4)(ii), (iii), (v) and (vi).

Itemization threshold exceeded

Two categories of disbursements are subject to the $200 election cycle threshold for itemization:

• Operating Expenditures (Line 17); and

• Other Disbursements (encompassing all disbursements that do not fit into the other categories) (Line 

21). 104.3(b)(4)(i) and (vi).

A disbursement under these categories must be itemized if it:

• Exceeds $200; or

• Aggregates over $200 when added to other disbursements (within the same category) made to the same 

payee during an election cycle.

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

Memo Item

C

Doe for Congress Committee

Cunningham for Senate

77 Center Street

Houston TX 00000

2,000.00

03 29 2022

X

Contribution 011

X X

TX

Richard Cunningham

13–23: Contributions to other federal candidates
117

Completing FEC Reports

Credit card transactions

In the case of operating 

expenditures charged on a credit 

card, a committee must itemize 

a payment to a credit card 

company if the payment exceeds 

the $200 aggregate threshold for 

itemization explained previously. 

The committee must also itemize, 

as a memo entry, any specific 

transaction charged on a credit 

card if the payment to the actual 

vendor exceeds the $200 threshold. 

The memo entry must include the 

name and address of the vendor, the 

purpose of the disbursement and 

the amount of the disbursement. 

Finally, any credit card debt must be 

reported following the procedures 

outlined in the next section.11

102.9(b)(2) and 104.9. (See 

examples 13–24 and 13–25.)

21. Reporting Debts 

Other Than Loans

Schedule D: continuous 

reporting

Debts and obligations must be 

reported continuously until repaid. 

104.3(d) and 104.11. Unpaid 

bills and written contracts or 

agreements to make expenditures 

are considered debts. See 100.112. 

Debts and obligations (other than 

loans—see Section 21 for reporting 

loans) are reported on Lines 9 

and 10 of the Summary Page and 

itemized on Schedule D according 

to the following rules:

• A debt of $500 or less is reportable once it has been outstanding 60 days from the date incurred (the 

date of the transaction, not the date the bill is received). The debt is disclosed on the next regularly 

scheduled report.

• A debt exceeding $500 must be reported in the report covering the date on which the debt was 

incurred. 104.3(d), 104.11 and 116.6(c).

11 See also, the Interpretive Rule on Reporting Ultimate Payees of Political Committee Disbursements (July 8, 2013) available on FEC.

gov.

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

B. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

Category/

Type

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

Amount of Each Disbursement this Period

FEC Identification Number

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

	 ▲	 ▲	 ▲ , , .

Memo Item

Memo Item

C

C

Doe for Congress Committee

Credit Card Company

12 Muche Ct.

Philadelphia PA 00000

1,300.00

02 28 2022

001

X

Credit card payment -- see below

Southeast Airlines

777 Jetstream Way

Dulles VA 00000

750.00

01 12 2022

Airline tickets 002

X credit card co.

X

X

2022

2022

13–24: Credit card transactions (Schedule B)

SCHEDULE D (FEC Form 3)

DEBTS AND OBLIGATIONS

Excluding Loans

(Use separate

schedule(s) 

for each 

numbered line)

NAME OF COMMITTEE (In Full)

A. Full Name (Last, First, Middle Initial) of Debtor or Creditor

Mailing Address

City State Zip Code

Payment This Period

    , , .

Outstanding Balance at Close of This Period

    , , .

Outstanding Balance Beginning This Period

    , , .

Amount Incurred This Period

    , , .

Nature of Debt (Purpose):

PAGE OF

FOR LINE NUMBER: 

(check only one) 9

 10

Doe for Congress Committee

Credit Card Company

12 Muche Ct.

Philadelphia PA 00000

credit card debt

1,300.00

1,200.00

X

1,300.00 1,200.00

13–25: Credit card transactions (Schedule D)
118

Chapter 13

The committee must use separate Schedule D forms for debts owed by the committee (Line 10) versus 

debts owed to the committee (Line 9). Paper filers must label each schedule accordingly by checking the 

appropriate box at the top of the form; electronic filing programs will label the schedules for you.

Exception

Regularly recurring administrative expenses such as rent, utilities and salaries are not considered to be 

debts until they are past due. 104.11(b).

Debts owed by the committee

The committee reports the total of 

outstanding debts (from Schedule 

D) plus the balance of loans owed 

by the committee (from Schedule 

C) on Line 10 of the Summary Page.

Itemizing debts owed

Schedule D is used to report:

• The outstanding amount owed 

on a debt or obligation;

• Payments made to reduce the 

debt;

• Complete name and address of 

creditor; and

• The nature and purpose of the 

debt.

The instructions for Schedule D 

explain what additional information 

is required. Note that payments to 

reduce debts must also be reported 

under the appropriate category 

of disbursement, on the Detailed 

Summary Page (for example, Line 

17 for a payment on a bill for 

an operating expenditure). (See 

examples 13–24, 13–25, 13–26 and 

13–27.)

Settlement of debts

Special rules apply to debts that are 

forgiven or settled for less than their full amount. See Chapter 14 for more information.

Special debt reporting problems

Debts of unknown amount

If the exact amount of a debt is not known, the committee reports an estimated amount. The committee 

must either amend the report (and all subsequent reports) to indicate the correct amount, once a correct 

figure is known, or include the correct figure, along with an explanation of the change, in the report for the 

reporting period during which the amount is determined. 104.11(b).

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

Memo Item

C

Doe for Congress Committee

WCFS-FM

1290 Tower Street

Winchester VA 00000

2,500.00

01 31 2022

X

Radio advertisement 004

See Schedule D

Jane Doe

X

2022

13–26: Debts owed by the committee (Schedule B)

SCHEDULE D (FEC Form 3)

DEBTS AND OBLIGATIONS

Excluding Loans

(Use separate

schedule(s) 

for each 

numbered line)

NAME OF COMMITTEE (In Full)

A. Full Name (Last, First, Middle Initial) of Debtor or Creditor

Mailing Address

City State Zip Code

Payment This Period

    , , .

Outstanding Balance at Close of This Period

    , , .

Outstanding Balance Beginning This Period

    , , .

Amount Incurred This Period

    , , .

Nature of Debt (Purpose):

PAGE OF

FOR LINE NUMBER: 

(check only one) 9

 10

Doe for Congress Committee

WCFS-FM

1290 Tower Street

Winchester VA 00000

radio advertisement; see 

Schedule B, Line 17

5,500.00

0.00

X

2,500.00 3,000.00

13–27: Debts owed by the committee (Schedule D)
119

Completing FEC Reports

Unpayable debts

If a debt cannot be paid because the creditor has gone out of business or cannot be located, the treasurer 

may write to the FEC to request permission to discontinue reporting the debt. The letter must demonstrate 

that the debt is at least two years old and that efforts to ascertain the current address of the creditor and to 

reach the creditor have been made by registered or certified letter and either in person or by phone. The 

committee must continue to report the debt until the Commission determines that the debt is unpayable. 

116.9.

Disputed debts

A disputed debt is a bona fide disagreement between the creditor and the committee as to the existence 

of a debt or the amount owed by the committee. 116.10. If the creditor provided something of value, 

notwithstanding the disputed amount, then the committee must disclose:

• The amount the committee admits it owes;

• The amount the creditor claims is owed; and

• Any amounts the committee has paid the creditor.

The committee may also note on the report that disclosure of a disputed debt is not an admission of liability 

or a waiver of any claims against the creditor. Once a disputed debt is resolved, the committee should report 

the correct amount on the next report, along with a statement explaining that the dispute was resolved.

Debts owed to the committee

The committee must continuously report a debt owed to the committee on Schedule D if the debt exceeds 

$500 or has been outstanding 60 days. 104.3(d) and 104.11. Payments received on the debt are also 

reported on Schedule D until the debt is retired. The debt repayments received must also be reported on the 

appropriate line number of the Detailed Summary Page and itemized on Schedule A if necessary. On Line 9 

of the Form 3 Summary Page, the committee enters the total of outstanding debts owed to it (from Schedule 

D), plus the balance of outstanding loans owed to it (from Schedule C). Paper filers must be sure to label 

the Schedule D as “debt owed to the committee” by checking the box for Line 9 at the top of Schedule D.

22. Reporting Loans

All loans received by a committee must be itemized and continuously reported until extinguished. 104.3(a)

(4)(iv) and (d); 104.11. All repayments made on a loan must also be itemized. 104.3(b)(4)(iii). Procedures 

for reporting loans and loan repayments are explained in this section. See also “Reporting Contributions, 

Loans and Advances from 

Candidate” in Section 6 of this 

chapter.

Schedule A: Initial receipt 

of loan

A committee must itemize the 

receipt of a loan, regardless of 

amount, on a separate Schedule A 

for the appropriate loan category 

(“made/guaranteed by the 

candidate” or “all other loans”). 

(See example 13–28.) 104.3(a)(4)

(iv).

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

National Trust Bank

800 Lincoln Ave.

Reston VA 00000

20,000.00

20,000.00

03 01 2022

X

X

(guaranteed 

by candidate)

2022

13–28: Bank loans endorsed by candidate
120

Chapter 13

Schedule B: Interest and principal payments

A committee must report interest 

paid on a loan as an operating 

expenditure, itemizing the payment 

on a Schedule B for operating 

expenditures once interest 

payments to one payee aggregate 

over $200 in an election cycle.

Payments to reduce principal must 

be itemized, regardless of amount, 

on a Schedule B for the appropriate 

category of loan repayment (“made/

guaranteed by the candidate” or “all 

other loans”). 104.3(b)(4)(iii). (See 

example 13–29.)

Schedule C: Continuous 

reporting

In addition, both the original loan 

and payments to reduce principal 

must be reported on Schedule 

C each reporting period (see 

examples) until the loan is repaid.

Committee has no other debts 

or obligations

If the committee has no other debts, 

the Schedule C balance of the total 

amount owed on loans is entered 

on Line 10 of the Form 3 Summary 

Page (“Debts and Obligations Owed 

by the Committee”).

Committee has other debts 

or obligations (reported on 

Schedule D)

If the committee has other debts 

or obligations that are reported on 

Schedule D, the total amount owed 

on loans is entered on Line 3 at the 

bottom of Schedule C and is carried 

over to the last page of Schedule 

D along with the other debts and 

obligations. The total from Schedule 

D is then entered on Line 10 of the 

Form 3 Summary Page reflecting all 

outstanding debts or obligations.

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

Memo Item

C

Doe for Congress Committee

National Trust Bank

800 Lincoln Avenue

Reston VA 00000

271.18

03 30 2022

X

Loan principal payment 009

X

2022

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Doe, Jane

626 Pritham Ave.

Springfield VA 00000

12,200.00

10,000.00

03 23 2022

X

X

(personal funds) U.S. House U.S. Representative

SCHEDULE C (FEC Form 3)

LOANS

PAGE OF

Use separate schedule(s) 

for each category of the 

Detailed Summary Page

NAME OF COMMITTEE (In Full)

    , , .    , , .    , , .

Original Amount of Loan Cumulative Payment To Date Balance Outstanding at Close of This Period

 Date Incurred Date Due Interest Rate Secured: 

 

 Yes No . % (apr)

Election: 

 Primary 

 General

 Other (specify) 

 LOAN SOURCE Full Name (Last, First, Middle Initial)

 Mailing Address

 City State ZIP Code

TERMS

FOR LINE NUMBER: 

(check only one) 13a

 13b

 M M / D D / Y Y Y Y M M / D D / Y Y Y Y

Memo Item

Personal Funds of the Candidate

(If none, enter 0)

Doe for Congress Committee

Doe, Jane

626 Pritham Ave.

Springfield VA 00000

10,000.00 0.00 10,000.00

03 23 2022 none none X

X

X

X

13–29: Loan payment

13–30: Loans from candidate’s personal funds (Schedule A)

13–31: Loans from candidate’s personal funds (Schedule C)
121

Completing FEC Reports

Schedule C-1: Additional information for loans from lending institutions

A committee that obtains a loan from a bank or other permissible lending institution must also file 

Schedule C-1 with the first report due after a new loan or line of credit has been established. 104.3(d)(1). 

A new Schedule C-1 must also be filed with the next report if the terms of the loan or line of credit are 

restructured. Additionally, in the case of a committee that has obtained a line of credit, a new Schedule C-1 

must be filed with the next report whenever the committee draws on the line of credit. 104.3(d)(1) and 

(3). (See 13–36 for example of C-1.) For loans derived from a candidate loan, the reporting on Schedule C-1 

is simplified. See the next section for more information.

Line-by-line instructions for filling out the schedule appear in the Form 3 instruction booklet. The 

committee treasurer or designated assistant treasurer must sign the schedule on Line G and attach a copy of 

the loan agreement. 104.3(d)(2).

Finally, an authorized representative of the lending institution must sign the statement on Line I.

23. Reporting Bank Loans, Brokerage Loans and Other Lines of Credit 

When Made to Candidates

Bank loans to candidates and loans derived from advances on a candidate’s brokerage accounts, credit cards, 

home equity line of credit, or other lines of credit obtained for use in connection with his or her campaign 

must be reported by the committee. 100.83. The committee must report the loan from the candidate as a 

receipt and repayment of the loan to the candidate as a disbursement. 104.3(a)(3)(vii)(B) and (b)(2)(iii)

(A).

Schedule A

The candidate may choose either to loan or to contribute the loan proceeds to the authorized committee. If 

the candidate treats the funds as a personal contribution, the receipt of the contribution from the candidate 

must be reported on Schedule A for Line 11(d). If the candidate treats the funds as a loan, the receipt of the 

loan must be reported on Schedule A for Line 13(a). (See example 13–33.) If the funds are designated as a 

contribution, then the committee cannot repay the underlying loan to the financial institution. AO 2006-37 

(Kissin for Congress).

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Doe, Jane

626 Pritham Ave.

Springfield VA 00000

60,000.00

50,000.00

03 15 2022

X

X

home equity line 

of credit

U.S. House U.S. Representative

13–32: Candidate home equity line of credit (Schedule A)
122

Chapter 13

Schedule B

If the funds are designated as a 

loan, the committee’s repayment 

to the lending institution or 

the candidate is reported as an 

itemized entry on Schedule B. 

104.3(b)(4)(iii). The committee 

is not required to report 

repayments by the candidate 

to the lending institution. The 

loan must also be continually 

reported on Schedule C until it 

is extinguished. (See example 

13–34.)

Schedule C

The committee need only list 

the candidate as the source 

of the loan on Schedule C. 

However, the type of loan the 

candidate receives (i.e. bank 

loan, brokerage account, credit 

card, home equity line of credit, 

other line of credit) must also 

be disclosed in either the first 

box for endorsers and guarantors 

with a notation for loan type 

or in the box for “Loan Source” 

after the candidate’s name. (See 

example 13–35.)

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

Memo Item

C

Doe for Congress Committee

Doe, Jane

626 Pritham Ave

Springfield VA 00000

5,000.00

03 30 2022

X

Line of credit payment (candidate loan)

X

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

Memo Item

C

Doe for Congress Committee

Doe, Jane

626 Pritham Ave

Springfield VA 00000

350.00

03 30 2022

X

Interest payment on candidate loan

X

SCHEDULE C (FEC Form 3)

LOANS

PAGE OF

Use separate schedule(s) 

for each category of the 

Detailed Summary Page

NAME OF COMMITTEE (In Full)

    , , .    , , .    , , .

Original Amount of Loan Cumulative Payment To Date Balance Outstanding at Close of This Period

 Date Incurred Date Due Interest Rate Secured: 

 

 Yes No . % (apr)

Election: 

 Primary 

 General

 Other (specify) 

 LOAN SOURCE Full Name (Last, First, Middle Initial)

 Mailing Address

 City State ZIP Code

TERMS

FOR LINE NUMBER: 

(check only one) 13a

 13b

 M M / D D / Y Y Y Y M M / D D / Y Y Y Y

Memo Item

Personal Funds of the Candidate

(If none, enter 0)

Doe for Congress Committee

Doe, Jane - Home equity line of credit

626 Pritham Ave.

Springfield VA 00000

50,000.00 5,000.00 45,000.00

03 15 2022 6.00 X

X

X

01 31 2024

13–33: Candidate home equity line of credit principal payment

13–34: Candidate home equity interest payment

13–35: Candidate home equity line of credit (Schedule C)
123

Completing FEC Reports

Schedule C-1

The committee must disclose, in the 

report covering the period when 

the loan was obtained, the following 

information on Schedule C-1 (see 

example 13–36):

• The date, amount, and interest 

rate of the loan, advance or line 

of credit;

• The name and address of the 

lending institution; and

• The types and value of collateral 

or other sources of repayment 

that secure the loan, advance or 

line of credit. 104.3(d)(1).

Unlike bank loans to committees, 

when reporting bank loans obtained 

by the candidate or loans derived 

from the candidate’s brokerage 

account, credit card, home equity 

line of credit or other line of credit, 

the committee is not required to 

submit the loan agreement to the 

Commission. Note, however, that 

Schedule C-1 must still be filed 

when the candidate obtains a loan 

and then contributes the proceeds 

to the committee. 104.3(d)(4).

Keeping records

The committee must retain records 

relating to the loan for three years 

after the date of the election in which the candidate ran. Additionally, the candidate must preserve the 

following records for three years after the election for which he or she was a candidate:

• Records to demonstrate the ownership of the accounts or assets securing the loans;

• Copies of the executed loan agreements and all security and guarantee statements;

• Statements of account for all accounts used to secure any loan for the period the loan is outstanding, 

such as brokerage accounts or credit card accounts and statements on any line of credit that was used 

for the purpose of influencing the candidate’s election for federal office;

• Documentation to establish the source of the funds in the account and the time of the loan; and

Documentation for all payments made on the loan by any person. 104.14(b)(3) and (4).

24. Reporting Liquidated Bitcoins

Reporting for liquidating bitcoins received as contributions depends on whether the committee sells to a 

known purchaser or to an unknown purchaser.

E. Are any future contributions or future receipts of interest income, pledged as 

 collateral for the loan? No Yes If yes, specify: 

D. Are any of the following pledged as collateral for the loan: real estate, personal 

 property, goods, negotiable instruments, certificates of deposit, chattel papers, 

 stocks, accounts receivable, cash on deposit, or other similar traditional collateral?

 No Yes If yes, specify:

SCHEDULE C-1 (FEC Form 3)

LOANS AND LINES OF CREDIT FROM LENDING INSTITUTIONS

Federal Election Commission, Washington, D.C. 20463

Supplementary for 

Information found on 

Page of Schedule C

FEC IDENTIFICATION NUMBER

C

NAME OF COMMITTEE (In Full)

 LENDING INSTITUTION (LENDER) 

 Full Name

 Mailing Address

 City State Zip Code

Amount of Loan

    , , .

FEC Schedule C-1 (Form 3) (Revised 05/2016)

Interest Rate (APR)

A. Has loan been restructured? No Yes If yes, date originally incurred

B. If line of credit, Total 

 Outstanding

 Amount of this Draw:    , , . Balance:    , , .

    , , .

    , , .

AUTHORIZED REPRESENTATIVE 

 Typed Name

 Signature Title

DATE

H. Attach a signed copy of the loan agreement.

I. TO BE SIGNED BY THE LENDING INSTITUTION:

 I. To the best of this institution’s knowledge, the terms of the loan and other information regarding the extension of the loan 

 are accurate as stated above.

 II. The loan was made on terms and conditions (including interest rate) no more favorable at the time than those imposed for 

 similar extensions of credit to other borrowers of comparable credit worthiness.

 III. This institution is aware of the requirement that a loan must be made on a basis which assures repayment, and has 

 complied with the requirements set forth at 11 CFR 100.82 and 100.142 in making this loan.

G. COMMITTEE TREASURER 

 Typed Name

 Signature

F. If neither of the types of collateral described above was pledged for this loan, or if the amount pledged does not equal or 

 exceed the loan amount, state the basis upon which this loan was made and the basis on which it assures repayment.

C. Are other parties secondarily liable for the debt incurred?

 No Yes (Endorsers and guarantors must be reported on Schedule C.)

Date Incurred or Established

Date Due

DATE

Date account established: 

Location of account:

Address:

City, State, Zip:

A depository account must be established pursuant 

to 11 CFR 100.82(e)(2) and 100.142(e)(2). 

 . %

What is the value of this collateral?

Does the lender have a perfected security

interest in it? No Yes

What is the estimated value?

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

Doe for Congress Committee

National Trust Bank

800 Lincoln Avenue

Reston VA 00000

250,000.00

real estate

50,000.00

X

X

X

X

00033000

6.00

03 15 2022

01 31 2024

03 15 2022

0.00 0.00

X 0.00

Gottlob Frege

Gottlob Frege

13–36: Candidate home equity line of credit (Schedule C-1)
124

Chapter 13

Selling to a known purchaser

If the committee sells the bitcoins directly to a purchaser, and therefore knows the identity of the 

purchaser, the purchaser is considered to have made a contribution to the committee.

The committee should report 

the purchaser’s name, address, 

occupation and employer 

information on Schedule A, Line 

11a. The committee must also report 

the date of the purchase, amount 

the bitcoin were sold for, election 

designation, and the contributor’s 

aggregate election cycle-to-date 

total. Next, the committee must 

create a memo entry disclosing the 

original contributor’s information, 

date of contribution, original value 

of the bitcoins, and the number 

of bitcoins originally given to the 

committee. See example 13–37.

Selling to an unknown 

purchaser

If the committee sells the bitcoins 

through an established market 

mechanism where the purchaser 

is not known, the purchaser is 

not considered to have made a 

contribution to the committee.

The committee should report the 

market or exchange’s name on 

Schedule A, Line 15. The committee 

will also report the address 

information for the exchange, as 

well as the date of the purchase, the 

amount the bitcoins were sold for, 

and the aggregate election cycleto-date total for the exchange. The 

committee includes how many 

bitcoins were sold, where they 

were sold, and that the purchaser is 

unknown. The committee will also 

report a memo entry disclosing the 

original contributor’s information, 

date of contribution, original value 

of the bitcoins and the number 

of bitcoins originally given to the 

committee. See example 13–38. 

104.13(b); AO 2014-02 (Make Your Laws PAC).

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

B.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Amount of Each Receipt this Period

, , .

Memo Item

Memo Item

Jane Purchaser

John Contributor

4456 Main Street

123 First Street

Arlington

Alexandria

Purchase of 0.2 Bitcoins

0.2 Bitcoins, contribution

previously disclosed

Memorial Hospital

First Bank

Physician

Teller

2022

$2,500.00

$100.00

$2,500.00

$425.00

TX

VA

76006

22314

04 15 2021

02 15 2021

X

X

X

Martha Washington for Congress

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

B.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Amount of Each Receipt this Period

, , .

Memo Item

Memo Item

ABC Bitcoin Exchange

John Contributor

789 West Street

123 First Street

New York

Alexandria

0.2 Bitcoins sold via ABC

Exchange – purchaser unknown

0.2 Bitcoins, contribution

previously disclosed

First Bank Teller

$2,500.00

$100.00

$2,500.00

$425.00

NY

VA

10005

22314

04 15 2021

02 15 2021

X

X

2022

X

Martha Washington for Congress

13–37: Selling bitcoin to known purchaser

13–38: Selling bitcoin to unknown purchaser
125

Completing FEC Reports

25. Reporting Refunds, Returns, Bounced or Uncashed Checks and 

Disgorged Contributions

Refunds and returns

A refund occurs when the 

committee has actually deposited 

a contribution in its bank 

depository and then pays it back 

to the contributor by issuing a 

check. When a committee refunds 

a contribution to a donor, the 

committee must include the refund 

in the total for the appropriate 

category of refund on the Detailed 

Summary Page (Lines 20(a), (b) or 

(c)). If the committee previously 

itemized the incoming contribution 

on Schedule A, then it must itemize 

the refund on a Schedule B for the 

appropriate category of refund. 

104.8(d)(4). (See examples 13–39 

and 13–40.)

Alternatively, a committee may 

return a contribution to the donor 

without depositing it, although the 

return must be made within 10 

days of the treasurer’s receipt of 

the contribution. 103.3(a). In this 

case, the committee does not have 

to report either the receipt or the 

return of the contribution.

Checks returned due to 

insufficient funds

If a committee reports the receipt of a check and later finds it cannot be negotiated because of insufficient 

funds in the donor’s account, the committee should deduct the amount of the check in its next report as 

follows:

• If the committee did not itemize the receipt on a previous report, it subtracts the amount of the check 

from the total for the appropriate category of receipts. The reduced total is entered on the Detailed 

Summary Page.

• If the committee previously itemized the receipt, it itemizes the return of the check as a negative entry 

on the appropriate Schedule A. (See example 13–41.)

Checks received and returned by the bank in the same reporting period do not need to be reported.

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Very Controversial PAC

879 Peabody Street

Washington DC 00000

5,000.00

5,000.00

03 19 2021

X

X

refunded 3/30/21

see Schedule B, 

Line 20(c)

C00000010

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

FEC Identification Number

	 ▲	 ▲	 ▲ , , .

Memo Item

C

Doe for Congress Committee

Very Controversial PAC

879 Peabody Street

Washington DC 00000

5,000.00

03 30 2021

X

Refund of 3/19/21 contribution 001

see Schedule A, 

Line 11(c)

Jane Doe

X

C00000010

13–39: Refunded contributions (Schedule A)

13–40: Refunded contributions (Schedule B)
126

Chapter 13

Checks never cashed by the 

recipient

A check issued by a committee that 

was never cashed by the recipient 

should be reported as a negative 

entry on Schedule B supporting the 

line on which the disbursement 

was originally disclosed if the 

disbursement required itemization. 

The committee should include memo 

text explaining that the check was 

not cashed. For disbursements not 

requiring itemization, the amount 

of the uncashed check should be 

subtracted from the unitemized total 

for the applicable line.

Disgorged contributions

As explained in Chapter 5, if a 

committee deposits a contribution 

that appears to be legal and later 

discovers that it is prohibited, 

the committee must refund 

the contribution to the original 

contributor (if known) within 30 days 

of making the discovery. 103.3(b)

(2). Alternatively, the committee 

may disgorge the funds to the U.S. 

Treasury. AO 1996-05 (Kim). This 

disgorgement should be reported as 

follows:

• Report the payment to the 

U.S. Treasury on Schedule B 

supporting Line 21 as an “Other 

Disbursement,” if payments to the 

U.S. Treasury exceed $200 in the 

election cycle. Report the purpose 

as “disgorgement.”

• If the identity of the original 

contributor is known and the 

contribution required itemization, 

report the original contribution 

as a memo entry on Schedule B 

supporting Line 21, with a crossreference to the entry for the 

payment to the U.S. Treasury. 

(See example 13–42.)

For more information about disgorging contributions, see Chapter 5, Section 2.

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Light, Jack

421 Overdraw Street

Falls Church VA 00000

0.00

-300.00

03 01 2021

X

X

None Graduate Student bounced check

SCHEDULE B (FEC Form 3)

ITEMIZED DISBURSEMENTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

    , , .

    , , . SUBTOTAL of Disbursements This Page (optional) .......................................................................

TOTAL This Period (last page this line number only) ....................................................................  

FEC Schedule B (Form 3) (Revised 05/2016)

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

A. Date of Disbursement

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

B. Date of Disbursement

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

C. Date of Disbursement

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page

Category/

Type

17 18 19a 19b

20a 20b 20c 21

Disbursement For: 

 Primary General

 Other (specify) 

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

Category/

Type

Disbursement For: 

 Primary General

 Other (specify) 

Purpose of Disbursement

Candidate Name

Office Sought: House

 Senate

 President

State: District:

Category/

Type

Disbursement For: 

 Primary General

 Other (specify) 

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

Amount of Each Disbursement this Period

Amount of Each Disbursement this Period

Amount of Each Disbursement this Period

FEC Identification Number

FEC Identification Number

FEC Identification Number

    , , .

    , , .

    , , .

Memo Item

Memo Item

Memo Item

C

C

C

Doe for Congress Committee

U.S. Treasury

PO Box 1328

Parkersburg WV 26106

5,000.00

09 20 2021

X

Disgorged Contributions

(unknown contributors) X

U.S. Treasury

PO Box 1328

Parkersburg WV 26106

1,000.00

10 01 2021

Disgorged Contribution

see contributor 

information below

X

Suspicious LLC

500 Questionable Lane

Springfield VA 00000

1,000.00

10 01 2021

Disgorged Contribution

X

X

6,000.00

13–41: Checks returned due to insufficient funds

13–42: Disgorged contributions
127

Completing FEC Reports

26. Reporting Transfers between Authorized Committees

As explained in Chapter 9, authorized committees may make and receive transfers to and from other 

federal authorized committees of the same candidate. The following sections explain the rules for reporting 

the permissible transfers discussed in Chapter 9.

Transfers between candidate’s committees for the same office

In the same election cycle

Transfers between a candidate’s 

authorized committees for the 

same election are reported by the 

transferring committee on Line 18 

of the Form 3 Detailed Summary 

Page, and by the committee 

receiving the transfer on Line 12 

of the Form 3 Detailed Summary 

Page. 104.3(a)(3)(vi) and (b)(2)

(ii). The receiving committee does 

not need to reitemize the sources 

of the funds transferred (e.g., 

contributions that comprise the 

transfer) because the transferring 

committee has already itemized 

them in its report to the principal campaign committee, which is attached to the principal campaign 

committee’s consolidated report (Form 3Z). 110.3(c). (See example 13–43.)

In different election cycles

The receiving committee also does not have to itemize contributions transferred between committees 

authorized by one candidate for two different election cycles as long as the original contributions count 

against the limits for the election for which the contributions were intended. 110.3(c)(4).

Example: A 2020 House candidate has a surplus from that campaign. The candidate may roll over that 

amount to his or her committee for reelection in 2022 without again itemizing the contributions that make 

up the transfer, provided that:

He or she did not become a candidate for the 2022 election before the 2020 general election; and

The surplus transferred from the 2020 committee consists of contributions that count against the 2020 

limits rather than the 2022 limits (i.e., were designated for or made prior to the 2020 general election).

Transfers between candidate’s committees for multiple offices

In the same/overlapping election cycle(s)

A candidate’s authorized committee for one office (e.g., a Senate campaign) receiving a transfer from that 

candidate’s authorized committee for another office (e.g., a House campaign) for which the candidate is 

running in the same or overlapping12 election cycle(s) must report the total transfer on Line 12 of the Form 

3 Detailed Summary Page and must itemize the transfer on Schedule A, regardless of amount. 104.3(a)(4)

12 For example, a candidate initially ran for 2020 House but then suspended the campaign to run for 2022 Senate. In this case, the 

two-year 2020 House election cycle (November 7, 2018 through November 3, 2020) overlaps with the six-year 2022 Senate election 

cycle (November 9, 2016 through November 8, 2022).

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Memo Item

Doe for Congress Committee

Friends of Jane Doe

147 Felicity Circle

Fairfax VA 00000

3,000.00

3,000.00

05 15 2021

X

X

00000002

13–43: Transfers between candidate’s committees, same office
128

Chapter 13

(iii)(A). (See Chapter 9 for information on when such transfers are permissible.) In addition, as discussed 

in Chapter 9, the receiving committee must aggregate the contributions that make up the transfer with any 

other contributions it receives from the same contributor. 110.3(c)(5).

If the aggregate contributions from one contributor exceed $200 in the election cycle, the receiving 

committee must itemize the contributions as memo entries on a Schedule A. The recipient committee must 

also report the total transfer on Line 12 of the Form 3 Detailed Summary Page and must itemize the source 

of the transfer on Schedule A, regardless of amount. See AO 1984-38 (Oberstar).

The committee making the transfer must report the transfer on Line 18 of the Form 3 Detailed Summary 

Page and must itemize the disbursement on Schedule B, regardless of amount. 104.3(b)(4)(ii).

In different election cycles

When an individual seeks different offices in different election cycles, surplus funds from the earlier 

campaign that remain after the general election may be transferred to the later campaign without 

aggregating the contributions of the original contributor to the two committees. 110.3(c)(4).

Transfers of joint fundraising receipts

For information on reporting transfers of joint fundraising receipts, see Appendix C, “Joint Fundraising.”

27. Reporting Investments

A committee that has invested its funds—for example, in a savings account, money market fund or 

certificate of deposit—must include the total amount invested in its cash on hand (Line 27 of the Form 3 

Detailed Summary Page). Since investment money is not actually spent, it is considered a committee asset 

and should not be reported as a disbursement. See 104.3(a)(1).

Reporting additional depository

Funds invested with banks

If a committee invests the funds in a bank that was not previously identified as a campaign depository on 

the Statement of Organization, the committee must file an amended Statement of Organization disclosing 

the name and address of the new depository. The amendment must be filed within 10 days of making the 

investment. 102.2(a)(2).

Funds invested with other establishments

If committee funds are invested in a fund that is not operated by a bank (such as a money market fund 

operated by a brokerage firm), no amendment to the Statement of Organization is required. Before using 

the funds (principal or interest) to make expenditures, the committee must first transfer them to a 

designated campaign checking account. 103.3(a). See, for example, AO 1986-18 (Bevill).

Note, however, that interest or other income earned on these investment accounts need not be placed in 

the campaign depository account before they are reinvested. As noted previously, investments are not 

expenditures; they are simply a conversion of assets from one form to another. The committee must report 

the reinvested income from investments by following the rules explained in this section. AO 1997-06 

(Hutchison).

Bitcoin as an investment

In AO 2014-02 (Make Your Laws PAC), the Commission concluded that a committee can purchase bitcoins 

with funds from its campaign depository for investment purposes. The bitcoins do not need to be deposited 

in a campaign depository within 10 days of receipt. Bitcoins may be received into and held in a bitcoin 

wallet until the committee liquidates them.
129

Completing FEC Reports

Reporting investment income and loss

Report investment income received or lost during the reporting period in the “Other Receipts” category 

(Line 15) of the Detailed Summary Page. If investment income from one source aggregates over $200 

during an election cycle, itemize the interest on a Schedule A for Line 15. 104.3(a)(4)(vi). Losses are 

indicated by negative entries.

Reporting income tax

A committee must report, as an operating expenditure, income tax paid on investment income. Income 

tax payments must be itemized on a Schedule B for Line 17 (Operating Expenditures) only if the payments 

aggregate over $200 during an election cycle to the same payee (the local, state or federal government).

28. Completing the Report

As noted previously, paper filers 

should complete the itemization 

schedules first so that they may 

accurately complete the Summary 

Page and the Detailed Summary 

Page. After completing the 

schedules, transfer the totals, 

plus other relevant totals derived 

from the committee’s records, 

to the Detailed Summary Page. 

Calculations from the Detailed 

Summary Page and from Schedules 

C and D are then transferred to the 

Summary Page. Paper filers should 

refer to the next two sections for 

detailed information. Note that 

electronic filing software completes 

these tasks automatically.

29. The Detailed 

Summary Page

The Detailed Summary Page lists 

the totals for various categories 

of receipts and disbursements. 

Some of the figures are taken from 

the totals listed on the attached 

Schedules A and B, some are totals 

of figures that are not itemized 

on these schedules and some are 

combined totals of itemized figures 

from the schedules plus some 

unitemized figures. (See example of 

Detailed Summary Page 13-44 and 

13-45.)

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 M M / D D / Y Y Y Y M M / D D / Y Y Y Y

    , , .

    , , .

COLUMN B

Election Cycle-to-Date

COLUMN A

Total This Period

11. CONTRIBUTIONS (other than loans) FROM:

 (a) Individuals/Persons Other Than 

 Political Committees

 (i) Itemized (use Schedule A) ...........

 (ii) Unitemized ....................................

 (iii) TOTAL of contributions 

 from individuals .......................

 (b) Political Party Committees.................

 (c) Other Political Committees 

 (such as PACs) ...................................

 (d) The Candidate ....................................

 (e) TOTAL CONTRIBUTIONS 

 (other than loans) 

 (add Lines 11(a)(iii), (b), (c), and (d))..

12. TRANSFERS FROM OTHER 

 AUTHORIZED COMMITTEES ....................

13. LOANS:

 (a) Made or Guaranteed by the 

 Candidate............................................

 (b) All Other Loans...................................

 (c) TOTAL LOANS 

 (add Lines 13(a) and (b))....................

14. OFFSETS TO OPERATING 

 EXPENDITURES 

 (Refunds, Rebates, etc.) ............................

15. OTHER RECEIPTS 

 (Dividends, Interest, etc.) ...........................

16. TOTAL RECEIPTS (add Lines 

 11(e), 12, 13(c), 14, and 15) 

 (Carry Total to Line 24, page 4)............

DETAILED SUMMARY PAGE

of Receipts

I. RECEIPTS

FEC Form 3 (Revised 05/2016) Page 3





Report Covering the Period: From: To:

Write or Type Committee Name

Doe for Congress Committee

5,385.00

01 01 2022 03 31 2022

2,307.00

7,692.00

0.00

15,385.00

12,307.00

27,692.00

0.00

6,260.00

1,200.00

15,152.00

14,260.00

4,000.00

45,952.00

4,900.00

80,000.00

80,000.00

750.00

100,802.00

6,000.00

85,000.00

0.00

85,000.00

1,400.00

138,352.00

0.00 0.00

0.00

13–44: Detailed Summary Page
130

Chapter 13

Column A and Column B

Note that Column A is for the 

figures relating to amounts received 

and disbursed during the reporting 

period covered by the report. 

Column B lists totals for the election 

cycle to date.

Line 11. Contributions

Line 11(a). Contributions from 

individuals/persons other 

than political committees 

(i.e. individuals and other 

groups that are not political 

committees)

Use Line 11(a), to report 

contributions from individuals 

and groups other than political 

committees (such as partnerships, 

sole proprietorships and certain 

LLCs and Indian tribes).

• Enter the total of itemized 

contributions from individuals 

and other groups (not political 

committees) on Line 11(a)(i).

• On Line 11(a)(ii), enter the 

total amount of unitemized 

contributions.

• On Line 11(a)(iii), enter the 

total of itemized and unitemized 

contributions from individuals/

others.

Line 11(b). Contributions from political party committees

On Line 11(b), enter the total amount of contributions from party committees including any party 

organizations not registered with the FEC. As noted earlier in the chapter, these contributions must be 

itemized on a Schedule A for this line, regardless of amount. 104.3(a)(3)(iii).

Line 11(c). Contributions from other political committees

On Line 11(c), enter the total amount of contributions from other political committees (such as PACs or 

other candidates’ committees) and other such groups not registered with the FEC, which, as noted earlier in 

the chapter, must be itemized on a Schedule A for this line, regardless of amount. 104.3(a)(3)(iv).

Line 11(d). Contributions from candidate

On Line 11(d), enter the total contributions from the candidate. This includes any contributions from the 

candidate that were itemized on Schedule A for this line, as well as any contributions that did not have 

to be itemized. If the contribution is derived from an underlying loan to the candidate from a lending 

institution, or from an advance from the candidate’s brokerage account, credit card or line of credit, report 

the underlying loan on Schedule C-1.

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COLUMN B

Election Cycle-to-Date

COLUMN A

Total This Period

17. OPERATING EXPENDITURES.....................

18. TRANSFERS TO OTHER 

 AUTHORIZED COMMITTEES .....................

19. LOAN REPAYMENTS:

 (a) Of Loans Made or Guaranteed

 by the Candidate.................................

 (b) Of All Other Loans ..............................

 (c) TOTAL LOAN REPAYMENTS 

 (add Lines 19(a) and (b)).....................

20. REFUNDS OF CONTRIBUTIONS TO:

 (a) Individuals/Persons Other 

 Than Political Committees ..................

 (b) Political Party Committees..................

 (c) Other Political Committees 

 (such as PACs) ....................................

 (d) TOTAL CONTRIBUTION REFUNDS 

 (add Lines 20(a), (b), and (c))..............

21. OTHER DISBURSEMENTS .........................

22. TOTAL DISBURSEMENTS 

 (add Lines 17, 18, 19(c), 20(d), and 21)

II. DISBURSEMENTS

DETAILED SUMMARY PAGE

of Disbursements FEC Form 3 (Revised 05/2016) Page 4

III. CASH SUMMARY

23. CASH ON HAND AT BEGINNING OF REPORTING PERIOD...............................................

24 TOTAL RECEIPTS THIS PERIOD (from Line 16, page 3).....................................................

25. SUBTOTAL (add Line 23 and Line 24) ..................................................................................

26. TOTAL DISBURSEMENTS THIS PERIOD (from Line 22)......................................................

27. CASH ON HAND AT CLOSE OF REPORTING PERIOD 

 (subtract Line 26 from Line 25)..............................................................................................



 , , . , , .

6,010.00

0.00

14,054.00

0.00

5,271.18

5,271.18

6,271.18

0.00

6,271.18

5,000.00

2,000.00

100,802.00

106,169.31

10,000.00

10,000.00

4,000.00

18,281.18

87,888.13

18,281.18

5,000.00

5,367,31

0.00

0.00

0.00 0.00

0.00

34,325.18

13–45: Detailed Summary Page, continued
131

Completing FEC Reports

Line 12. Transfers from other authorized committees

On Line 12, enter the total amount of transfers from the candidate’s other authorized committees (if there 

are any such committees) which, as noted earlier in the chapter, must be itemized on a Schedule A for this 

line, regardless of amount.

Line 13. Loans

Line 13(a). Loans made or guaranteed by the candidate

On Line 13(a), enter the total amount of loans made or guaranteed by the candidate which, as noted earlier 

in the chapter, must be itemized on a Schedule A for this line, regardless of amount.

Line 13(b). All other loans

On Line 13(b), enter the total of all other loans (i.e., those not made or guaranteed by the candidate) the 

committee received during the reporting period which, as noted earlier in the chapter, must be itemized on 

a Schedule A for this line, regardless of amount.

Line 14. Offsets to operating expenditures

On Line 14, enter the total amount of offsets to operating expenditures (such as refunds or rebates) 

received during the reporting period. The figure might include unitemized offsets as well as itemized 

offsets, which, as noted earlier, are listed on a Schedule A for this line.

Line 15. Other receipts

On Line 15, enter the total amount of any other receipts—both itemized and unitemized—included for 

the reporting period. Note that the type of receipts included here may vary widely. Examples of receipts 

disclosed on Line 15 include dividends, certain sales of campaign assets, recount donations and refunds of 

contributions made by the committee to other committees or candidates. Remember that those receipts 

aggregating over $200 from any source during the election cycle must be itemized on a Schedule A for this 

line.

Line 17. Operating expenditures

On Line 17, enter the total amount of disbursements for operating expenditures—both itemized and 

unitemized—made during the reporting period. Remember that these disbursements must be itemized 

when they aggregate over $200 to any one source during the election cycle. Therefore, the amount entered 

on this line will not match the amount totaled on Schedule B for Line 17, which includes only itemized 

expenditures (unless the committee chooses to itemize expenditures that it is not required to itemize).

Line 18. Transfers to other authorized committees

On Line 18, enter the total amount of transfers made to the candidate’s other authorized committees (if any 

such committees exist). As noted earlier in the chapter, such transfers must be itemized on a Schedule B for 

this line, regardless of amount.

Line 19. Loan repayments

Line 19(a). Repayments on loans made or guaranteed by the candidate

On Line 19(a), enter the total of repayments of principal of loans made or guaranteed by the candidate. 

Such payments of principal must be itemized on a Schedule B for this line, regardless of amount. As noted 

earlier in the chapter, payments of interest are considered operating expenditures, not repayments on loans, 

and must be reported on Line 17 (see Section 22, “Reporting Loans”).
132

Chapter 13

Line 19(b). Repayments on all other loans

On Line 19(b), enter the total of repayments of principal of all loans not made or guaranteed by the 

candidate. Such payments of principal must be itemized on a Schedule B for this line, regardless of amount. 

As noted earlier in the chapter, payments of interest are considered operating expenditures, not repayments 

on loans, and must be reported on Line 17 (see Section 22, “Reporting Loans”).

Line 20. Refunds of contributions

Line 20(a). Refunds of contributions to individuals/persons other than political committees 

(i.e., individuals and other groups that are not political committees)

On Line 20(a), enter the total amount of contributions refunded to individuals or groups (other than 

political committees). Remember that contribution refunds need only be itemized (on a Schedule B) if 

the original contributions were itemized (on a Schedule A). (See Section 25, “Reporting Refunds, Returns, 

Bounced or Uncashed Checks and Disgorged Contributions.”)

Line 20(b). Refunds to political party committees

On Line 20(b), enter the total amount of contributions refunded to political party committees. Remember 

that, since these contributions must be itemized regardless of amount, the refunds will have to be itemized 

as well.

Line 20(c). Refunds to other political committees

On Line 20(c), enter the total amount of contributions refunded to other political committees (i.e., other 

than political party committees). Remember that, since these contributions must be itemized regardless of 

amount, the refunds will have to be itemized as well.

Line 21. Other disbursements

On Line 21 enter the total of all other disbursements—itemized and unitemized—made during the reporting 

period. This line may contain a wide array of disbursements, including contributions to other federal 

candidates, donations to charitable organizations, and recount-related disbursements. Remember that 

disbursements aggregating over $200 to the same payee during the election cycle must be itemized on a 

Schedule B for this line.

Line 23. Beginning cash on hand

A committee must report the cash on hand it possessed at both the beginning of the reporting period 

and the close of the reporting period. Note that the closing cash balance for the current reporting period 

appears on the next report as the beginning cash on hand. Cash on hand includes petty cash, funds held in 

checking and savings accounts, traveler’s checks, certificates of deposit, treasury bills and other investments 

valued at cost. 104.3(a)(1).

First report

Beginning cash on hand—i.e., money that the committee had in its possession at the time of registration—is 

subject to the contribution limits, prohibitions and disclosure requirements of federal law. (The committee 

must exclude any contributions that are not permissible under federal law.) If the beginning cash-on-hand 

balance is not $0, then the committee must itemize, as memo entries on Schedule A, contributions and 

other receipts included in the beginning cash-on-hand balance. (See Section 5 of this chapter, “When to 

Itemize Receipts.”)

Line 24. Total receipts this period

Enter the total receipts figure from Line 16 of the Detailed Summary Page.
133

Completing FEC Reports

Line 26. Total disbursements this period

Enter the amount of total disbursements from Line 22 of the Detailed Summary Page.

Line 27. Cash on hand at close of reporting period

Subtract the total disbursements for the period (Line 26) from the subtotal (entered on Line 25) of 

beginning cash on hand for the reporting period (Line 23) and the total receipts for the reporting period 

(Line 24) to derive the closing cash-on-hand balance. (In other words, (Beginning Cash on Hand + Total 

Receipts for Reporting Period) – (Total Disbursements for Reporting Period = Closing Cash on Hand.) Note 

that for the next report, this amount must be entered on Line 23 (Cash on Hand at Beginning of Reporting 

Period).

30. Post-Election Detailed Summary Page

In election years, the reporting period for the Post-General (or, in cases where the candidate was not a 

candidate in the general election, the Year-End) report will span two election cycles. For this report only, 

committees must not use the 

normal Detailed Summary Page; 

instead, they must use the PostElection Detailed Summary Page. 

This form divides the post-election 

reporting period into two time 

frames:

• From the beginning of the 

reporting period through the 

date of the election; and

• From the day after the election 

to the end of the reporting 

period. (See example 13–46.)

The campaign must divide its 

records into those two time periods 

in order to fill out the form. 

Campaigns that do not participate 

in the general election must file the 

Post-Election Detailed Summary 

Page with their election-year YearEnd report. Committees involved 

in a special general election must 

also file the Post-Election Detailed 

Summary Page with any special 

Post-General report required.

Electronic filers must file this form 

electronically, and thus must ensure 

that their filing software is able to 

generate this form, or use FECFile. 

Paper filers may download this form

from FEC.gov.

FE1AN044

COLUMN C

Total for

(date after general election)

through

(last day of reporting period)

POST-ELECTION DETAILED SUMMARY PAGE

Report of Receipts and Disbursements

I. RECEIPTS

FEC Form 3 (Revised 07/05) Page 5

Report Covering the Period: From: To:

Write or Type Committee Name

• If the candidate participated in the general election, use this form for the 30-day Post-General report.

• If the candidate did NOT participate in the general election, use this form for the Year-end report covering through December 31 of 

the election year (due on January 31).

This form is used in lieu of filling out Line Numbers 6 through 7 on Page 2 (Summary Page) and Pages 3 and 4 (the Detailed Summary Page) for the last report filed by a candidate during the current election cycle.

COLUMN A

Total this Period

	 ▲	 ▲	 ▲ , , . 	 ▲	 ▲	 ▲ , , .

	 ▲	 ▲	 ▲ , , .

11. CONTRIBUTIONS 

(other than loans) FROM:

(a) Individuals/Persons Other than 

 Political Committees

 (i) Itemized (use Schedule A)

 

 (ii) Unitemized

 (iii) Total of contributions from individuals

(b) Political Party Committees

(c) Other Political Committees

	 ▲	 ▲	 ▲ , , .

COLUMN B

Election Cycle Total as of

(date of general election)

	 ▲	 ▲	 ▲ , , . 	 ▲	 ▲	 ▲ , , . 	 ▲	 ▲	 ▲ , , .

	 ▲	 ▲	 ▲ , , . 	 ▲	 ▲	 ▲ , , . 	 ▲	 ▲	 ▲ , , .

M M / D D / Y Y Y Y M M / D D / Y Y Y Y

	 ▲	 ▲	 ▲ , , .

M M / D D / Y Y Y Y M M / D D / Y Y Y Y

M M / D D / Y Y Y Y

	 ▲	 ▲	 ▲ , , .

	 ▲	 ▲	 ▲ , , . 	 ▲	 ▲	 ▲ , , .

	 ▲	 ▲	 ▲ , , .

Doe for Congress Committee

10 18 2022 11 26 2022

10,385.00 108,680.00

12,005.00

4,600.00

2,500.00 275.00

5,050.00

16,000.00

12,885.00 4,875.00

0.00

120,685.00

65,000.00 1,000.00

50.00

11 08 2022 11 09 2022

11 26 2022

13–46: Post-Election Detailed Summary Page
134

Chapter 13

31. The Summary Page

After completing the Detailed Summary Page, totals from that page and from Schedules C and D are used 

to complete the Summary Page. See 

example 13–47 and 13–48.

Line 1. Name and address

Fill in the committee’s full name 

and mailing address. If the address 

has changed, be sure to check the 

appropriate box.

Line 2. ID number

Enter the committee’s FEC 

identification number on Line 2. 

If the committee is filing its first 

report, it may not yet have received 

an ID number; in that case the 

committee should leave this space 

blank.

A committee should include its ID 

number in all reports, statements, 

notices and other written 

communications with the FEC.

Line 3. Original or amended 

report

Check “amended” only when 

amending a report that has already 

been filed with the FEC; otherwise, 

check “new.”

Line 4. Type of report

Check the appropriate box and, if 

necessary, fill in the appropriate 

information (for 12-day preelection, 30-day post-election, 

special election reports and 

termination reports).

Line 5. Coverage dates

The period covered by the report begins on the day after the close of books of the last report filed by the 

committee. If the report is the first one filed by the committee, then the reporting period begins with the 

date of the committee’s first activity.

Line 6. Net contributions (other than loans)

On Line 6(a), enter the amount of total contributions other than loans from Line 11(e) of the Detailed 

Summary Page.

On Line 6(b), enter the amount of refunds from Line 20(d) of the Detailed Summary Page.

C

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

FEC 

FORM 3

1. NAME OF 

 COMMITTEE (in full)

ADDRESS (number and street)

 Check if different 

 than previously 

 reported. (ACC)

FEC FORM 3

(Revised 05/2016)

Office 

Use 

Only

NOTE: Submission of false, erroneous, or incomplete information may subject the person signing this Report to the penalties of 52 U.S.C. §30109. 

I certify that I have examined this Report and to the best of my knowledge and belief it is true, correct and complete.

Type or Print Name of Treasurer

Signature of Treasurer Date

4. TYPE OF REPORT (Choose One)

 (a) Quarterly Reports:

12-Day PRE-Election Report for the:

Primary (12P) General (12G) Runoff (12R)

Convention (12C) Special (12S)

30-Day POST-Election Report for the:

General (30G) Runoff (30R) Special (30S)

CITY STATE ZIP CODE

2. FEC IDENTIFICATION NUMBER

3. IS THIS NEW AMENDED

 REPORT (N) OR (A)

in the 

Election on State of



TYPE OR PRINT

REPORT OF RECEIPTS 

AND DISBURSEMENTS For An Authorized Committee

5. Covering Period through





in the 

Election on State of

STATE DISTRICT

 

Office Use Only



April 15 Quarterly Report (Q1)

July 15 Quarterly Report (Q2)

October 15 Quarterly Report (Q3)

January 31 Year-End Report (YE)

Termination Report (TER) 

(b) 

 Example: If typing, type 

over the lines.

(c) 

12FE4M5

Doe for Congress Committee

01 01 2022 03 31 2022

319 Main Street

Springfield

00033000

Gottlob Frege

Gottlob Frege 04 10 2022

X

X VA 12

VA 00000

13–47: Summary Page
135

Completing FEC Reports

Line 7. Net operating 

expenditures

On Line 7(a), enter the amount of 

total operating expenditures from 

Line 17 of the Detailed Summary 

Page.

On Line 7(b), enter the amount 

of total offsets to operating 

expenditures from Line 14 of the 

Detailed Summary Page.

Line 8. Cash on hand at close of 

reporting period

On Line 8, enter the amount of cash 

on hand at the close of the reporting 

period from Line 27 of the Detailed 

Summary Page.

Line 9. Debts owed to 

committee

On Line 9, transfer the total amount 

owed to the committee from the 

appropriate Schedule C and/or D.

Line 10. Debts owed by 

committee

On Line 10, transfer the total 

amount owed by the committee 

from the appropriate Schedule C 

and/or D.

Treasurer’s name and signature

The treasurer must sign and 

date Form 3 at the bottom of the 

Summary Page. Only a treasurer or assistant treasurer designated on Form 1 (Statement of Organization) 

may sign the report. 104.14(a). In the case of electronic filers, the treasurer’s password serves as the 

“signature.” See Chapters 2, 11 and 12 for more information on the treasurer’s responsibilities.

31. Filing Amendments

The committee must file an amended report if it:

• Discovers that an earlier report contained erroneous information; or

• Does not obtain all the required information about a particular itemized receipt or disbursement in 

time to include it in the appropriate report.

Paper filers

When filing an amended Form 3, the committee should complete the Summary Page (including the 

treasurer’s signature), indicating on Line 3 that the document is an amended report.

    , , .    , , .

    , , .    , , .

    , , .    , , .

    , , .    , , .

    , , .    , , .

    , , .    , , .

    , , .

    , , .

    , , .

 M M / D D / Y Y Y Y M M / D D / Y Y Y Y

COLUMN B

Election Cycle-to-Date

COLUMN A

This Period

6. Net Contributions (other than loans)

 (a) Total Contributions 

 (other than loans) (from Line 11(e)) ....

 (b) Total Contribution Refunds 

 (from Line 20(d)) ..................................

 (c) Net Contributions (other than loans) 

 (subtract Line 6(b) from Line 6(a)) ......

7. Net Operating Expenditures

 (a) Total Operating Expenditures 

 (from Line 17) ......................................

 (b) Total Offsets to Operating 

 Expenditures (from Line 14)................

 (c) Net Operating Expenditures 

 (subtract Line 7(b) from Line 7(a)) ......

8. Cash on Hand at Close of 

 Reporting Period (from Line 27).................

9. Debts and Obligations Owed TO

 the Committee (Itemize all on

 Schedule C and/or Schedule D) ................

10. Debts and Obligations Owed BY

 the Committee (Itemize all on

 Schedule C and/or Schedule D) ................

For further information contact:

Federal Election Commission

1050 First Street, N.E.

Washington, DC 20463

Toll Free 800-424-9530

Local 202-694-1100

FEC Form 3 (Revised 03/2016) Page 2

SUMMARY PAGE

of Receipts and Disbursements

Report Covering the Period: From: To:

Write or Type Committee Name

Doe for Congress Committee

5,000.00

01 01 2022 03 31 2022

10,152.00

0.00

45,952.00

10,000.00

35,952.00

0.00

6,010.00

15,152.00

14,054.50

6,010.00 14,054.50

87,888.13

79,678.82

0.00

13–48: Summary Page, continued
136

Chapter 13

In addition to the Summary Page (Pages 1 and 2 of Form 3), the committee should file a corrected version 

of the schedule that contained the incomplete or incorrect itemized information in the earlier report, along 

with a revised Detailed Summary Page (Pages 3 and 4 of Form 3), if appropriate. Transactions originally 

reported correctly do not need to be itemized again. The Commission recommends that the treasurer attach 

a cover letter explaining the change.

Electronic filers

Electronic filers must electronically resubmit the entire report, not just the amended portions. The 

committee must check the amendment box on the new report before filing. The amendments must be 

formatted to comply with the Electronic Filing Specifications Requirements mentioned in Chapter 12. 

104.18(f).

A Form 99 (Miscellaneous Electronic Submission) may be used for narrative responses that do not affect 

actual entries within a report, such as when outlining the committee’s procedures for making “best efforts” 

to obtain contributor information.
137

CHAPTER 14

Winding Down the Campaign

This chapter explains the requirements for an authorized committee that wishes to close down its 

operations at the end of a campaign.1

1. Terminating the Committee

Eligibility

A committee may file a termination report at any time, provided that:

• The committee no longer intends to receive contributions, make expenditures or make any 

disbursements that would otherwise qualify it as a political committee; and

• Neither the committee seeking to terminate nor any other authorized committee of the same candidate 

has any outstanding debts or obligations.

102.3 and 116.1. Campaigns with debts or obligations should see “Retiring Debts” and “Settling Debts.”

A committee involved in an FEC enforcement action, an FEC audit or litigation with the FEC, however, 

must continue to file regularly scheduled reports until the matter is resolved.

Termination report

When filing the committee’s termination report, the treasurer must check the “Termination Report” box on 

Line 4 of the Summary Page of Form 3. A termination report may be filed anytime and may be combined 

with a regularly scheduled report. (For example, a quarterly report may also serve as a termination report if 

the filer checks the “Termination Report” box.) The termination report must disclose:

• All receipts and disbursements not previously reported, including an accounting of debt retirement 

(See “Retiring Debts” and “Settling Debts”); and

• The purposes for which any remaining committee funds or assets will be used. (See Chapter 8, 

“Expenditures and Other Uses of Campaign Funds;” see also “Winding Down Costs” and “Sale of 

Campaign Assets.”) 102.3(a).

Committee no longer required to report once notified

The committee’s reporting obligation ends only when the Commission notifies the committee in writing 

that the termination report has been accepted. Until the committee receives this notification, it must 

continue to file reports.

Administrative termination

The FEC, upon its own initiative or at the request of a political committee, may administratively terminate 

a committee’s reporting status. For details on administrative termination, consult Section 102.4 of the 

regulations.

1 If a candidate wishes to use the committee for a subsequent federal campaign, he or she may redesignate it as an authorized 

committee using FEC Form 2. See Chapter 2, “Candidate and Committee Registration,” for more information.
138

Chapter 14

2. Conversion to Multicandidate Committee

In past advisory opinions, the Commission has permitted a principal campaign committee to become a 

multicandidate committee as an alternative to the committee’s termination. In meeting the requirements 

for multicandidate status, a former principal campaign committee may avail itself of the length of time of its 

prior registration, the number of contributions it has made in the past and the number of contributions it 

has received. Note that the prohibition on converting campaign funds to personal use still applies to such a 

committee. See AOs 2012-06 (RickPerry.org), 2004-03 (Dooley for the Valley), 1993-22 (Roe), and 1985-

30 (Holt) and the Campaign Guide for Nonconnected Committees for more information. Principal campaign 

committees of active candidates cannot qualify as multicandidate committees. 102.12(c) and 102.13(c).

To change the committee type, the committee must amend its Form 1 (Statement of Organization) to:

• Change the committee’s name. A PAC’s name must not include the candidate’s name.

• Update the committee type.

• Amend any other information that has changed.

After the conversion, the committee remains responsible for resolving any outstanding obligations, such as 

debts and unrefunded impermissible contributions. 

3. Winding Down Costs

Campaign funds may be used to pay ordinary and necessary expenses incurred in connection with one’s 

duties as a federal officeholder. Such expenses include the costs of winding down the office of a former 

federal officeholder for a period of six months after he or she leaves office. 113.2(a)(2).

Winding down costs include:

• Moving expenses. A retiring federal officeholder may use campaign funds to pay for the expenses of 

moving office and personal furnishings from the congressional office in Washington, DC back to the 

officeholder’s home state. While the costs of transporting an officeholder’s personal household effects 

and furnishings from Washington, DC to the officeholder’s home state are not “winding down costs,” 

such costs are “ordinary and necessary expenses” incurred in connection with ending his or her duties 

as a federal officeholder. AO 1996-14 (de la Garza). See also AO 1996-44 (Wilson). All such moving 

expenses should be reported as “other disbursements” by the officeholder’s committee, with specific 

payee(s) and purpose noted. 104.3(b)(2)(vi) and (b)(4)(vi).

• Payments to committee staff. See AOs 1976-90 (Randall) and 1978-43 (Jordan).

• Gifts. Campaign funds may be used to purchase gifts or make donations of nominal value to persons 

other than the members of the candidate’s family. 113.1(g)(4).

See also AO 2008-04 (Dodd for President).

Other permissible uses of excess campaign funds include:

• Donations to charitable organizations defined in 26 U.S.C. §170(c). 113.2(b);

• Unlimited transfers to any national, state or local political party committee. 113.2(c);

• Donations to state and local candidates, pursuant to state law. 113.2(d); and

• Any other lawful purpose, unless such use is personal use under 113.1(g). (See Chapter 8, Section 2, 

“Prohibited Uses of Campaign Funds.”) 113.2(e).
139

Winding Down the Campaign

4. Sale of Campaign Assets

Purchaser makes contribution

Generally, when a campaign sells its property, the purchase is considered a contribution to the campaign 

by the purchaser. The payment, therefore, must not come from prohibited sources and must not exceed the 

contribution limits.

Sale of campaign materials

The sale of fundraising items or materials developed uniquely for the committee (such as artwork, 

publications and opinion polls2) results in contributions from the purchasers. 100.53. See, for example, AOs 

1982-24 (Phillips) and 1980-19 (Young). (However, note the exception for mailing lists, in this section.)

Commercial ventures

The Commission has determined that when a committee asset is sold or used for an ongoing commercial 

venture to produce revenue for a committee, the proceeds are considered contributions to the committee. 

See AOs 1991-34 (West Virginia Republicans) and 1983-02 (Emery).

Purchaser does not make contribution

Under limited circumstances, however, the sale of a campaign asset does not result in a contribution.

Mailing lists

Mailing lists developed by a campaign for its own use may be sold or exchanged at the “usual and normal” 

charge without the purchaser making a contribution. See, for example, AOs 2002-14 (Libertarian National 

Committee), 1982-41 (Dellums) and 1981-53 (Frazier).

Liquidation of equipment and supplies

The Commission has said that the sale of campaign equipment and supplies does not result in a contribution 

under certain conditions. See AOs 2003-19 (DCCC) and 1986-14 (Burton).

5. Retiring Debts

Through contributions

When raising contributions to retire debts after the election is over, a campaign must remember three 

general rules:3

• The contributions are still subject to the limits and prohibitions of the Federal Election Campaign Act

(the Act), even if the candidate lost the election and does not plan to run for future federal office.

• Contributions made after an election to retire debts must, in most cases, be specifically designated for 

that election by the contributor. See “Designated and Undesignated Contributions,” Chapter 4, Section 

4.

• Contributions designated for, but made after, a particular election may not exceed the campaign’s net 

debts outstanding, as explained in Chapter 4.

110.1(b)(3)(i).4

2 For more information on opinion polls, see Commission regulations at 106.4.

3 A campaign may raise funds to retire debts through joint fundraising. See Appendix C.

4 The Commission has determined that a federal officeholder may solicit, receive and expend both federally permissible funds, as 

well as funds that do not comply with the Act, in order to retire existing debt incurred by a previous nonfederal campaign, so long as 

the fundraising is solely in connection with the nonfederal campaign, refers only to the candidate or to other candidates for that same 

nonfederal office and is permitted under state law. AOs 2016-25 (Pence), 2007-01 (McCaskill). See also AO 2009-06 (Risch).
140

Chapter 14

Through sale of assets

A campaign may sell its assets to raise funds to retire debts. Note that the sale or use of assets to retire debts 

may result in contributions from the purchasers, as explained in Section 4.

Through transfers

A campaign may receive funds to retire debts through transfers of excess funds from the same candidate’s 

federal campaign for a different election cycle, as long as the transferor committee has no outstanding 

debts. 116.2(c)(2). See Chapter 9, “Transfers.” See also AO 1997-10 (Hoke).

Salary owed to campaign staff

Unpaid salary or wages owed to campaign employees are not considered contributions from those 

employees. Uncompensated services rendered by an employee may be converted to volunteer work, or the 

amount owed may be treated as a debt. 116.6(a). Note, however, that FEC rules do not require an employee 

to accept less than full payment for his or her services. 116.6(b).

Treatment as volunteer service

Uncompensated employee service may be considered volunteer service if the employee signs a statement 

agreeing to the arrangement. 116.6(a). (Services performed by volunteers are exempt from limits and 

reporting requirements. See Chapter 7.)

Treatment as debt

Alternatively, the committee may treat the unpaid amount of salary as a debt to the employee (see Chapter 

13 for reporting information). The committee and the employee may settle the debt for less than the 

amount owed using the procedures described in the next section. 116.6(b).

6. Settling Debts

Eligibility for debt settlement

Only a terminating committee may settle a debt for less than the full amount owed to the creditor. A 

“terminating committee” is one that does not intend to raise contributions or make expenditures—except 

for the purposes of paying winding-down costs and retiring its debts. 116.1(a) and 116.2(a). An authorized 

committee may not settle any debts if any other authorized committee of the same candidate has enough 

permissible cash on hand to pay all or part of the debt. 116.2(c)(1).

Debts subject to settlement

The types of debts that are subject to debt settlement requirements include:

• Amounts owed to commercial vendors;

• Debts arising from advances by individuals (e.g., staff using personal funds or credit to purchase goods 

and services on behalf of the committee);

• Salary owed to committee employees; and

• Debts arising from loans from political committees or individuals, including candidates. 116.7(b).

The debt settlement rules do not apply to disputed debts, which are covered by other rules 116.7(c)(2).

They also do not apply to bank loans, though the Commission recognizes that under extraordinary 

circumstances, such as the death or bankruptcy of the candidate, settlement of bank loans may be 

appropriate. (The Commission will consider specific requests on a case-by-case basis.)
141

Winding Down the Campaign

Debt settlement rules

A commercial vendor (incorporated or unincorporated) may forgive or settle a debt owed by a committee 

without incurring a contribution if:

• Credit was initially extended in the vendor’s ordinary course of business, and the terms of the 

credit were similar to those observed by the vendor when extending a similar amount of credit to a 

nonpolitical client of similar risk (116.3 and 116.4(d)(1));

• The committee undertook all reasonable efforts to satisfy the outstanding debt, such as fundraising, 

reducing overhead costs and liquidating assets (116.4(d)(2)); and

• The vendor made the same efforts to collect the debt as those made to collect debts from a nonpolitical 

debtor in similar circumstances. Remedies might include, for example, late fee charges, referral to a 

debt collection agency or litigation. 116.4(d)(3). 

If the committee or the creditor fails to take these steps, the difference between the amount owed and 

the amount actually paid may be considered a contribution subject to limits and source prohibitions (i.e., 

prohibited if the vendor is incorporated). 114.2(b).

Debt settlement plans

After a terminating committee has reached agreements with its creditors, the treasurer must file a debt 

settlement plan on FEC Form 8. Once the plan has been submitted to the Commission for review, the 

committee must postpone payment on the debt until the Commission has completed the review. 116.7(a). 

Payments to creditors must be disclosed in the committee’s termination report.

Completing Form 8

Step-by-step instructions for completing Form 8 are included with the form. The Commission recommends 

that the committee include as many debts as possible in the plan and submit a separate Part II (second 

page) for each creditor along with Part I (cover page). The treasurer must also submit Part III (third page) 

to indicate how the committee intends to address other debts not included in the submission. The treasurer 

must sign and date the first page. The creditor must also sign the form to indicate his or her acceptance of 

the settlement. As an alternative, the treasurer may attach a signed statement from the creditor containing 

the same information.

Reporting debts undergoing settlement

Debts undergoing settlement must be continuously reported until the Commission has completed its review 

of the committee’s debt settlement plan. The committee may file a termination report once all debts have 

been paid, settled, forgiven or otherwise extinguished. 116.4(f), 116.5(e) and 116.6(c).

Disputed debts

A disputed debt is a bona fide disagreement between the creditor and the committee as to the existence of 

a debt or the amount owed by the committee. When filing a debt settlement plan, a terminating committee 

must describe any disputed debts and the committee’s efforts to resolve them on Part III of Form 8. 

116.10(b).

Creditor’s rights

No commercial vendor or other creditor is required to forgive or settle debts owed by committees. 116.4(e).

Assigning debts to another committee

To expedite termination, an authorized committee that qualifies as a terminating committee and has no 

remaining cash on hand may assign its debts to another authorized committee of the same candidate, 

provided that:
142

Chapter 14

• The committee transferring the debts was organized for an election that has already been held;

• Within 30 days before the assignment takes effect, the transferor committee notifies each creditor in 

writing of the name and address of the committee assuming the debts; and

• The committee assuming the debts notifies the FEC in writing that it has assumed the obligation to pay 

the debts. That committee must continue to report the debts until they are retired. 

116.2(c)(3).

The committee transferring the debts should report this to the FEC using memo text on the termination 

report or on a Form 99.

Forgiveness of candidate loans

The candidate may choose to forgive all or a part of a loan from his or her personal funds to the campaign. 

See 110.10; AOs 1985-10 (Cantrell), 1979-05 (Brathwaite). To report the loan forgiveness, the candidate 

must file a signed statement with the FEC indicating that he or she forgives the loan. The statement must be 

filed on paper with the candidate’s original signature, even for committees that file reports electronically. 

The report for the period during which a loan was forgiven should disclose the adjusted outstanding 

balance on Schedule C with a memo entry text referencing the statement.

Forgiveness of debts owed by ongoing committees

Forgiveness rules

A creditor may forgive a debt owed by an ongoing committee (that is, one that does not qualify as a 

terminating committee) if the debt has been outstanding at least 24 months and:

• The ongoing committee (1) has insufficient cash on hand to pay the debt, (2) has had receipts of less 

than $1,000 and disbursements of less than $1,000 during the previous 24 months and (3) owes debts 

to other creditors of such magnitude that the creditor could reasonably conclude that the ongoing 

committee will not pay its particular debt; or

• The creditor is unable, after reasonable diligence, to locate the ongoing committee.

116.8(a).

Notification to Commission

A creditor who intends to forgive a debt owed by an ongoing committee must notify the Commission of its 

intent in writing. The letter must provide the following information:

• The terms of the initial extension of credit and a description of the terms under which the creditor has 

extended credit to similar nonpolitical debtors;

• A description of the campaign’s efforts to satisfy the debt; 

• A description of the steps taken by the creditor to obtain payment, along with a comparison of those 

remedies with others pursued by the creditor under similar circumstances; and

• An indication that the creditor has forgiven other debts involving nonpolitical debtors in similar 

circumstances.

116.8(b).

Commission review

The Commission will review each proposal to forgive a debt to ensure that the creditor, the ongoing 

committee and the candidate have complied with the Act’s contribution limits and prohibitions. 116.8(c).
143

Appendix A

Earmarked Contributions

An earmarked contribution is one which the contributor directs (either orally or in writing) to a clearly 

identified candidate or the candidate’s authorized committee through an intermediary or conduit. 

Earmarking may take the form of a designation, instruction or encumbrance and may be direct or indirect, 

express or implied, written or oral. 110.6(b)(1). Earmarked contributions require additional disclosure, as 

summarized in this chapter.

In addition, under the provisions of the Honest Leadership and Open Government Act of 2007 (HLOGA), 

Pub. Law No. 110-81, 121 Stat. 735, signed into law September 14, 2007, certain “bundled” contributions 

may trigger additional disclosure of the identity of the person who raised the bundled contribution as 

summarized in Section 6 of this appendix. See also Appendix F, “Lobbyist Bundled Contributions,” for 

further information.

1. Earmarked Contributions

Conduit/intermediary

Anyone who receives and forwards an earmarked contribution to a candidate or candidate’s authorized 

committee is considered a conduit or intermediary. 110.6(b)(2). (The terms “conduit” and “intermediary” 

are interchangeable; “conduit” will be used in the remainder of this appendix.) Individuals, political 

committees, unregistered committees and partnerships may act as conduits for earmarked contributions.

Persons not considered conduits

For the purposes of the earmarking rules, certain individuals and organizations are not considered conduits 

even though they may participate in activities to raise money for a candidate. These persons include:

• An employee or full-time volunteer working for a candidate committee;

• An individual who occupies a significant position in a candidate’s campaign and who is expressly 

authorized to raise money on behalf of the candidate;

• A committee affiliated with the candidate committee; and

• A commercial fundraising firm retained by the candidate committee. 110.6(b)(2)(i).

Prohibitions apply

No corporation, labor organization or other entity prohibited from making contributions in connection 

with federal elections may act as a conduit for an earmarked contribution. A nonconnected committee or a 

separate segregated fund (SSF), however, may act as a conduit. 110.6(b)(2)(ii) and 114.2(f)(3)(ii).

Furthermore, no individual may receive a contribution on behalf of a candidate (as a conduit or otherwise) 

while acting as the representative of a corporation, labor organization or other entity prohibited from 

making contributions. 110.6(b)(2)(i)(A) and (E) and 114.2(f).

2. Effect on Contribution Limits

Contributor’s limit

An earmarked contribution counts against the contributor’s contribution limit for the recipient candidate. 

110.6(a).
144

Appendix A

Conduit’s limit

Direction or control

The conduit’s limit is affected when the conduit exercises direction or control over the contributor’s 

choice of recipient candidate (see “Contributions Earmarked through SSF”). In that case, the full amount 

of the contribution counts against the limits of both the original contributor and the conduit, even though 

the candidate receives only one check. 110.6(d). For examples of how the Commission has viewed the 

“direction or control” rule in specific situations, see AOs 2019-11 (Pro-Life Democratic Candidate PAC), 

2019-01 (It Starts Today), 2014-13 (Act Blue), 2003-23 (WE LEAD), 1986-04 (Armstrong Industries) and, 

1981-57 (Coal Miners PAC).

Effect on unregistered organization

An unregistered organization acting as a conduit should be aware that conduit activity could result in a 

contribution by the organization, under the circumstances previously described. In such a case, the activity 

may trigger registration requirements for the unregistered organization.

Contributions earmarked through SSF

Unsolicited

As discussed in Section 1, a corporation or labor organization may never act as a conduit for earmarked 

contributions. A corporation or labor organization’s SSF, however, may collect and forward earmarked 

contributions. An unsolicited earmarked contribution, transmitted to a candidate through the SSF, counts 

against the original contributor’s contribution limits, but it does not count against the limits on the SSF’s 

own contributions to the candidate. 110.6(d)(1).

Solicited

If, however, the earmarked contribution was solicited from the restricted class by a communication from 

the SSF’s connected organization, under 114.3, and was collected by the SSF, it is considered a contribution 

to both the SSF and the candidate, and from both the individual contributor and the SSF. As such, the 

earmarked contribution counts against several contribution limits. Note that, under these circumstances, 

the contribution automatically counts against the SSF’s contribution limits regardless of whether the SSF 

exercised direction or control over the choice of recipient. 114.2(f)(2)(iii) and (f)(4)(iii).

3. Forwarding Earmarked Contributions

10-day limit

The conduit must forward an earmarked contribution, along with a report (see next section) to the 

recipient candidate committee within 10 days of receiving the contribution. 102.8(a) and (c) and 110.6(c)

(1)(iii).

4. Transmittal to Campaign

Along with the funds, the conduit must forward to the recipient candidate committee a transmittal report 

containing information that the candidate’s campaign committee will need for its own records and reports. 

110.6(c)(1).

Contributions exceeding $50

When an earmarked contribution exceeds $50, the accompanying transmittal report must contain the name 

and mailing address of the original contributor, the date the contribution was received by the conduit and 

the amount. 102.8(a) and 110.6(c)(1)(iv)(A). The report should also state the election designated by the 

contributor, if any. 110.1(b)(2)(i).
145

Earmarked Contributions

Contributions exceeding $200

When an earmarked contribution exceeds $200, the accompanying report must contain the name and 

mailing address of the contributor, the contributor’s occupation and name of employer, the date the 

contribution was received by the conduit and the amount. 102.8(a) and 110.6(c)(1)(iv). The report should 

also state the election designated by the contributor, if any. 110.1(b)(2)(i).

5. Reporting Earmarked Contributions

An earmarked contribution must be reported by both the conduit (political committee or unregistered 

entity) and the recipient authorized committee. The conduit must comply with special reporting rules, 

which vary depending on whether the contribution was deposited in the conduit’s bank account or was 

passed on directly to the campaign in the form of the original contributor’s check. 110.6(c)(1)(v).

Reports by political committee conduit

A political committee that serves as a conduit of an earmarked contribution must disclose the earmarked 

contribution, regardless of amount, on two separate reports: the committee’s next regularly scheduled 

FEC report, and a special transmittal report (mentioned in Section 4) sent to the recipient authorized 

committee. 110.6(c)(1).

Next regular FEC report

The conduit’s next regularly scheduled report must indicate whether the earmarked contribution was:

• Transmitted through the conduit’s account, in which case each contribution must be reported on the 

reporting schedules for itemized receipts and disbursements (Schedules A and B); or

• Transmitted in the form of the original contributor’s check, in which case each earmarked contribution 

must be reported as a memo entry on Schedules A and B.

110.6(c)(1)(iv) and (v). For more information, see Appendix D of the Campaign Guide for Nonconnected 

Committees and Appendix E of the Campaign Guide for Corporations and Labor Organizations.

Reports by unregistered conduit

A conduit that is not a registered political committee (that is, the conduit is an individual, a partnership or a 

group) must, within 30 days of forwarding the contribution, file a report by letter with the Federal Election 

Commission and must, when the contribution is forwarded, file a transmittal report by letter with the 

recipient authorized committee. 52 U.S.C. 30102(g); 110.6(c)(1)(ii).

Contents of reports by conduit

The reports filed by a conduit must contain the following information:

• The name and mailing address of the original contributor and, if the contribution is from an individual 

and exceeds $200, the contributor’s occupation and employer;

• The amount of the earmarked contribution;

• The date the contribution was received by the conduit;

• The recipient of the contribution, as designated by the contributor;

• The date the contribution was forwarded to the recipient; and

• Whether the contribution was passed on in cash, by the contributor’s check or by the conduit’s check. 

Note that if the conduit is an individual, he or she may deposit earmarked contributions into a personal 

bank account. See 110.6(c)(1)(iv). However, contributions may not be commingled with the personal 

funds of any individual. 102.15.
146

Appendix A

Report by recipient committee

The recipient of an earmarked contribution also has an obligation to itemize earmarked contributions if 

the earmarked contributions received from a single conduit exceed $200 in an election cycle. (Earmarked 

contributions not requiring itemization should be included in the Line 11(a)(ii) total.) If earmarked 

contributions require itemization on Schedule A, the authorized committee must:

• Identify the conduit by name 

and address (and occupation 

and employer if the conduit is 

an individual);

• Report the date of receipt and 

total amount of earmarked 

contributions received from 

that conduit; and

• Itemize the original 

contributions from each 

individual whose total 

contributions to the committee 

aggregate over $200 per election 

cycle (including the full name, 

mailing address, occupation and 

employer of the contributor, 

the amount earmarked and the 

date the conduit received the 

contribution). 110.6(c)(2). (See 

example A–1.) If appropriate, 

the campaign must report 

whether the conduit’s limit was 

affected. See 110.6(d)(2).

Contributions of $1,000 or more earmarked through a conduit and received by a campaign committee 

less than 20 days but more than 48 hours prior to an election in which the candidate is running must be 

reported on 48-Hour Notices. (See Chapter 12 for information on reporting last minute contributions.)

6. Contributions Bundled by Lobbyists/Registrants and Lobbyist/

Registrant PACs

Under the provisions of HLOGA, additional disclosure is required for certain “bundled contributions.” 

Bundled contributions include contributions collected and forwarded by a lobbyist/registrant or lobbyist/

registrant PAC either physically or electronically, as well as contributions for which the lobbyist/registrant 

or lobbyist/registrant PAC receives credit from the recipient authorized committee, through record, 

designation or other form of recognition. See Appendix F, “Lobbyist Bundled Contributions” for further 

information.

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

A.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

Full Name (Last, First, Middle Initial)

Mailing Address

City State Zip Code

Receipt For: 

Primary General

Other (specify)

B.

Election Cycle-to-Date

Date of Receipt

Name of Employer Occupation

, , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

12 13a 13b 14 15

M M / D D / Y Y Y Y

M M / D D / Y Y Y Y

Amount of Each Receipt this Period

, , .

Amount of Each Receipt this Period

, , .

Memo Item

Memo Item

Doe for Congress Committee

Akoma, Claude

5739 Totem St.

Alexandria VA 00000

1,000.00

1,000.00

03 13 2021

X

X

Earmarked through

AnthroPAC

Anthropologists Association PAC (AnthroPAC)

2321 Origin St.

Alexandria VA 00000

1,150.00

1,150.00

03 15 2021

X total earmarked through

conduit. PAC limit not affected.

X

Alexandria University Anthropologist

00000002

A–1: Earmarked contribution
147

Appendix B

Contributions from Partnerships

There are special rules concerning contributions received from partnerships and from limited liability 

companies taxed as partnerships.1

1. Contribution Limits

Contributions made by partnerships

Contributions received by a candidate’s authorized committees from a partnership may not exceed $2,900 

per election. In addition, a contribution from a partnership also counts proportionately against each 

participating partner’s own limit with respect to the same candidate. 110.1(b)(1) and (e).

Contributions made by individual partners

Each individual partner may make contributions of $2,900 per election, per candidate. 110.1(b)(1). 

Although contributions made by the partnership as a whole count proportionately against each participating 

partner’s $2,900 limit, contributions made by individual partners from their own funds do not count against 

the partnership’s limit. 110.1(e). See “Attribution among Partners.”

Note, however, that certain partnerships and partners may be prohibited from contributing. See “Prohibited 

Partnership Contributions.”

Limited liability companies

In some cases, limited liability companies (LLCs) are treated as partnerships. For the purposes of 

contribution limitations and prohibitions, an LLC is treated as a partnership if:

• It does not have publicly traded shares, and

• It has chosen to file, under IRS rules, as a partnership; or

• It has made no choice, under IRS rules, as to whether it is a corporation or a partnership. 110.1(g)(2) 

and (3).

Under these conditions, an LLC may make contributions to candidates, subject to the rules described in this 

appendix. See also Chapter 4, Section 1.

2. Attribution among Partners

Formula

A portion of the partnership contribution must be attributed to each contributing partner.2 If all partners 

within the organization are contributing, the partnership may attribute the contribution according to each 

partner’s share of the firm’s profits.

However, if the partnership attributes a contribution on another basis agreed to by the partners, the 

following rules must be observed:

1 For information on contributions from limited liability companies, see Chapter 4, Section 1.

2 A portion of a contribution drawn on a partnership account may not be attributed to the spouse of a partner unless the spouse is also 

a member of the partnership. AO 1980-67 (Long).
148

Appendix B

• The profits of only the partners to whom the contribution is attributed are reduced (or their losses 

increased); and

• The profits (or losses) of those partners are reduced (or losses increased) in the amount of the 

contribution attributed to them.

The portion attributed to each partner must not, when aggregated with other contributions from that 

person, exceed his or her individual contribution limit. 110.1(e). See also “Partnerships or LLCs with 

corporate partners or members” in the next section and AO 2009-02 (True Patriot Network, LLC) regarding 

independent expenditures by single member LLCs.

Notice to recipient committee

Because a contribution from a partnership is a joint contribution, the partnership must provide to the 

recipient committee, along with the contribution, a written notice listing the names of the contributing 

partners and the amount to be attributed to each. However, unlike other joint contributions, the signature 

of each contributing partner is not required. 110.1(k)(1).

3. Prohibited Partnership Contributions

Professional corporations

Although law firms, doctors’ practices and similar businesses are often organized as partnerships, some of 

these businesses may instead be professional corporations. Unlike a partnership, a professional corporation 

is prohibited from making any contributions because contributions from corporations to campaign 

committees are unlawful. 114.2.

Partnerships or LLCs with corporate partners or members

Because corporations are prohibited from contributing to a campaign committee, a partnership or LLC with 

corporate partners or members may not attribute any portion of a contribution to the corporate partners or 

members. 110.1(e) and 114.2(b). See also Chapter 4, Section 1.

A partnership or LLC composed solely of corporate partners or members may not make any contributions. 

AOs 2001-07 (NMC PAC) and 1981-56 (Satellite Business Systems); see also AOs 2009-14 (Mercedes-Benz 

USA / Sterling), 2003-28 (Horizon Lines), 2001-18 (BellSouth) and 1992-17 (DuPont Merck) for a limited 

exception pertaining to exempt costs for an affiliated corporate partner’s SSF.

Partnerships or LLCs with foreign national members

Similarly, because contributions from foreign nationals are prohibited, a partnership or LLC may not 

attribute any portion of a contribution to a partner who is a foreign national. 110.20. See Chapter 5, Section 

1 for further information on the foreign national prohibition.

Partnerships or LLCs with federal government contracts

A partnership or LLC that is negotiating a contract with the federal government or that has not completed 

performance of such a contract is prohibited from making contributions. However, an individual partner 

in such a firm may make contributions from personal funds (rather than from funds drawn on the 

partnership’s account). 115.4. See also AOs 2005-20 (Pillsbury Winthrop Shaw Pittman), 1991-01 (Deloitte 

& Touche PAC) and Chapter 5, Section 1.

Also, an individual who is, in his or her own right or as a sole proprietor, a federal government contractor or 

negotiating a contract with the federal government may not make contributions using any funds (business 

or personal) under his or her control. 115.5. Note that the spouse of such an individual is not prohibited 
149

Contributions From Partnerships

from making a personal contribution in his or her own name (as long as he or she is not otherwise 

prohibited from making contributions in connection with a federal election). 

4. Reporting Partnership / LLC Contributions

Included in total figure

Partnership or LLC contributions 

are included in the total figure 

reported for “Contributions from 

Individuals/Persons Other Than 

Political Committees” on the 

Detailed Summary Page of Form 3 

(Line 11a).

Itemization

If a contribution from a partnership 

or LLC exceeds $200 or aggregates 

over $200 during an election 

cycle, the committee must itemize 

the contribution on a Schedule 

A used for “Contributions from 

Individuals/Persons Other Than 

Political Committees” (Line 11(a)).

Additionally, if an individual 

partner’s share of the contribution 

exceeds $200 when combined 

with other contributions received 

from that partner in the same 

election cycle, the committee 

must disclose, as a memo entry, 

itemized information on the partner 

(name, address, occupation, date 

contribution received, partner’s 

share of contribution and aggregate 

cycle-to-date total of contributions 

made by that partner). 104.8 and 

110.1(e). (See example B–1.)

In-kind contributions

A committee reports the value of an in-kind contribution from a partnership or LLC in the same way it 

reports a monetary contribution. In addition, as with all in-kind contributions, the committee must report 

the value of the in-kind contribution as an operating expenditure. Moreover, an in-kind contribution 

itemized on Schedule A must also be itemized on a Schedule B for operating expenditures. 104.13 and 

110.1(e). However, any information about a partner itemized as a memo entry on Schedule A does not have 

to be reported on Schedule B.

More information on partnership contributions

For more information on partnership-sponsored PACs and partnership contribution plans, see the 

Campaign Guide for Nonconnected Committees.

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

    , , .

SUBTOTAL of Receipts This Page (optional) ............................................................................    , , .

TOTAL This Period (last page this line number only) ...............................................................  

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

Receipt For: 

 Primary General

 Other (specify)

A.

Election Cycle-to-Date 

Date of Receipt

Name of Employer Occupation

    , , .

FEC ID number of contributing

federal political committee. C

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

Receipt For: 

 Primary General

 Other (specify)

B.

Election Cycle-to-Date 

Date of Receipt

Name of Employer Occupation

    , , .

FEC ID number of contributing

federal political committee. C

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

Receipt For: 

 Primary General

 Other (specify)

C.

Election Cycle-to-Date 

Date of Receipt

Name of Employer Occupation

    , , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

 12 13a 13b 14 15

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

Amount of Each Receipt this Period

    , , .

Amount of Each Receipt this Period

    , , .

Amount of Each Receipt this Period

    , , .

FEC Schedule A (Form 3) (Revised 05/2016)

Memo Item

Memo Item

Memo Item

Doe for Congress Committee

Locke & Rousseau

101 Modernity Ave.

Fairfax VA 00000

1,000.00

1,000.00

03 04 2021

X

X

see attribution below

Locke, John

180 Prosperity Street

Luckets VA 00000

1,150.00

500.00

03 04 2021

X partnership attribution

X

Partnership

Rousseau, Jean Jacques

101 General Will Rd.

Front Royal VA 00000

500.00

500.00

03 04 2021

X partnership attribution

X

Locke & Rousseau

Locke & Rousseau

Accountant

Accountant

B–1: Partnership contributions
150

Appendix B
151

Appendix C

Joint Fundraising

1. Introduction

What is joint fundraising

Joint fundraising is election-related fundraising conducted jointly by a political committee and one or more 

other political committees or unregistered organizations.

Who must observe joint fundraising rules

The rules described in this appendix apply to political committees and unregistered organizations engaged 

in joint fundraising.

Note that nothing in the joint fundraising rules supersedes the fundraising restrictions of 11 CFR Part 300. 

Participants in joint fundraisers should consult those regulations in addition to the following provisions. See 

Appendix E, “Fundraising by Federal Candidates and Officeholders.”

The participants in joint fundraising activity may include:

• Party committees;

• Party organizations not registered as political committees;

• Federal and nonfederal candidate committees;

• Nonparty political committees (except separate segregated funds—SSFs); and

• Unregistered nonparty organizations. 102.17(a)(1)(i) and (2).

The rules described in this appendix do not apply to fundraising by collecting agents and separate 

segregated funds. 102.17(a)(3). Such organizations may only jointly raise funds with another affiliated 

organization. For more information, see Chapter 3, Section 15 of the Campaign Guide for Corporations and 

Labor Organizations.

Overview of rules

All participants in a joint fundraising effort, including unregistered organizations, must:

• Create or select a federal political committee to act as the joint fundraising representative;

• Agree to a formula for allocating proceeds and expenses;

• Sign a written agreement naming the joint fundraising representative and stating the allocation formula;

• Establish a separate account for joint fundraising receipts and disbursements;

• Notify the public of the allocation formula and certain other information (detailed in the next section) 

when soliciting contributions;

• Screen contributions to make sure they comply with the limits and prohibitions of the Federal Election 

Campaign Act (the Act); and

• Report allocated proceeds and expenses (applies to political committees only). 102.17.

The committee named as the fundraising representative has additional responsibilities, as explained in the 

next section.
152

Appendix C

2. Fundraising Representative

Joint fundraising participants must either establish a new political committee (using a Statement of 

Organization (FEC Form 1)) or select a participating political committee to act as the joint fundraising 

representative.1 102.17(a)(1)(i); see also AO 2007-24 (Burkee/Walz). This committee is responsible for 

collecting and depositing joint fundraising contributions; paying expenses; allocating proceeds and expenses 

to each participant; keeping records; and reporting overall joint fundraising activity. 102.17(b)(1)-(2), (c)(4), 

(c)(6), (c)(8).

A new political committee established for the joint fundraiser must register with the FEC using a Statement 

of Organization, and must include the name of each participating federal candidate in the new committee’s 

name. 52 U.S.C. §30102(e)(4). (An existing committee would be required to amend its Statement of 

Organization.) Thus, for example, a joint fundraising committee established to raise funds for a candidate 

and a party could not be called “Victory ’14,” but might be called the “John Doe Victory ’14” committee. 

Any federal candidate participating in the fundraiser must designate the fundraising representative as an 

authorized committee (by amending the Statement of Candidacy, (FEC Form 2)). 102.13(a), 102.17(a)(1)(i), 

(b)(1) and (b)(2); AO 2007-24 (Burkee/Walz).

Joint fundraising representative

If a new committee is established, it collects all the contributions. 102.17(b)(1). Note that such a committee 

may not itself be a participant in any other joint fundraising effort, though it may conduct more than one 

event or activity on behalf of its own participants. 102.17(a)(1)(i). Alternatively, if a committee participating 

in the fundraiser serves as the joint fundraising representative, it and any other participating committees 

may collect contributions; however, all contributions received by the other participants must be forwarded 

to the joint fundraising representative within 10 days of receipt. 102.17(b)(2). Under either option, the joint 

fundraising procedures explained in this chapter will apply.

Use of commercial firm

Although participants may hire a commercial fundraising firm or other type of agent to assist with organizing 

and holding the joint fundraiser, they are still required to establish or select a new political committee to 

serve as the fundraising representative. 102.17(a)(1)(ii).

3. Written Agreement

Before conducting a joint fundraiser, all participants must enter into a written agreement that identifies 

the joint fundraising representative and states the allocation formula—the amount or percentage that the 

participants agree to use for allocating proceeds and expenses. The joint fundraising representative must 

retain a copy of the written agreement for three years and make it available to the FEC upon request. 

102.17(c)(1).

4. Separate Depository

Establishing the account

The joint fundraising participants or the joint fundraising representative must establish a separate account 

solely for the receipt and disbursement of all joint fundraising proceeds. Each participating political 

committee must amend its Statement of Organization (FEC Form 1) to show the account as an additional 

depository.2 102.17(c)(3)(i).

1 It is strongly recommended that participants establish a new political committee for ease of compliance with the law.

2 Note that when paper filers amend the Statement of Organization (FEC Form 1), only the committee’s name, address and the new or 

changed information need be included.
153

Joint Fundraising

Depositing contributions

The joint fundraising representative 

must deposit contributions into 

the account within 10 days after 

receiving them. Only contributions 

permissible under the Act may be 

deposited in the joint fundraising 

account. If any participant is an 

unregistered organization which 

may, under state law, accept 

prohibited contributions, the 

participants may either establish 

a second account for such 

contributions or forward them 

directly to the participants that may 

accept them. 102.17(c)(3)(i) and 

(ii).

5. Statements of 

Organization

Joint fundraising 

representatives

As noted in the previous section, 

the joint fundraising committee 

must file a Statement of 

Organization (FEC Form 1). The 

Statement of Organization must:

• Identify the committee as the 

joint fundraising representative;

• List the names and addresses 

of all federal committees 

participating in the joint 

fundraising effort; and

• Name the depository institution 

being used by the joint 

fundraising committee. 102.2. 

(See examples C–1 and C–2.)

Other joint fundraising 

participants

Each participant in the joint 

fundraiser (other than the joint 

fundraising representative) 

must amend its Statement of 

Organization to provide the name 

and address of the joint fundraising 

Joint Fundraising Representative:

(g) This committee collects contributions, pays fundraising expenses and disburses net proceeds for two or more political 

 committees/organizations, at least one of which is an authorized committee of a federal candidate.

 Committees Participating in Joint Fundraiser

1.

2.

3.

4.

(h) This committee collects contributions, pays fundraising expenses and disburses net proceeds for two or more political 

 committees/organizations, none of which is an authorized committee of a federal candidate.

FEC ID number C

FEC ID number C

FEC ID number C

FEC ID number C

Doe for Congress Committee 00033000

Johnson for Congress Committee 00044000

X

C–1: Form 1 filed by joint fundraising representative

FEC Form 1 (Revised 02/2009) Page 3

Write or Type Committee Name

8. Treasurer: List the name and address (phone number -- optional) of the treasurer of the committee; and the name and address of

any designated agent (e.g., assistant treasurer).

CITY STATE ZIP CODE

Full Name

of Treasurer

Mailing Address

Title or Position

Telephone number

6. Name of Any Connected Organization, Affiliated Committee, Joint Fundraising Representative, or Leadership PAC Sponsor

 

Mailing Address

Relationship: Connected Organization Affiliated Committee Joint Fundraising Representative 

CITY STATE ZIP CODE

Custodian of Records: Identify by name, address (phone number -- optional) and position of the person in possession of committee

books and records.

CITY STATE ZIP CODE

Full Name

Mailing Address

Title or Position

Telephone number

7.

 Leadership PAC Sponsor

Doe for Congress

Doe / Johnson Golf Outing 2022

201 King Street

Alexandria

Herman Lotze

319 Main St.

Springfield

Bookkeeper

Gottlob Frege

319 Main St.

Springfield

Treasurer

00000

00000

00000

703 555 0000

VA

VA

VA

703 555 0000

X

C–2: Form 1 filed by principal campaign committee showing affiliation
154

Appendix C

representative—identified as the “JFR”—and to state the name and address of the depository institution 

holding the joint fundraising account, if it differs from the depository named on its current Statement of 

Organization. In addition, each federal candidate participating in the fundraiser must amend FEC Form 

2 (Statement of Candidacy) to designate the joint fundraising representative as an authorized candidate 

committee. 102.2(a)(2), 102.17(a)(1)(i), (b)(1), (b)(2) and (c)(3).

6. Start-Up Costs

Participants may advance funds to the joint fundraising representative for start-up costs of the fundraiser. 

(Note, however, that individuals may not advance such costs or pay for expenses out of pocket to be 

reimbursed later. See AO 2007-24 (Burkee/Walz).) The amount advanced by a participant should be 

in proportion to the agreed upon allocation formula. Any amount advanced in excess of a participant’s 

proportionate share is considered a contribution and must not exceed the amount the participant may 

contribute to the other participants. 102.17(b)(3)(i) and (ii). (However, an exception is made for funds 

transferred between party committees under 102.6(a)(1)(ii) and 110.3(c)(1). See also Section 14.)

Example: Committees A, B and C determine they need $2,000 in start-up costs. According to their 

allocation formula (Committees A and B, 25 percent each; Committee C, 50 percent), Committees A 

and B each advance $500 to the joint fundraising representative, and Committee C, $1,000. If, however, 

Committee C advances the entire $2,000, it has made a $500 contribution to each of the other committees.

Unregistered organizations

An unregistered organization (such as a party organization that has not yet qualified as a political 

committee) must use permissible funds when advancing money for start-up costs. 102.17(c)(3)(i). If an 

unregistered participant advances more than its share of start-up costs and thus makes a contribution, the 

contributed amount may trigger registration and reporting requirements under the Act. 100.5.

7. Joint Fundraising Notice

General rule

In addition to any fundraising or disclaimer notices required (see Chapter 10, Sections 1 and 2; see also, 

AO 2013-13 (Freshman Hold’em JFC)), a joint fundraising notice must appear with every solicitation for 

contributions. The notice must contain the following information:

• The names of all participants, regardless of whether they are registered political committees or 

unregistered organizations;

• The allocation formula (the amount or percentage of each contribution that will be allocated to each 

participant);

• A statement informing contributors that they may designate contributions for a particular participant 

(notwithstanding the formula); and

• A statement that the allocation formula may change if any contributor makes a contribution which 

would exceed the amount he or she may lawfully give to any participant.

102.17(c)(2)(i).

Special situations

In two situations, participants must include additional information in the joint fundraising notice:

• If a participant is engaging in the joint fundraiser to pay off outstanding debts, the notice must state that 

the allocation formula may change if the participant receives enough funds to pay its debts. See Chapter 

4, Section 8, “Contributions to Retire Debts.”
155

Joint Fundraising

• If, under state law, any unregistered participant is permitted to receive contributions prohibited under 

the Act, the notice must say that such contributions will be given only to participants that may legally 

accept them.

102.17(c)(2)(ii).

8. Screening Contributions

The fundraising representative and participants must screen all contributions to make sure they are neither 

prohibited by the Act nor in excess of the Act’s contribution limits. The maximum amount a contributor 

may give to a joint fundraiser is the total amount he or she may contribute to all participants without 

exceeding any limits.

To facilitate screening, participants must provide the joint fundraising representative with records of past 

contributions so that the representative may determine whether a donor has exceeded the contribution 

limits. 102.17(c)(4)(i) and (c)(5).

9. Recordkeeping

Receipts

With 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.

100.12, 102.8(a) and (b) and 102.17(c)(4)(ii).

The date of receipt is the date the joint fundraising representative receives the contribution. 102.17(c)(3)

(iii).

Prohibited contributions

The joint fundraising representative must also keep a record of the total amount of prohibited contributions 

received, if any, and of any transfers containing prohibited funds made to participants that may accept 

them. 102.17(c)(4)(ii).

Disbursements

The joint fundraising representative must retain, for three years, records on all disbursements made for the 

joint fundraiser. 102.17(c)(4)(iii) and 102.9. The required recordkeeping information is described under 

Chapter 11, Section 3, “Recording Disbursements.” If a commercial fundraising firm or agent is used, it 

must forward required records on disbursements to the joint fundraising representative. 102.17(c)(4)(iii).

10. Paying Expenses: Step 1—Allocating Gross Proceeds

In general, expenses must be paid before proceeds may be transferred to the participants. Thus, the joint 

fundraising representative may make payments for fundraising expenses from gross proceeds collected 

at the fundraiser (and from funds advanced by the participants). 102.17(c)(7)(iii). Nevertheless, it must 

allocate (but not transfer) gross proceeds among the participants.
156

Appendix C

Generally, the joint fundraising representative must allocate gross proceeds according to the allocation 

formula. However, as stated in the fundraising notice, the formula may change if the allocation results in:

• An excessive contribution from a contributor to one of the participating committees; or

• A surplus for a participant raising money solely to pay off campaign debts.

Reallocation under these circumstances must be based on the other participants’ proportionate shares 

under the allocation formula. If reallocation results in a contributor exceeding the contribution limits 

for the remaining participants, the joint fundraising representative must return the excess amount to the 

contributor. 102.17(c)(6)(i).

Example: Using the same example mentioned previously (allocation formula: Committees A and B, 25 

percent each; Committee C, 50 percent), the participants receive a $2,000 contribution from a donor 

who had previously contributed up to his limit to Committee C. If the fundraising representative were 

to divide the contribution according to the allocation formula, Committee C would receive an excessive 

contribution of $1,000. Instead, the excess $1,000 is divided equally between Committees A and B, since 

their proportionate shares under the allocation formula are equal. Each receives an extra $500, bringing 

their total allocation to $1,000 apiece.

If, however, Committee A can accept only $800 from the contributor without exceeding the limit, the 

excess $200 is allocated to Committee B. If Committee B cannot accept the money for the same reason, the 

$200 must be returned to the contributor.

Designated contributions

Designated or earmarked contributions that exceed the contributor’s limit for a participant may not be 

reallocated without the prior written consent of the contributor. 102.17(c)(6)(ii).

Prohibited contributions

Prohibited contributions must be distributed only to the unregistered participants that may lawfully accept 

them; they do not have to be distributed according to the allocation formula. 102.17(c)(6)(iii).

11. Paying Expenses: Step 2—Allocating Expenses

After gross proceeds are allocated, the joint fundraising representative must calculate each participant’s 

share of expenses based on its actual share of gross proceeds. This allocation may differ from the original 

formula. (See example C–3.) (Prohibited contributions may be excluded from the gross proceeds when 

determining the ratio.) 102.17(c)(7)(i)(A). Expenses for a series of fundraising events must be allocated on 

a per-event basis. 102.17(c)(7)(i)(C).

Example: At the start of the fundraiser, Committees A, B and C agree to allocate 25 percent of proceeds 

and expenses to Committee A, 25 percent to Committee B and 50 percent to Committee C. However, 

because the joint fundraising representative must reallocate some contributions, Committee A is actually 

allocated 20 percent of gross proceeds; Committee B, 35 percent; and Committee C, 45 percent. The 

fundraising representative must allocate the joint fundraising expenses, $10,000, on the same basis: $2,000 

to Committee A, $3,500 to Committee B and $4,500 to Committee C.

Excess payment

If a participant pays for more than its allocated share of expenses, the excess payment is considered a 

contribution, subject to the Act’s limits (see “Start-Up Costs,” Section 6 of this chapter). 102.17(c)(7)(i)

(B). (Party committees are exempt from this rule when paying for other party committee participants 

because, as explained in Section 14, they may make unlimited transfers to other party committees.)
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Joint Fundraising

Remember, if an unregistered participant makes such a contribution, the payment may trigger registration 

and reporting requirements for that organization. 100.5.

12. Paying Expenses: Step 3—Calculating Net Proceeds

The joint fundraising representative may delay transferring net proceeds to participants until after 

it receives all contributions and pays all expenses for the fundraiser. To determine net proceeds, the 

fundraising representative subtracts the participant’s share of expenses from its share of gross proceeds. 

102.17(c)(3)(ii) and (c)(7)(i)(A).

Example: Committees A, B and C raise $50,000 in gross proceeds and spend $10,000 in expenses, leaving 

$40,000 in net proceeds. The joint fundraising representative allocates $10,000 (20 percent) in gross 

proceeds to Committee A and $2,000 (20 percent) in expenses; Committee A’s net proceeds equal $8,000.

SCHEDULE A (FEC Form 3)

ITEMIZED RECEIPTS

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

    , , .

SUBTOTAL of Receipts This Page (optional) ............................................................................    , , .

TOTAL This Period (last page this line number only) ...............................................................  

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

Receipt For: 

 Primary General

 Other (specify)

A.

Election Cycle-to-Date 

Date of Receipt

Name of Employer Occupation

    , , .

FEC ID number of contributing

federal political committee. C

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

Receipt For: 

 Primary General

 Other (specify)

B.

Election Cycle-to-Date 

Date of Receipt

Name of Employer Occupation

    , , .

FEC ID number of contributing

federal political committee. C

 Full Name (Last, First, Middle Initial)

 Mailing Address

 City State Zip Code

Receipt For: 

 Primary General

 Other (specify)

C.

Election Cycle-to-Date 

Date of Receipt

Name of Employer Occupation

    , , .

FEC ID number of contributing

federal political committee. C

FOR LINE NUMBER: PAGE OF

Use separate schedule(s) (check only one)

for each category of the 

Detailed Summary Page 11a 11b 11c 11d

 12 13a 13b 14 15

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

 M M / D D / Y Y Y Y

Amount of Each Receipt this Period

    , , .

Amount of Each Receipt this Period

    , , .

Amount of Each Receipt this Period

    , , .

FEC Schedule A (Form 3) (Revised 05/2016)

Memo Item

Memo Item

Memo Item

Doe for Congress Committee

Doe / Johnson Golf Outing 2022

201 King St.

Alexandria VA 00000

2,000.00

1,900.00

03 28 2022

X

X

joint fundraiser

Rosario, Jenny

1324 Seven Chimney Ln.

Centreville VA 00000

1,000.00

1,000.00

02 25 2022

X joint fundraiser

Doe/Johnson Golf 2022

X

Magnusen, Joseph

490 Main St.

Fredericksburg VA 00000

1,000.00

1,000.00

02 25 2022

X joint fundraiser

Doe/Johnson Golf 2022

X

Centreville College

Wittgenstein & Russell

Professor

Attorney

00000000

1,900.00

10,060.00

C–3: Joint fundraising (Schedule A)
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Appendix C

13. Reporting

By joint fundraising representative

The joint fundraising representative reports all joint fundraising proceeds in the reporting period in which 

they are received. If any prohibited contributions are received for a participating unregistered organization, 

the joint fundraising representative must report them as a memo entry. Any Schedule A used to itemize 

contributions must clearly indicate on the schedule that the receipts are joint fundraising proceeds. 

102.17(c)(3)(iii) and (c)(8)(i)(A).

The joint fundraising representative must also report all disbursements made for the joint fundraiser 

in the reporting period in which they are made. 102.17(c)(8)(ii). Transfers of net proceeds to the joint 

fundraising participants are reported as transfers to affiliated committees and itemized on a separate 

Schedule B for that category.

Joint fundraising representatives that only support federal candidates must file reports using Form 3 and 

follow the reporting schedule for authorized committees (102.13(c)). Joint fundraising representatives that 

support at least one party or non-party political committee (such as a PAC) must file reports using Form 3X 

and follow the filing schedule for unauthorized committees (104.5(a) - (c)).

Reporting last-minute contributions

If a candidate’s campaign participates in a joint fundraiser, the joint fundraising representative must notify 

the campaign if it receives contributions of $1,000 or more less than 20 days but more than 48 hours 

before 12:01 a.m. of the day of any election in which the candidate is running. It is imperative that the 

joint fundraising representative quickly notifies the campaign of the receipt since the principal campaign 

committee is responsible for filing the 48-Hour Notice (FEC Form 6) to disclose those contributions within 

48 hours of the receipt. The notice should disclose the information for the original contributor(s) rather 

than information about the joint fundraiser’s total transfer. For more information on 48-Hour Notices, see 

Chapter 12, Section 3.

Electronic filing

The joint fundraising representative must file electronically if its total yearly contributions or total yearly 

expenditures exceed, or are expected to exceed, $50,000. 104.18. For more information on electronic filing, 

see Chapter 12, Section 5.

Participants

After the joint fundraising representative distributes the net proceeds, each participating political 

committee reports its share as a transfer-in from the joint fundraising representative on Line 12 (Transfers 

from Other Authorized Committees) and itemizes the transfer on a separate Schedule A for that Line. 

Using the records received from the joint fundraising representative, a participating committee also must 

itemize its share of gross receipts as contributions from the original donors on a memo entry Schedule 

A (to the extent required by the rules on itemization—see Chapter 13, Section 4). When itemizing gross 

contributions, the participant must report the date of receipt as the day the joint fundraising representative 

received the contribution. 102.17(c)(3)(iii) and (c)(8)(i)(B).

Termination

The joint fundraising committee should follow the instructions in Chapter 14 for terminating the 

committee. Note that the joint fundraising account cannot be closed until the Commission notifies the 

committee in writing that the termination report has been accepted.
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Joint Fundraising

14. Exception for Party Committees3

Payments made by a party committee (that is a registered federal political committee) on behalf of 

another party committee are considered transfers of funds rather than contributions. Because there is no 

limit on transfers between party committees of the same political party, a party committee may pay any 

amount of another party committee’s allocated start-up costs and fundraising expenses. Moreover, if all 

the participants in the fundraiser are party committees, start-up costs and fundraising expenses need not 

be allocated at all. 102.6(a)(1)(i) and (ii); 102.17(b)(3)(iii) and (c)(7)(ii).

Payments by unregistered party organizations

The same exception also applies to unregistered party organizations. They must use funds permissible 

under the Act when making payments for start-up costs and fundraising expenses. Furthermore, such 

payments by a party organization on behalf of a registered party committee count against the $1,000 

contribution/expenditure threshold for registration as a political committee. 100.5, 102.6(a)(2) and 

102.17(c)(7)(ii).

3 This section also applies to nonconnected committees and unregistered political organizations that are affiliated. See Chapter 4, 

Section 1 for the definition of “affiliated.”
160

Appendix C
161

Appendix D

Communications

NOTE: This section discusses communications that are not made by the campaign but that are made by 

others in support of, or opposition to, a candidate. Candidates and their campaigns may reproduce and 

distribute this appendix to anyone who requests FEC guidelines on such communications. Citations refer 

to Federal Election Commission regulations, contained in Title 11 of the Code of Federal Regulations (11 

CFR). Advisory opinions (AOs) issued by the Commission are cited as well. If you have any questions after 

reading this appendix, please call the Commission: 800/424-9530 (toll free) or 202/694-1100.

1. Public Communications

It is important to understand how the Federal Election Campaign Act (the Act) and FEC regulations define 

“public communication” because many of the rules regarding political communications depend upon 

whether the communication in question is a public communication.

Definition1

A public communication is a communication made by means of:

• Any broadcast, cable or satellite communication;

• Newspaper;

• Magazine;

• Outdoor advertising facility;

• Mass mailing (more than 500 pieces of substantially similar mail within any 30-day period);

• Telephone bank (more than 500 substantially similar telephone calls within any 30-day period);

• An advertisement placed for a fee on another person’s website; or

• Any other form of general public political advertising.2 100.26, 100.27 and 100.28.

2. Coordinated Communications

When a committee, group or individual pays for a communication that is coordinated with a campaign or 

a candidate, the communication is either an in-kind contribution or, in some limited cases, a coordinated 

party expenditure by a party committee.

“Coordinated” defined

Coordinated means made in cooperation, consultation or concert with, or at the request or suggestion of, a 

candidate, a candidate’s authorized committee, or their agents, or a political party committee or its agents.3

109.20.

1 As noted in Chapter 7, at the time of this publication, the Commission was considering proposals to amend its regulations 

concerning the definition of “public communication.” Any updates to these rules will be announced and posted on the FEC’s website. 

The Notice of Proposed Rulemaking is available on FEC.gov.

2 The term “general public political advertising” does not include any internet communication except for a communication placed for a 

fee on another person’s website.

3 For the purposes of 11 CFR Part 109 only, “agent” is defined at 109.3.
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Appendix D

Determining coordination

FEC regulations provide for a three-pronged test to determine whether a communication is coordinated. A 

communication must satisfy all three prongs of the test to be considered a coordinated communication (and 

as a result, count against contribution limits). 109.21(a).

The three prongs of the test consider:

• The source of payment (payment prong);

• The subject matter of the communication (content prong); and

• The interaction between the person paying for the communication and the candidate or political party 

committee (conduct prong).

When the payment prong, the content prong and the conduct prong are all satisfied, then the 

communication is a coordinated communication and results in an in-kind contribution. (See Chapter 13, 

Section 10 for reporting instructions.)

Payment prong

The payment prong is satisfied when a coordinated communication is paid for, in whole or in part, by a 

person other than the candidate, an authorized committee or a political party committee with whom the 

communication is coordinated. 109.21(a)(1).

Content prong

A communication that meets any one of these five standards meets the content prong:

1) A communication that is an electioneering communication (see Section 6 of this appendix);

2) A public communication that republishes, disseminates or distributes candidate campaign materials, 

unless the activity meets one of the exceptions at 109.23(b);

3) A public communication that expressly advocates the election or defeat of a clearly identified 

candidate for federal office;4

4) A public communication that:

• Refers to a clearly identified House or Senate candidate and is publicly distributed in the identified 

candidate’s jurisdiction within 90 days of the candidate’s primary or general election;

• Refers to a clearly identified Presidential or Vice Presidential candidate and is publicly distributed 

in a jurisdiction during the period starting 120 days before the primary election (or nominating 

convention or caucus) in that jurisdiction and ending on the date of the general election;

• Refers to a political party (but not a candidate) in a midterm election cycle, is coordinated with a 

party committee and is publicly distributed within 90 days of a primary or general election;

• Refers to a political party (but not a candidate) in a Presidential election cycle, is coordinated with a 

party committee and is publicly distributed during the period starting 120 days before the primary 

in that jurisdiction and ending on the date of the general election;

• Refers to a political party (but not a candidate), is coordinated with a House or Senate candidate 

and is publicly distributed in that candidate’s jurisdiction within 90 days of the primary or general 

election; or

4 A candidate is clearly identified when his or her name, nickname, photograph or drawing appears or when his or her identity is 

apparent by unambiguous reference such as “the President,” “your Congressman,” or “the incumbent,” or through an unambiguous 

reference to his or her status as a candidate such as “the Democratic presidential nominee” or “the Republican candidate for Senate in 

the State of Texas.” 100.17; 106.1(d).
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Communications

• Refers to a political party (but not a candidate), is coordinated with a Presidential candidate and 

is publicly distributed during the period starting 120 days before the primary until the date of the 

general election.5

5) A public communication that is the functional equivalent of express advocacy.6 109.21(c)(5).

Conduct prong

The purpose of the conduct prong is to determine when interaction between the campaign and the person 

paying for the communication might constitute coordination. A communication that satisfies any one of 

these conduct standards satisfies the conduct prong:

1) Request or suggestion. This conduct standard has two parts, and satisfying either satisfies the 

standard. The first part is satisfied if the person creating, producing or distributing the communication 

does so at the request or suggestion of a candidate, authorized committee, or political party committee 

or agent of any of these. A communication satisfies the second part of the “request or suggestion” 

conduct standard if the person paying for the communication suggests the creation, production or 

distribution of the communication to the candidate, authorized committee, political party committee or 

agent of any of the above, and the candidate, authorized committee or political party committee assents 

to the suggestion. 109.21(d)(1).

2) Material involvement. This conduct standard is satisfied if a candidate, candidate committee, 

political party committee or an agent of any of these was “materially involved in decisions regarding” 

any of the following aspects of a public communication paid for by someone else:

• Content of the communication;

• Intended audience;

• Means or mode of the communication;

• Specific media outlet used;

• Timing or frequency of the communication; or

• Size or prominence of a printed communication or duration of a communication by means of 

broadcast, cable or satellite. 109.21(d)(2).

3) Substantial discussion. A communication meets this conduct standard if it is created, produced 

or distributed after one or more substantial discussions between the person paying for the 

communication, or the person’s agents, and the candidate clearly identified in the communication 

or that candidate’s committee, that candidate’s opponent or opponent’s committee, a political party 

committee or an agent of the above. A discussion would be “substantial” if information about the 

plans, projects, activities or needs of the candidate or political party committee that is material to the 

creation, production or distribution of the communication is conveyed to the person paying for the 

communication. 109.21(d)(3).

4) Employment of common vendor. The conduct standard provides that the use of a common vendor 

in the creation, production or distribution of a communication satisfies the conduct standard if:

• The person paying for the communication contracts with, or employs, a “commercial vendor” to 

create, produce or distribute the communication;7 and

• The commercial vendor, including any officer, owner or employee of the vendor, has a previous 

or current relationship with the candidate or political party committee that puts the commercial 

5 For communications that refer to both a party and a clearly identified federal candidate, see 109.21(c)(4)(iv).

6 A communication is the functional equivalent of express advocacy if it is “susceptible of no reasonable interpretation other than 

as an appeal to vote for or against a clearly identified federal candidate.” This content standard applies without regard to the timing 

of the communication or the targeted audience. See the Commission’s Final Rules on Coordinated Communications published in the 

September 15, 2010, Federal Register (75 FR 55947), available on FEC.gov.

7 The term “commercial vendor” is defined at 116.1(c).
164

Appendix D

vendor in a position to acquire information about the campaign plans, projects, activities or needs 

of the candidate or political party committee. This previous relationship is defined in terms of nine 

specific services related to campaigning and campaign communications. (See 109.21(d)(4)(ii).) 

Note that these services would have to have been rendered within 120 days before the purchase or 

public distribution of the communication; and

• The commercial vendor uses or conveys information about the campaign plans, projects, activities 

or needs of the candidate or political party committee, or information previously used by the 

commercial vendor in serving the candidate or political party committee, to the person paying for 

the communication, and that information is material to the creation, production or distribution of 

the communication. 109.21(d)(4). “Safe harbor for publicly available information” and “Safe harbor 

for use of a firewall” in this section..

5) Former employee/independent contractor. This conduct standard applies to communications paid 

for by a person or the employer of a person, who has previously been an employee or an independent 

contractor of a candidate, candidate’s campaign committee or a political party committee during the 

120 days before the purchase or public distribution of the communication.

This standard requires that the former employee or contractor use or convey information about the 

plans, projects, activities or needs of the candidate, candidate’s opponent, or political party committee, or 

information used by the former employee or contractor in serving the candidate, candidate’s opponent, or 

political party committee, to the person paying for the communication, and that the information is material 

to the creation, production or distribution of the communication. 109.21(d)(5).8 See AO 2016-21 (Great 

America PAC); “Safe harbor for publicly available information” and “Safe harbor for use of a firewall” in this 

section.

Dissemination, distribution or republication of campaign material

A communication that republishes, disseminates or distributes campaign material only satisfies the first 

three conduct standards on the basis of the candidate’s conduct—or that of his or her committee or agents—

that occurs after the original preparation of the campaign materials that are disseminated, distributed or 

republished. 109.21(d)(6).9

Agreement or formal collaboration

Neither agreement (defined as a mutual understanding on any part of the material aspects of the 

communication or its dissemination) nor formal collaboration (defined as planned or systematically 

organized work) is necessary for a communication to be a coordinated communication. 109.21(e).

Safe harbor provisions to the conduct prong

Safe harbor for responses to inquiries about legislative or policy issues

A candidate’s or political party committee’s response to an inquiry about that candidate’s or party’s 

positions on legislative or policy issues that does not include discussion of campaign plans, projects, 

activities or needs will not satisfy any of the conduct standards. 109.21(f).

8 Under the rules, a candidate or political party committee would not be held responsible for receiving or accepting an in-kind 

contribution that resulted only from conduct described in the “Employment of common vendor” and ”Former employee/independent 

contractor” sections. 109.21(d)(4) and (d)(5). However, the person paying for a communication that is coordinated because of 

conduct described in these sections would still be responsible for making an in-kind contribution for purposes of the contribution 

limitations, prohibitions and reporting requirements of the Act. 109.21(b)(2).

9 Note that the financing of the distribution or republication of campaign materials, while considered an in-kind contribution by 

the person making the expenditure, is not considered an expenditure made or a contribution received by the candidate’s authorized 

committee unless the dissemination, distribution or republication of campaign materials is coordinated. Additionally, republications of 

campaign materials coordinated with party committees are in-kind contributions to such party committees and are reportable as such. 

109.23(a).
165

Communications

Safe harbor for publicly available information

The standards for substantial discussion, material involvement, use of a common vendor and involvement 

of a former employee are not satisfied if the information used in creating or distributing the communication 

was obtained from a publicly available source. Publicly available sources include, but are not limited to:

• Newspaper or magazine articles;

• Candidate speeches or interviews;

• Transcripts from television shows;

• Press releases;

• A candidate or political party’s website; and

• Any publicly available website.

109.21(d)(3).

Safe harbor for use of a firewall

None of the conduct standards are satisfied if the vendor, political committee, former employee or 

contractor implements a firewall. The firewall must be designed and implemented to prohibit the flow 

of information between employees or consultants providing services to the person paying for the 

communication and those employees or consultants providing services to a political party committee or to 

the candidate who is clearly identified in the communication or to the campaign of the candidate opposing 

the candidate clearly identified in the communication. The firewall must be described in a written policy 

statement that is distributed to all employees, consultants and clients affected by the policy. 109.21(h).

Safe harbor for candidate endorsements and solicitations

A federal candidate may endorse or solicit funds for a candidate for federal or nonfederal office in a 

public communication without the communication being considered a “coordinated communication” with 

respect to the endorsing or soliciting candidate, so long as the communication does not promote or support 

the candidate making the solicitation and does not attack or oppose his/her opponent. The safe harbor 

described in this paragraph also covers candidate solicitations for other political committees (including 

party committees) and candidate solicitations for certain tax-exempt organizations as described at 300.65. 

109.21(g)(1) and (2).

Safe harbor for certain commercial transactions

A federal candidate may appear in a public communication in which he or she is clearly identified as the 

owner or operator of a business that existed prior to the candidacy without the communication being 

considered a “coordinated communication,” so long as the public communication does not promote, 

attack, support or oppose (PASO) that candidate or another candidate who seeks the same office. The 

communication must also be consistent with other public communications made by the business prior to 

the candidacy in terms of the medium, timing, content and geographic distribution. 109.21(i).

3. Independent Expenditures

Individuals, corporations, labor unions and political committees may support (or oppose) candidates by 

making independent expenditures. Independent expenditures are not contributions and are not subject to 

contribution limits. Compare 109.20(b).

Defined

An independent expenditure is an expenditure for a communication that:

• Expressly advocates the election or defeat of a clearly identified federal candidate; and

• Is not coordinated with a candidate, candidate’s committee, party committee or their agents. (See 

Section 2, “Coordinated Communications.”) 100.16(a).
166

Appendix D

Clearly identified candidate

A candidate is “clearly identified” if the candidate’s name, nickname, photograph or drawing appears, or the 

identity of the candidate is otherwise apparent through an unambiguous reference to “the President,” “your 

Congressman,” “the Democratic Presidential nominee,” “the Republican candidate for Senate in the State of 

Georgia.” 100.17.

Express advocacy

“Express advocacy” means that the communication includes a message that unmistakably urges the election 

or defeat of one or more clearly identified candidate(s). There are two ways that a communication can be 

considered express advocacy: by use of certain “explicit words of advocacy of election or defeat” or by the 

“only reasonable interpretation” test. 100.22.

Explicit words of advocacy of election or defeat

The following words convey a message of express advocacy:

• “Vote for the President,” “re-elect your Congressman,” “support the Democratic nominee,” “cast your 

ballot for the Republican challenger for the U.S. Senate in Georgia,” “Smith for Congress,” “Bill McKay in 

’12;”

• Words urging action with respect to candidates associated with a particular issue, e.g., “vote ProChoice”/“vote Pro-Life,” when accompanied by names or photographs of candidates identified as either 

supporting or opposing the issue;

• “Defeat” accompanied by a photograph of the opposed candidate, the opposed candidate’s name or 

“reject the incumbent;” and

• Campaign slogan(s) or word(s), e.g., on posters, bumper stickers and advertisements, that in context can 

have no other reasonable meaning than to support or oppose a clearly identified candidate, for example, 

“Nixon’s the One,” “Carter ‘76,” “Reagan/Bush.” 100.22(a).

“Only reasonable interpretation” test

In the absence of such “explicit words of advocacy of election or defeat,” express advocacy is found in 

a communication that, when taken as a whole and with limited reference to external events, such as the 

proximity to the election, can only be interpreted by a “reasonable person” as advocating the election or 

defeat of one or more clearly identified candidate(s). 100.22(b). This test requires advocacy of a candidate 

that is unmistakable, unambiguous and suggestive of only one meaning (that being the election or defeat of 

a candidate). 100.22(b)(1). Note that the author’s intent is irrelevant. The test is how a “reasonable” receiver 

of the communication objectively interprets the message. If reasonable minds could not differ as to the 

unambiguous electoral advocacy of the communication, it is express advocacy regardless of what the author 

intended. 100.22(b)(2).

Disclaimer notice required

A communication representing an independent expenditure must display a disclaimer notice. See 

“Disclaimers” later in this appendix for more information.

Allocation among candidates

When an independent expenditure is made on behalf of more than one clearly identified candidate, the 

committee must allocate the expenditure among the candidates in proportion to the benefit that each is 

expected to receive. For example, in the case of a published or broadcast communication, the attribution 

must be determined by the proportion of space or time devoted to each candidate in comparison with the 

total space or time devoted to all the candidates. 104.10 and 106.1(a).
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Communications

4. Reporting Requirements for Independent Expenditures

Made by a political committee

A federally registered political committee reports independent expenditures on Schedule E of FEC Form 

3X. A political committee must itemize each independent expenditure which exceeds $200 or which, when 

added to previous independent expenditures made on behalf of (or in opposition to) the same candidate, 

aggregates over $200 during a calendar year. Schedule E instructions explain what itemized information 

must be disclosed. (Independent expenditures of $200 or less must be subtotaled and reported as 

unitemized expenditures on Schedule E.) 104.3(b)(3)(vii) and 104.4(a).

Made by any other person

Any other person (including a corporation or labor organization) must file a report with the FEC on Form 

5 at the end of the first reporting period in which independent expenditures aggregate more than $250 and 

must continue to file quarterly reports in any succeeding reporting period during the same year in which 

additional independent expenditures of any amount are made. 109.10(b) and (c). Form 5 instructions 

explain what information must be disclosed. Filers whose independent expenditures exceed, or are 

expected to exceed, $50,000 in any calendar year must electronically file FEC Form 5. Visit www.fec.gov to 

access this form.

Date made

An independent expenditure is considered made on the date that the communication is publicly distributed 

or otherwise publicly disseminated. 104.4. Independent expenditures publicly distributed or otherwise 

publicly disseminated prior to payment should be disclosed as memo entries. Political committees list 

these entries on Schedule E and on Schedule D as a reportable debt. 104.11. Other filers must disclose this 

information on Schedule 5-B of Form 5.

Certification

Both Schedule E (used by political committees) and Form 5 (used by others) require a certification, under 

penalty of perjury, that the expenditure meets the standards for independence. 104.3(b)(3)(vii)(B), 

104.4(d) and 109.10(e)(1)(v). See Section 2 of this appendix.

24-hour reports

Any independent expenditure of $1,000 or more (in the aggregate with respect to a given election) that is 

made after the 20th day, but more than 24 hours, before the day of the election must be reported within 

24 hours. 104.4(c).The report must include all the information required on Schedule E or Form 5 and 

must be received by the FEC within 24 hours after the communication is publicly distributed or otherwise 

publicly disseminated. 104.4(c) and (e), 105.4 and 109.10(d). A political committee must disclose a lastminute independent expenditure a second time on a Schedule E filed with its next scheduled report. The 

committee may, if it wishes, note that the expenditure was previously reported.

48-hour reports

Political committees and other persons who make independent expenditures that aggregate $10,000 or 

more for a given election at any time during a calendar year—up to and including the 20th day before 

the election—must disclose this activity within 48 hours of the date that the communication is publicly 

distributed or otherwise publicly disseminated. 104.4(b)(2) and 109.10(c). Electronic filers must file 

48-hour reports electronically and paper filers may file by fax or e-mail. 100.19(d)(3), 104.4(b)(2) and 

109.10(c).
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Committees must report in their regularly scheduled report on Schedule E of Form 3X, all independent 

expenditures made for a given election which aggregate over $200 in a calendar year. The report must be 

filed no later than the filing date of the committee’s next regularly scheduled report. 104.4(a) and (b)(1). 

Other filers must disclose on FEC Form 5 independent expenditures aggregating in excess of $250 with 

respect to a given election during the calendar year that are made during this time period. The report must 

be filed by the filing deadline of the next report under the quarterly filing schedule. 109.10(b).

Aggregating independent expenditures for reporting purposes

Independent expenditures are aggregated toward the various reporting thresholds on a per election basis, 

within the calendar year, per office sought (race). Consider, as examples, the following scenarios, all of 

which occur outside of the 20-day window before an election when 24-hour reports are required:

• If a committee makes $5,000 in independent expenditures with respect to a Senate candidate and 

$5,000 in independent expenditures with respect to a House candidate, then the committee is not 

required to file 48-hour reports but must disclose this activity on its next regularly scheduled report.

• If the committee makes $5,000 in independent expenditures with respect to a clearly identified 

candidate in the primary and an additional $5,000 in independent expenditures with respect to the 

same candidate in the general, then no 48-hour report is required and the expenditures are disclosed on 

the committee’s next report.

• If the committee makes $6,000 in independent expenditures supporting a Senate candidate in the 

primary election and $4,000 opposing that Senate candidate’s opponent in the same election, then the 

committee must file a 48-hour report.

Again, the date that a communication is publicly distributed or otherwise publicly disseminated serves 

as the date that the independent expenditure is “made” and the date a person or committee must use 

to determine whether the total amount of independent expenditures has, in the aggregate, reached or 

exceeded the threshold reporting amounts of $1,000 or $10,000.10 The calculation of the aggregate amount 

of the independent expenditures must include both disbursements for independent expenditures and all 

contracts obliging funds for disbursements of independent expenditures. 104.4(f).

5. Party Communications

In addition to general coordinated communications, there are “party coordinated communications,” which 

are communications paid for by a party and coordinated with a candidate’s campaign. Additionally, some 

communications by party committees may trigger additional requirements for those committees because 

they qualify as federal election activity.

Determining coordination

Party coordinated communications satisfy a similar three-pronged test for coordination. However, there 

are two important differences. First, the communication is paid for by a political party committee. Second, 

electioneering communications do not satisfy the content prong. 109.37(a)(1)-(3).

In-kind contribution vs. party coordinated expenditure

Party coordinated communications must be treated by the party committee as either an in-kind 

contribution to the candidate or as a coordinated party expenditure in connection with the general 

10 Independent expenditures such as yard signs, mini-billboards, handbills, t-shirts, hats and buttons are “publicly disseminated on 

any reasonable date starting with the date the filer receives or exercises control over the items in the usual and normal course of 

dissemination, up to and including the date that the communications are actually disseminated to the public.” For more information, 

see the FEC’s Interpretive Rule on when Certain Independent Expenditures are “Publicly Disseminated” for Reporting Purposes on 

FEC.gov.
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Communications

election campaign of the candidate. 109.37(b). For more information on the rules for Coordinated Party 

Expenditures, see Chapter 7 in the Campaign Guide for Political Party Committees.

Party communications as Federal Election Activity

Certain activities are restricted under the Act when they qualify as Federal Election Activity (FEA). If a 

party committee pays for a public communication (defined in Section 1) that refers to a clearly identified 

candidate for federal office and that promotes, attacks, supports or opposes any candidate for federal office, 

the activity qualifies as FEA. 100.24(b)(3). The communication does not need to expressly advocate the 

election or defeat of the federal candidate to qualify as FEA. FEA requires specific payment methods.

For further information on FEA, see Chapter 8 of the Campaign Guide for Political Party Committees.

6. Electioneering Communications

An electioneering communication is any broadcast, cable or satellite communication that 1) refers to a 

clearly identified federal candidate, 2) is publicly distributed within 60 days of a general election or 30 

days of a primary, and 3) is targeted to the relevant electorate, in the case of House and Senate candidates. 

100.29(a).

Clearly identified candidate

A candidate is clearly identified if his or her name, nickname, photograph or drawing appears in the ad, or 

if the ad contains an unambiguous reference to the candidate through titles such as “the President,” “your 

Representative,” or “the incumbent.” 100.29(b)(2).

Publicly distributed

A communication is “publicly distributed” when it is aired, broadcast, cablecast or otherwise disseminated 

through the facilities of a radio or television station, cable television system or a satellite system. 100.29(b)

(3).11

Targeted to the relevant electorate

A communication is “targeted to the relevant electorate” when it is receivable by 50,000 or more persons in 

the candidate’s district (for a House candidate) or state (for a Senate candidate). 100.29(b)(5).

What is not an electioneering communication?

A communication is not an electioneering communication if it:

• Is publicly disseminated through means other than broadcast, cable or satellite media (100.29(c)(1));

• Appears in a news story, commentary or editorial that is distributed by broadcast, cable, or satellite 

facilities not owned or controlled by any political party or candidate (100.29(c)(2));

• Is a bona fide news story distributed by facilities owned and controlled by a party or candidate 

(100.29(c)(2) and 100.132);

• Constitutes an expenditure or independent expenditure that is required to be reported as such 

(100.29(c)(3));

11 In the case of a Presidential or Vice Presidential candidate, publicly distributed means that the communication meets the 

requirements of 100.29(3)(i) and can be received by 50,000 or more persons in a state within 30 days of a primary, or by 50,000 or 

more persons anywhere in the U.S. within 30 days of the national nominating convention. 100.29(b)(3)(ii); but see AO 2015-10 (21st 

Century Fox).
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Appendix D

• Constitutes a candidate debate or forum or promotion of such a debate or forum by the sponsor of the 

event (100.29(c)(4) and 110.13); or

• Is paid for by a candidate for nonfederal office in connection with a nonfederal election, provided that 

the communication does not promote, support, attack or oppose any federal candidate (100.29(c)(5)).

Who may make electioneering communications?

Individuals and other persons, including corporations and labor organizations, may make electioneering 

communications. The messages must include disclaimers (as described in Section 7) and are subject to 

disclosure requirements.

Political committees may make communications that meet the definition of electioneering communications. 

However, because such communications would be reportable as “expenditures” under the Act, they are not 

technically considered electioneering communications. 100.29(c)(3) and 114.5(i). If such a communication 

is coordinated with a campaign, it counts as an in-kind contribution, subject to limitations and reporting 

requirements. See Section 2 of this appendix.

Coordinated electioneering communication

As noted previously, an electioneering communication meets the content and payment tests under the 

Commission’s three-part test for determining whether a communication is coordinated. 109.21(a)(1) and 

(c)(1). If the conduct prong is met as well, then the electioneering communication would be considered 

an in-kind contribution subject to contribution limitations, source prohibitions and reporting by both the 

payor and the campaign. To avoid receiving an illegal excessive or prohibited contribution, campaigns 

should avoid interacting with those making electioneering communications in the manner noted under 

“conduct prong” in Section 2 of this appendix.

For more information, see Chapter 7, Section 12 and the Commission’s webpage on making electioneering 

communications.

7. Disclaimer Notices on Communications

Any public communication made by a political committee—including communications that do not expressly 

advocate the election or defeat of a clearly identified federal candidate or solicit a contribution—must 

display a disclaimer.12 Disclaimers must also appear on political committees’ internet websites and in 

certain e-mail communications. 110.11(a)(1). Moreover, all public communications that expressly advocate 

the election or defeat of a clearly identified candidate, electioneering communications, and all public 

communications that solicit any contribution require a disclaimer, regardless of who has paid for them. 

110.11(a)(2)-(4).

This section focuses on disclaimer requirements for communications that are not paid for by the campaign. 

For information on disclaimer notices on communications and advertisements paid for by the campaign, see 

Chapter 10, Section 2. Note that solicitations must meet additional disclaimer requirements. See Chapter 10.

Wording of disclaimer

Communications not authorized by a candidate

Communications not authorized by a candidate or his or her campaign committee, including any 

solicitation, must disclose the full name and permanent street address, telephone number or website 

12 At the time of this publication, the Commission was considering proposals to amend its regulations concerning disclaimers on 

certain internet communications. Any updates to these rules will be announced and posted on the FEC’s website. The Notice of 

Proposed Rulemaking is available on FEC.gov.
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Communications

address of the person who paid for the communication, and also state that the communication was not 

authorized by any candidate. 110.11(b)(3) and (d)(3). See AO 2017-05 (Great America PAC).

Example: “Paid for by the Citizens PAC (www.citizenspac.org) and not authorized by any candidate or 

candidate’s committee.”

In addition, for a radio or television communication that is not authorized by a candidate or the candidate’s 

authorized committee, a representative of the individual or group paying for the communication must state 

that “XXX is responsible for this communication,” where “XXX” is the name of the political committee 

or other person who paid for the communication. If applicable, the name of the sponsoring committee’s 

connected organization is also required in the disclaimer.13 110.11(c)(4)(i). See “Visibility requirements.”

Communications authorized by a candidate

The disclaimer for a communication authorized by a candidate or candidate’s committee, but paid for 

by any other person, must state both who paid for the communication and that it was authorized by that 

candidate. 110.11(b)(2).

Example: “Paid for by the Citizens PAC and authorized by the John Doe for Congress Committee.”

Coordinated party expenditures

On a communication that is made as a coordinated party expenditure before a nominee is officially chosen, 

the disclaimer notice need only identify the committee that paid for the message. 110.11(d)(1)(ii).

Example: “Paid for by the XYZ State Party Committee.”

Once a candidate has been nominated for the general election, the disclaimer notice must also state who 

authorized the communication and comply with the other applicable requirements listed in the next 

section.

Example: “Paid for by the XYZ State Party Committee and authorized by John Doe for Congress 

Committee.” 110.11(d)(2).

Exempt party activity

On an exempt activity communication, such as campaign materials, the disclaimer notice must identify 

the committee that paid for the message but need not state whether the communication is authorized by a 

candidate. 110.11(e).

Example: “Paid for by the XYZ State Party Committee.”

Visibility requirements

All disclaimers must be “clear and conspicuous” regardless of the medium in which the communication is 

transmitted. A disclaimer is not clear and conspicuous if it is difficult to read or hear, or if its placement is 

easily overlooked. 110.11(c)(1).

Specific requirements for radio and television communications.

For radio and television communications authorized by a candidate, the candidate must deliver an audio 

statement identifying himself or herself, and stating that he or she has approved the communication. 

110.11(c). For example, the candidate could state “My name is John Doe, and I approved this message.”

13 In addition, communications transmitted through telephone banks, defined by 100.28 as more than 500 substantially similar 

calls within 30 days, must carry this same disclaimer statement made by a representative of the individual or group paying for the 

communication. 110.11(a).
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Appendix D

See AO 2004-01 (Bush/Kerr). For a television communication, this disclaimer must be conveyed by either:

• A full-screen view of the candidate making the statement; or

• A “clearly identifiable photographic or similar image of the candidate” that appears during the 

candidate’s voice-over statement. 110.11(c)(3)(ii).

In the case of a televised ad not authorized by a candidate, the disclaimer must include a statement that is 

conveyed by a full screen view of a representative of the political committee or other person making the 

statement, or a voice-over by the representative. 110.11(c)(4)(ii).

Both authorized and unauthorized television communications must also contain a “clearly readable” written 

statement that appears at the end of the communication, with a reasonable degree of color contrast between 

the background and the disclaimer statement. The written statement must occupy at least four percent of 

the vertical picture height, and it must be shown for a period of four seconds. 110.11(c)(3)(iii) and (c)(4).

Safe harbor for television communication disclaimers

A still picture of the candidate shall be considered “clearly identifiable” if it occupies at least 80 percent 

of the vertical screen height. 110.11(c)(3)(ii)(B). Disclaimers that are printed in black text on a white 

background, as well as disclaimers that have at least the same degree of contrast with the background 

color as the degree of contrast between the background color and the color of the largest text used in the 

communication, will be considered “clearly readable.” 110.11(c)(3)(iii)(C).

Specific requirements for printed communications

Printed materials must contain a printed box that is set apart from the contents in the communication. The 

disclaimer print in this box must be of sufficient type size to be “clearly readable” by the recipient of the 

communication, and the print must have a reasonable degree of color contrast between the background and 

the printed statement. 110.11(c)(2)(ii) and (iii).

The regulations contain a safe harbor that establishes a fixed, twelve-point type size as a sufficient size for 

disclaimer text in newspapers, magazines, flyers, signs and other printed communications that are no larger 

than the common poster size of 24” x 36.” 110.11(c)(2)(i). Disclaimers for larger communications will be 

judged on a case-by-case basis.

The regulations additionally provide two safe harbor examples that would comply with the color-contrast 

requirement:

• The disclaimer is printed in black text on a white background; or

• The degree of contrast between the background color and the disclaimer text color is at least as 

great as the degree of contrast between the background color and the color of the largest text in the 

communication. 110.11(c)(2)(iii).14

Multiple-paged document

A disclaimer need not appear on the front page or cover of a multiple-paged document so long as it appears 

somewhere within the communication. 110.11(c)(2)(iv).

Package of materials

Each communication that would require a disclaimer if distributed separately must still display the 

disclaimer when included in a package of materials. 110.11(c)(2)(v). For example, if a campaign poster is 

mailed with a solicitation for contributions, a separate disclaimer must appear on the solicitation and the 

poster.

14 Note that these examples do not constitute the only ways to satisfy the color contrast requirement.
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Communications

When disclaimer is not required

A disclaimer is not required:

• When it cannot be conveniently printed (e.g., pens, bumper stickers, campaign pins, campaign buttons 

and similar small items).

• When its display is not practicable (e.g., clothing, water towers and skywriting).

• When the item is of minimal value, does not contain a political message and is used for administrative 

purposes (e.g., checks and receipts). 110.11(f). See AOs 2010-19 (Google) (character-limited text ads), 

2002-09 (Target Wireless) (SMS messages), 1980-42 (Hart) (tickets for fundraiser).
174

Appendix D
175

Appendix E

Fundraising by Federal Candidates and Officeholders

The Federal Election Campaign Act (the Act) and Commission regulations restrict the ability of federal 

candidates and officeholders to raise funds. Specifically, federal candidates and officeholders, their agents 

and entities established, financed, maintained or controlled by them, may not solicit,1 receive, direct,2

transfer, spend or disburse funds in connection with a federal election, including funds for federal election 

activity, unless the funds are within the Act’s limits, prohibitions and reporting requirements. 300.61.

In addition, federal candidates and officeholders may solicit, receive, direct, transfer, spend or disburse 

funds in connection with a nonfederal election only in amounts and from sources that are consistent with 

state law and that do not exceed the Act’s contribution limits or come from prohibited sources. 300.62.

The Act and Commission regulations provide for exceptions and clarifications to these general prohibitions, 

as discussed in this chapter.

1. Fundraising for State/Local Candidates and Elections

Nonfederal elections

A federal candidate, officeholder or his or her agents, and any entity directly or indirectly established, 

financed, maintained or controlled by, or acting on behalf of, one or more federal candidates or 

officeholders, may raise funds in connection with a nonfederal election, but only in amounts consistent 

with state law and that do not exceed the Act’s contribution limits or come from prohibited sources.3 4

300.62; see also 300.64(b)(2).

Ballot initiatives

In AO 2010-07 (Yes on FAIR), the Commission concluded that Members of Congress could solicit funds 

outside the Act’s limits and prohibitions on behalf of a California ballot initiative committee during the 

time before the initiative qualified for the ballot, and afterward could solicit up to $20,000 from individuals 

1 To solicit means to ask, request or recommend, explicitly or implicitly, that another person make a contribution, donation, transfer 

of funds or otherwise provide anything of value. A solicitation is an oral or written communication that, construed as reasonably 

understood in the context in which it is made (including the conduct of the persons involved), contains a clear message asking, 

requesting or recommending that another person make a contribution, donation, transfer of funds or otherwise provide anything of 

value. A solicitation may be made directly or indirectly, and does not include mere statements of political support or mere guidance as 

to the applicability of a particular law or regulation. 300.2(m). See the regulations at 300.2(m)(1)-(3) for examples of communications 

and statements that do or do not constitute solicitations.

2 To direct means to guide, directly or indirectly (through a conduit or intermediary), a person who has expressed an intent to make 

a contribution, donation, transfer of funds or otherwise provide anything of value, by identifying a candidate, political committee or 

organization for the receipt of such funds or things of value. Direction does not include merely providing information or guidance as to 

the applicability of a particular law or regulation. 300.2(n).

3 See 300.2(b) and (c) for a list of the factors considered by the Commission in determining whether an entity is directly or indirectly 

established, financed, maintained or controlled by, or acting on behalf of, a federal candidate, officeholder or agent. See also AOs 2006-

04 (Tancredo), 2005-02 (Corzine II) and 2004-33 (Ripon).

4 Previously, the Commission had stated in an advisory opinion that federal candidates and officeholders could appear at a fundraising 

event for a state or local political party and solicit donations not subject to the Act’s amount limitations and source prohibitions. 

AO 2005-02 (Corzine II) (second paragraph in answer to Question 2). The Commission subsequently promulgated a regulation 

superseding that conclusion. See the Explanation and Justification, Participation by Federal Candidates and Officeholders at NonFederal Fundraising Events, prescribed June 4, 2010, 75 Fed. Reg. 24375 (May 5, 2010).
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Appendix E

on behalf of the committee.5 For additional information on ballot initiatives, see AOs 2007-28 (McCarthy/

Nunes), 2006-04 (Tancredo), 2005-10 (Berman/Doolittle), 2004-29 (Akin) and 2003-12 (Flake).

Candidates who run for both federal and nonfederal office

Commission regulations provide a limited exception for federal candidates and officeholders who seek state 

or local office. The restrictions on raising and spending funds outside the Act’s limitations and prohibitions 

do not apply to any federal candidate or officeholder who is or was also a candidate for state or local office 

so long as the raising or spending of funds is 1) solely in connection with his or her state or local campaign; 

2) refers only to him or her or to other candidates for that same state or local office; and 3) is permitted 

under state law. 300.63.

If the candidate or officeholder is simultaneously running for both federal and state or local offices, then 

the candidate or his or her agents may only raise and spend funds within the limits, prohibitions and 

reporting requirements of the Act for the federal election. 300.63; See also AOs 2007-01 (McCaskill), 2005-

12 (Fattah) and 2005-02 (Corzine II).6

2. Nonfederal Fundraising Events

Participation at nonfederal fundraising events

A federal candidate or officeholder may attend, speak at and be a featured guest at a nonfederal fundraiser. 

300.64(b)(1). He or she is also free to solicit funds at the fundraising event, provided that the solicitation 

for funds is within the limitations and prohibitions of the Act and consistent with state law. 300.64(b)(2).

Such a solicitation should either be explicitly limited or should be limited by displaying at the fundraiser 

a clear and conspicuous written notice, or by making a clear and conspicuous oral statement, that the 

solicitation is not for Levin funds (when applicable) and does not seek funds in excess of federally 

permissible amounts or from corporations, labor organizations, national banks, federal government 

contractors and foreign nationals. 300.64(b)(2)(i-ii). If the federal candidate or officeholder chooses to 

make an oral statement, it need only be made once.

Publicity for nonfederal fundraising events

FEC regulations also address the publicity for nonfederal fundraisers including, but not limited to, ads, 

announcements or pre-event invitation materials, regardless of format or medium of the communication. 

300.64(c).

If the publicity does not contain a solicitation or solicits only federally permissible funds, then the federal 

candidate or officeholder (or agent of either) is free to consent to the use of the name or likeness of the 

federal candidate or officeholder in the publicity for the nonfederal fundraiser. 300.64(c)(1)-(2).

If the publicity contains a solicitation for funds outside the limitations or prohibitions of the Act or for 

Levin funds, the federal candidate or officeholder (or agent of either) may consent to the use of the name 

or likeness of the federal candidate or officeholder in the publicity, only if:

5 The Commission was unable to agree on whether, during the post-qualification period, Members of Congress may solicit donations 

of more than $20,000 and donations from persons other than individuals. See AO 2010-07 (Yes on FAIR). See also Concurring Opinion 

(Chairman Petersen and Commissioners Hunter and McGahn) ; and Concurring Opinion (Vice Chair Bauerly and Commissioners 

Walther and Weintraub).

6 The Commission superseded the second paragraph in the answer to Question 2 in AO 2005-02 (Corzine II). See the Explanation and 

Justification, Participation by Federal Candidates and Officeholders at Non-Federal Fundraising Events, prescribed June 4, 2010, 75 

Fed. Reg. 24375 (May 5, 2010).
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Fundraising by Federal Candidates and Officeholders

• The federal candidate or officeholder is identified in a manner not specifically related to fundraising, 

such as a featured guest, honored guest, special guest, featured speaker or honored speaker; and

• The publicity includes a clear and conspicuous oral or written disclaimer that the solicitation is not 

being made by the federal candidate or officeholder. 300.64(c)(3)(i). (Examples of disclaimers are 

provided in the regulation at 300.64(c)(3)(iv).)

However, a federal candidate or officeholder (or agent of either) may not agree to the use of his or her 

name or likeness in publicity that contains a solicitation of funds outside the limitations and prohibitions of 

the Act or of Levin funds if:

The federal candidate or officeholder is identified as serving in a manner specifically related to fundraising, 

such as honorary chairperson or member of a host committee; or is identified in the publicity as extending 

the invitation to the event; or the federal candidate or officeholder signs the communication. These 

restrictions apply even if the publicity contains a disclaimer. 300.64(c)(3)(v).

In addition, the federal candidate or officeholder (or their agent) is prohibited from disseminating publicity 

for nonfederal fundraisers that contains a solicitation of funds outside the limitations or prohibitions of the 

Act or of Levin funds. 300.64(c)(3)(vi).

3. Supporting Independent Expenditure-Only Political Committees

Political committees that make only independent expenditures may solicit and accept unlimited 

contributions from individuals, corporations, labor organizations and other political committees. They may 

not accept contributions from foreign nationals, federal contractors, national banks or federally chartered 

corporations. These committees, known as Independent Expenditure-Only Political Committees or IEOPCs, 

must register with the Commission and comply with all applicable reporting requirements of the Act. See 

AO 2010-11 (Commonsense Ten); see also Citizens United v. FEC, 558 U.S. 310, 365 (2010) and SpeechNow.

org v. FEC, 599 F.3d 686 (D.C. Cir. 2010).

Federal candidates and officeholders may raise funds on behalf of IEOPCs so long as they only solicit funds 

subject to the Act’s amount limitations and source prohibitions—i.e. up to $5000 from individuals (and any 

other source not prohibited by the Act from making a contribution to a political committee).7

Additionally, federal candidates and officeholders may attend, speak at and be featured guests at fundraisers 

for IEOPCs at which unlimited individual, corporate and labor organization contributions are solicited, 

so long as they restrict any solicitation they make to funds subject to the limitations, prohibitions and 

reporting requirements of the Act. AO 2011-12 (Majority PAC and House Majority PAC). See 300.64(b)(1) 

and (2).

4. Supporting Tax-Exempt Organizations

General rule for solicitations

A federal candidate, officeholder or his or her agents may make solicitations for certain tax-exempt 

organizations. The regulations regarding solicitations for tax-exempt organizations differ depending 

on whether the funds solicited will be used for certain federal election activities and whether the 

organization’s principal purpose is to conduct federal election activity.

7 Individuals who are “agents” of federal candidates may solicit nonfederal funds on behalf of IEOPCs if the individuals act in their 

own capacities exclusively on behalf of the IEOPC, not on the authority of the candidates, and raise funds on behalf of the candidates 

and IEOPCs at different times. See AOs 2015-09 (Senate Majority PAC and House Majority PAC) at 7, 2003-10 (Reid), 2007-05 

(Iverson).
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Appendix E

Limits and prohibitions on solicitations

General solicitations

A federal candidate or officeholder (or individual acting on behalf of either) may make a general solicitation 

on behalf of a 501(c) tax-exempt organization, or an organization that has applied for this tax status, 

without limits on the source or amount of funds, if:

• The organization does not engage in activities in connection with elections; or

• It is not the principal purpose of the organization to conduct election activities, including certain 

federal election activity, and the solicitation is not to obtain funds for activities in connection with an 

election, including certain federal election activity.

300.65(a) and (c).

Specific solicitations for federal election activity

A federal candidate or officeholder (or individual acting on behalf of either) may also make a specific 

solicitation explicitly to obtain funds to pay for federal election activities conducted by or for a tax-exempt 

organization whose principal purpose is to undertake such activities. The federal election activities for 

which such a specific solicitation may be made are limited to:

• Voter registration activity during the period that begins 120 days before the date of a regularly 

scheduled federal election and ends on the day of that election; and

• Voter identification, get-out-the vote or generic campaign activity conducted in connection with 

an election in which a federal candidate appears on the ballot (regardless of whether a state or local 

candidate also appears on the ballot). See 100.24, 100.25 and 300.65(c).

When making specific solicitations for a tax-exempt organization, the candidate may solicit only individuals 

and may solicit no more than $20,000 per calendar year from each contributor. 300.65(b).

General prohibition

Federal law permits solicitations by federal candidates and officeholders only for the specific federal 

election activities listed in the previous section. These individuals must not make any solicitations on 

behalf of a 501(c) organization, or an organization that has applied for this tax status, for any other types 

of election activities, such as public communications promoting, supporting, attacking or opposing federal 

candidates. 300.65(d).

Safe harbor

• To determine whether a 501(c) organization is not one whose principal purpose is to conduct 

election activities, a federal candidate or officeholder or their agent may obtain and rely upon a 

written certification, signed by an officer or other authorized representative of the organization with 

knowledge of the organization’s activities, stating that:

• It is not the organization’s principal purpose to engage in election activities, including the types of 

election activity previously described; and

• The organization does not intend to pay debts incurred from expenditures or disbursements in 

connection with an election for federal office (including for federal election activities) in a prior 

election cycle.

If the federal candidate or officeholder (or an agent of either) has actual knowledge that the certification is 

false, then the certification may not be relied upon. 300.65(e) and (f).
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Appendix F

Lobbyist Bundled Contributions

The Honest Leadership and Open Government Act of 2007 (HLOGA),1 requires candidate committees to 

disclose information about lobbyists, registrants and lobbyist/registrants PACs that provide two or more 

bundled contributions that exceed the reporting threshold within a covered period. 104.22(b)(1).2

1. What is a Bundled Contribution?

A “bundled contribution” is a term of art for a certain type of contribution triggering special reporting 

requirements. 104.22(a)(6). There are two types of bundled contributions:

Type 1: Contributions forwarded by the lobbyist/registrant or lobbyist/

registrant PAC

The first type of bundled contribution is a contribution forwarded from the contributor(s) to the 

candidate committee by a lobbyist/registrant or lobbyist/registrant PAC. 104.22(a)(6)(i). The 

contribution may be delivered or transmitted by physical or electronic means to the candidate committee 

by the lobbyist/registrant or lobbyist/registrant PAC, or by any person that the candidate committee 

knows to be forwarding such a contribution on behalf of a lobbyist/registrant or lobbyist/registrant PAC. 

104.22(a)(6)(i). Contributions forwarded electronically include contributions received by a lobbyist/

registrant or lobbyist/registrant PAC in the form of checks that are deposited into the lobbyist/registrant 

or lobbyist/registrant PAC’s account and then transmitted electronically to the candidate committee. A 

lobbyist/registrant or lobbyist/registrant PAC may also receive contributions via credit card, debit card 

or electronic check, and then transmit the contributions in the form of a check or via credit card to the 

candidate committee.3

Note that a contribution delivered by a lobbyist/registrant’s or lobbyist/registrant PAC’s employee, 

colleague, friend or courier service falls under this provision if the candidate committee knows that the 

contribution is being forwarded on behalf of the lobbyist/registrant or lobbyist/registrant PAC.

Contributions forwarded by a prohibited source

Under the Lobbying Disclosure Act of 1995 (LDA),4 lobbyist/registrants may include lobbying 

organizations that would be prohibited sources of contributions under FECA (e.g. corporations, labor 

organizations, federal government contractors). Candidate committees may not accept contributions 

from, or that have been forwarded by, a prohibited source; however, candidate committees may give 

credit to a lobbyist/registrant who is a prohibited source (see “Type 2,” next). 110.6(b)(2)(ii), 110.20, 

114.2, 115.2.

1 Honest Leadership and Open Government Act of 2007, Pub. L. No. 110-81, 121 Stat. 735.

2 Although HLOGA requires all authorized candidate committees, Leadership PACs and party committees (reporting committees) 

to disclose information about certain lobbyist bundled contributions, this guide will only address candidate committees that receive 

lobbyist bundled contributions. For more information on party committees and Leadership PACs that receive lobbyist bundled 

contributions, please consult the FEC website.

3 See Reporting Contributions Bundled by Lobbyists, Registrants and the PACs of Lobbyists and Registrants, 74 Fed. Reg. 7285, 

7292 (Feb. 17, 2009), available on FEC.gov.

4 Lobbying Disclosure Act of 1995 (LDA), Pub. L. No. 104-65, 109 Stat. 691.
180

Appendix F

Type 2: Contributions credited to the lobbyist/registrant or lobbyist/registrant 

PAC

The second type of bundled contribution covers contributions received by the candidate committee from a 

contributor but credited to the lobbyist/registrant or lobbyist/registrant PAC through records, designations 

or other means of recognizing that a certain amount of money has been raised by the lobbyist/registrant 

or lobbyist/registrant PAC. 104.22(a)(6)(ii). In this case, the contribution must be 1) received by the 

candidate committee and 2) credited to a lobbyist/registrant or lobbyist/registrant PAC to satisfy the 

definition of bundled contribution.

Crediting contributions

Crediting recognizes that a certain amount of money has been raised by the lobbyist/registrant or lobbyist/

registrant PAC. 104.22(a)(6)(ii). Examples of crediting include:

• Maintaining records or using any method to retain written evidence pertaining to the committee’s 

crediting. Records include paper, electronic, digital, audio, and video records, and records in any other 

format, including informal items such as hand-written notations on a business card.5 104.22(a)(6)(ii)

(A).

• Providing designations and other benefits to the lobbyist/registrant or lobbyist/registrant PAC, 

including giving honorary titles, tracking identifiers, access or invitations to events for people who 

raised a certain amount of money, mementos such as photographs with the candidate and autographed 

copies of books authored by the candidate. 104.22(a)(6)(ii)(A).

Crediting a prohibited source

As discussed previously, under the LDA, lobbyist/registrants may include lobbying organizations that 

would be prohibited sources of contributions under FECA (e.g. corporations, labor organizations, federal 

government contractors). Candidate committees may give credit to a lobbyist/registrant who is a prohibited 

source, however candidate committees may not accept contributions from, or that have been forwarded by, 

a prohibited source. 110.6(b)(2)(ii), 110.20, 114.2, 115.2.

Contributions from a lobbyist/registrant or lobbyist/registrant PAC

Note that the definition of “bundled contribution” does not include contributions made by a lobbyist/

registrant PAC or from the personal funds of the lobbyist/registrant who forwards or is credited with 

raising the contributions or from the personal funds of that lobbyist/registrant’s spouse. 104.22(a)(6)(iii).

5 See Reporting Contributions Bundled by Lobbyists, Registrants and the PACs of Lobbyists and Registrants, 74 Fed. Reg. 7285, 7293 

(Feb. 17, 2009), available on FEC.gov.
181

Lobbyist bundled contributions

2. Who are Lobbyist/

Registrants and 

Lobbyist/Registrant 

PACs?

A lobbyist/registrant is a person 

who, at the time a contribution 

is forwarded or received, is a 

current registrant under Section 

4(a) of the LDA; or an individual 

who is named on a current 

registration or report filed under 

Section 4(b)(6) or 5(b)(2)(C) of 

the LDA.6 104.22(a)(2).

A lobbyist/registrant PAC is any political committee that a lobbyist/registrant established or controls. 

100.5(e)(7) and 104.22(a)(3). For the purposes of these rules, a lobbyist/registrant “established or 

controls” a political committee if he or she is required to make a disclosure to that effect to the Secretary 

of the Senate or Clerk of the House of Representatives under the LDA. 104.22(a)(4)(i). If a political 

committee is not able to obtain definitive guidance from the Senate or House regarding whether it is 

established or controlled by a lobbyist or registrant under the LDA, then it must consult additional criteria 

in FEC regulations at 104.22(a)(4)(ii). Under these criteria, a political committee is a lobbyist/registrant 

PAC if:

• It is a separate segregated fund whose connected organization is a current registrant under the LDA, 

104.22(a)(4)(ii)(A); or

• A lobbyist/registrant had a primary role in the establishment of the committee or directs the 

governance or operations of the committee. Note that the mere provision of legal compliance services 

or advice by a lobbyist/registrant would not by itself meet these criteria. 104.22(a)(4)(ii)(B)(1) and 

(2).

Identifying lobbyists/registrants or lobbyist/registrant PACs

In order for a candidate committee to determine whether a person is reasonably known to be a lobbyist/

registrant or a lobbyist/registrant PAC, the candidate committee is required to consult the websites of the 

Clerk of the House, the Secretary of the Senate and the FEC. 104.22(b)(2)(i).

If the candidate committee does not find the name of the person for whom it is searching it may retain 

a computer printout or screen capture from each website indicating that the name of the person or PAC 

sought was not listed in the results of the search. This will constitute conclusive evidence that the candidate 

committee consulted the websites and did not find the name sought. 104.22(b)(2)(ii). Note that these are 

not the exclusive means by which the candidate committee may provide evidence that it has consulted the 

websites and not found the name of the person sought.

Additionally, a candidate committee is subject to the reporting requirements if it has actual knowledge that, 

at the time a contribution was forwarded or received, the person whose name is sought was required to be 

listed on any registration or report under the LDA. 104.22(b)(2)(iii).

6 For more information on the LDA or for registration and filing requirements under the LDA, contact the Secretary of the Senate or 

the Clerk of the House of Representatives.

5. TYPE OF REPORT

(Choose One)

(a) Quarterly Reports:

12-Day Primary (12P) General (12G) Runoff (12R) PRE-Election

Report for the: Convention (12C)

30-Day

POST-Election General (30G) Runoff (30R) Special (30S)

Report for the:

(b) Monthly 

Report 

Due On:

Feb 20 (M2) May 20 (M5) Aug 20 (M8)

Mar 20 (M3) Jun 20 (M6) Sep 20 (M9)

Apr 20 (M4) Jul 20 (M7) and/or

Semi-annual Report Oct 20 (M10) Jan 31 (YE) and/or

Semi-annual Report

6. Covered Period(s)

through

April 15 

Quarterly Report (Q1)

July 15 

Quarterly Report (Q2)

and/or Semi-annual Report

October 15 

Quarterly Report (Q3)

January 31 

Year-End Report (YE)

and/or Semi-annual Report

July 31 Mid-Year 

Report (Non-election 

Year - PAC/Party) (MY)

and/or Semi-annual Report in the 

Election on State of

in the 

Election on State of

(c)

Nov 20 (M11)

Dec 20 (M12) (Non-Election Year Only) 

(d)

M M / D D / Y Y Y Y

M M / D D / Y Y Y Y

M M / D D / Y Y Y Y

and/or January 1 - June 30

July 1 - December 31

M M / D D / Y Y Y Y

This report also covers 

the semi-annual period Special (12S)

See Line 6(b)

See Line 6(b)

This report also covers 

the semi-annual period

(Non-Election Year Only) 

(a) Quarterly/Monthly/Pre-/Post-Election Covered Period (b) Semi-annual Covered Period

This report covers 04 01 2022 06 30 2022 X

X

F–1: Reporting bundled contributions
182

Appendix F

Table 2: Form 3L Covered Periods and Filing Deadlines for Quarterly Filers

3. Filing Reports

Reporting threshold

Candidate committees must file Form 3L if they have received two or more bundled contributions (as 

defined in Section 1), forwarded by or credited to a particular lobbyist/registrant or lobbyist/registrant 

PAC, that aggregate in excess of the reporting threshold within a covered period. The threshold is indexed 

for inflation annually. The reporting threshold for 2021 is $19,300. 104.22(b)(1) and (g) and 110.17(e)(2) 

and (f).

Covered periods

The covered periods for disclosing lobbyist bundling activity include the semi-annual periods of January 

1 through June 30, and July 1 through December 31, plus the periods that coincide with a candidate 

committee’s quarterly campaign finance reporting schedule under 104.5. 104.22(a)(5). See chart later in 

this appendix.

Quarterly filing schedule

• Semi-annual periods of January 1 through June 30, and July 1 through December 31;

• Quarters beginning on January 1, April 1, July 1, October 1;

• Any applicable pre/post-election reporting periods;

• Any applicable special election reporting periods; and

• A year-end report.

Pre- and Post-election reports

A candidate committee must file Form 3L for the pre- and post-election reports if it receives bundled 

contributions in excess of the reporting threshold during those periods. 104.22(a)(5)(ii).

Special and run-off election reports

Candidate committees that receive two or more bundled contributions from a lobbyist/registrant or 

lobbyist/registrant PAC in connection with a special or run-off election that aggregate more than the 

Report Covered Period Filing Date

First quarterly January 1 – March 31 April 15

Second quarterly April 1 – June 30 July 15

First semi-annual January 1 – June 30 July 15

Third quarterly July 1 – September 30 October 15

Year-end October 1 – December 31 January 31

Second semi-annual July 1 – December 31 January 31

Pre/post-election (if necessary) See FEC’s Dates and Deadlines page

for reporting dates)
183

Lobbyist bundled contributions

reporting threshold must file FEC Form 3L at the same time that the candidate committee files its report 

for the special or run-off election. The covered period for reporting bundled contributions in connection 

with a special or run-off election is the same as the reporting periods for special and run-off elections under 

104.5(h). 104.22(a)(5)(v).

Reporting by certain presidential committees

Most candidate committees file on a quarterly schedule in all years. However, presidential campaign 

committees that have, as of January 1 of the election year, received or anticipate receiving $100,000 or more 

in contributions or have made or anticipate making $100,000 or more in expenditures file FEC reports on a 

monthly basis. 104.5(b)(1). For these committees, the covered periods are:

During an election year:

• Semi-annual periods of January 1 through June 30, and July 1 through December 31;

• Monthly reporting periods (report due on the 20th of each month);

• Pre/post-election reporting periods (in lieu of November and December reporting periods);

• Any applicable special election reporting periods; and

• A year-end report.

During a non-election year:

• Semi-annual periods of January 1 through June 30, and July 1through December 31;

• Monthly reporting periods (report due on the 20th of each month) or quarterly reporting periods, 

based on the regular filing schedule under 104.5(b)(2);

• Any applicable special election reporting periods; and

• A year-end report.

Monthly filers may elect to file form 3L on a quarterly basis by notifying the Commission in writing, but 

may only change their filing schedule once per year. 104.22(a)(5)(iv). See Chapter 12.

Form 3L

Each candidate committee must file Form 3L if it has received two or more bundled contributions (as 

described in Section 1), forwarded by or credited to a particular lobbyist/registrant or lobbyist/registrant 

PAC, aggregating in excess of the reporting threshold during any covered period. 104.22(b)(1). The report 

must include:

• The name and address of the lobbyist/registrant or lobbyist/registrant PAC;

• The employer (if an individual); and

• The aggregate amount of bundled contributions forwarded by or received and credited to each lobbyist/

registrant or lobbyist/registrant PAC during the covered period.

Candidate committees must file Form 3L with the first campaign finance report that they file following the 

end of each covered period. 104.22(e).

Example: Lenny Kosnowski, a registered lobbyist for the Schotz Brewing Company, forwards four checks 

for $5,800 each (none are from Kosnowski or his spouse) to a candidate committee on July 1, 2021. The 

committee, a quarterly filer, must file Form 3L because the candidate committee received two or more 

bundled contributions from a registered lobbyist during the covered period aggregating in excess of the 

$19,300 disclosure threshold. Note that the committee reports bundled contributions received during 

the October quarterly period (July 1-September 30) as well as during the second semi-annual covered 
184

Appendix F

period (July 1-December 31). The 

second semi-annual covered period 

information is reported with the 

committee’s Year-End report. (See 

example F–2.)

Returned or refunded 

contributions

If a bundled contribution is not 

deposited and is returned, then 

it does not aggregate toward the 

reporting threshold for disclosure of 

bundled contributions and it is not 

reported on Form 3L. On the other 

hand, if the bundled contribution 

is received, deposited and later refunded, then the bundled contribution aggregates toward the reporting 

threshold for the covered period in which it was received, and must be reported on Form 3L if the reporting 

threshold is exceeded for that covered period. If the receipt of the bundled contribution is reported on 

Form 3L, then the refund of the bundled contribution should also be reported on Form 3L for the covered 

period in which the refund occurred.7

Where to file

Candidate committees file reports and statements with the Federal Election Commission, 1050 First Street 

NE, Washington, DC 20463. 52 U.S.C. § 30102(g); 104.22(d).

Recordkeeping

Candidate committees must maintain records of any bundled contributions forwarded by or received 

and credited to a lobbyist/registrant or lobbyist/registrant PAC that aggregate in excess of the reporting 

threshold for any covered period for three years after filing. 104.22(f).

Co-hosted fundraisers

Co-hosted fundraising events will be treated like any other fundraising activity– candidate committees 

must disclose the actual amounts of all bundled contributions credited to, or forwarded by, a lobbyist/

registrant or lobbyist/registrant PAC, that aggregate in excess of the reporting threshold within the relevant 

covered period. Note that contributions forwarded by a lobbyist/registrant or lobbyist/registrant PAC at a 

co-hosted fundraiser count as contributions bundled by the lobbyist/registrant or lobbyist/registrant PAC 

that forwarded the contributions, regardless of whether the lobbyist/registrant or lobbyist/registrant PAC is 

a co-host of the fundraiser or an attendee.8

7 See Reporting Contributions Bundled by Lobbyists, Registrants and the PACs of Lobbyists and Registrants, 74 Fed. Reg. 7285, 7298 

(Feb. 17, 2009), available on FEC.gov.

8 See Reporting Contributions Bundled by Lobbyists, Registrants and the PACs of Lobbyists and Registrants, 74 Fed. Reg. 7285, 7298 

(Feb. 17, 2009), available on FEC.gov.

A. Full Name of Lobbyist/Registrant (Last, First, Middle Initial) or Lobbyist/Registrant PAC

Mailing Address

City State Zip Code 

Name of Employer 

FEC ID number of Lobbyist/Registrant

PAC, if applicable. C

SCHEDULE A (FEC Form 3L)

REPORTABLE BUNDLED CONTRIBUTIONS FORWARDED BY OR CREDITED TO

LOBBYISTS/REGISTRANTS AND LOBBYIST/REGISTRANT PACs

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions 

or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITTEE (In Full)

Semi-annual Covered Period

Reportable Bundled Contributions during:

Quarterly / Monthly / Pre-Election 

or Post-Election Covered Period

, , .

Doe for Congress Committee

Kosnowski, Lenny

100 Knapp Street, Apt. 1A

Milwaukee WI 00000 19,200.00

19,200.00 Schotz Brewing Company

F–2: Reporting bundled contributions (Schedule A)
185

Lobbyist bundled contributions

Examples: 

Note: In each of these examples, the candidate committee must check the appropriate websites to 

determine whether the individuals who have forwarded or are credited with raising the funds are 

lobbyist/registrants.9 If the candidate committee knows that the person forwarding contributions is 

doing so on behalf of a lobbyist/registrant or a lobbyist/registrant PAC, disclosure will be triggered 

where the contributions exceed the threshold in a covered period. Also, where disclosure is triggered in 

each example, the committee must disclose the bundled contributions on FEC Form 3L twice, once on 

the report for the monthly or quarterly covered period, as applicable and a second time on the report 

covering the semi-annual covered period.10

• A fundraising event is co-hosted by registered Lobbyists A, B and C. The event generates $20,000 in 

contributions, none of which are forwarded contributions. The candidate committee believes that 

Lobbyist A raised the entire $20,000 and thus credits Lobbyist A with the entire $20,000 raised at 

the event, and does not credit Lobbyists B or C. The candidate committee must disclose the $20,000 

that has been credited to Lobbyist A. The candidate committee need not disclose any information 

regarding Lobbyist B and C, because neither Lobbyist B nor C has been credited with any bundled 

contributions.

• A fundraising event is co-hosted by registered Lobbyists A and B, as well as three non-lobbyist 

hosts. The event generates $20,000 in contributions, none of which are forwarded contributions. 

The candidate committee gives each host credit for raising $20,000. The candidate committee must 

disclose the $20,000 of bundled contributions that has been credited to Lobbyist A and also report 

the $20,000 of bundled contributions that has been credited to Lobbyist B because the candidate 

committee has credited the full amount to each lobbyist. The candidate committee may, if it chooses, 

include a memo entry in the space provided on FEC Form 3L to indicate that, although only a total of 

$20,000 was raised at the event, that full $20,000 was credited to each of the co-hosts.

• A fundraising event is co-hosted by registered Lobbyist A and several non-lobbyist hosts. Registered 

Lobbyist B (who is not a co-host of the fundraiser) approaches the candidate for whom funds are 

being raised and hands the candidate $20,000 in contributions from other individuals. Because 

these are contributions that have been “forwarded” by Lobbyist B, the candidate committee must 

disclose the $20,000 of bundled contributions that were forwarded by Lobbyist B irrespective of any 

amount of credit given to Lobbyist B. If the candidate committee also credits Lobbyist A, a co-host 

of the fundraiser, $20,000 for having raised the contributions forwarded by Lobbyist B (because the 

contributions were received during the fundraising event), the candidate committee must then also 

disclose that $20,000 of bundled contributions has been credited to Lobbyist A. Even though the 

candidate committee must disclose the entire $20,000 as having been forwarded by Lobbyist B, the 

candidate committee must also report that same $20,000 of bundled contributions has been credited 

to Lobbyist A.

9 Lobbyist/registrants are listed with the Clerk of the House and the Secretary of the Senate. If contributions are forwarded by a 

PAC, the candidate committee must check the FEC website to determine whether the committee is a lobbyist registrant PAC. See 

Section 2 for details.

10 For additional examples, see Reporting Contributions Bundled by Lobbyists, Registrants and the PACs of Lobbyists and 

Registrants, 74 Fed. Reg. 7285, 7296-7 (Feb. 17, 2009), available on FEC.gov
186

Appendix F

Lobbyist bundled contributions v. earmarked contributions

Note that the lobbyist bundling regulations do not change a candidate committee’s reporting obligations 

under the rules for earmarked contributions. Candidate committees that receive earmarked contributions 

through a conduit are still required to report such conduit activity on their regularly scheduled FEC report. 

52 U.S.C. § 30102(g); 110.6(c)(1)(ii) and (c)(2). For more information on earmarked contributions, see 

Appendix A.

In addition to filing regularly scheduled FEC reports, a candidate committee must file Form 3L if it received 

two or more bundled contributions from a lobbyist/registrant or lobbyist/registrant PAC aggregating in 

excess of the reporting threshold during the covered periods.
187

Appendix G

Compliance with Other Laws

In addition to complying with the Federal Election Campaign Act, campaigns must observe laws and rules 

outside the Commission’s jurisdiction. This appendix lists some of the laws that affect the activities of 

candidates, political committees and federal officeholders. The FEC has no jurisdiction over these laws.

1. Ethics in Government Act/Personal Finance Reports

The Ethics in Government Act requires all candidates to file reports on personal finances. See 5 U.S.C. App. 

4 §§101-111.

• Senate candidates file forms with the Senate Select Committee on Ethics, 220 Hart Senate Office 

Building, Washington, DC 20510 (phone: 202/224-2981).

• House candidates file forms with the Clerk of the U.S. House of Representatives, Legislative Resource 

Center, 135 Cannon House Office Building, Washington, DC 20515-6612. For forms, questions or more 

information, contact the Committee on Ethics at (202) 225-7103.

• Presidential and Vice Presidential candidates (except the incumbent President and Vice President1).

file their personal financial disclosure forms with the FEC. The Commission is the agency responsible 

for public disclosure of those forms. However, detailed review and approval of those forms is the 

responsibility of the Office of Government Ethics (phone: 202/482-9300).

2. House and Senate Rules

The U.S. Senate and House each have rules regulating activity of incumbent Senators and Representatives. 

Contact the Senate Select Committee on Ethics or the House Committee on Ethics (addresses given in 

Section 1).

3. Ballot Access Rules

State laws and procedures govern how candidates come to appear on election ballots. For information, 

individuals should contact the chief election official in their state. (See the FEC’s Combined Federal/State 

Disclosure and Election Directory, available at FEC.gov for contact information.)

4. Tax Laws

Campaigns should be aware that they have to comply with federal and state laws on income tax. For 

information on federal tax laws, contact the Internal Revenue Service, 1111 Constitution Avenue, NW, 

Washington, DC 20224, Attention: EEO (phone: 877/829-5500).

Committees that need to obtain a taxpayer ID number should call 800/TAX-FORM (800/829-3676) or 

visit IRS.gov for information. Each regional IRS office also has a toll-free number; consult your telephone 

directory for the number in your state. Campaigns should also consult the appropriate state agency for 

information on state income tax laws.

1 The incumbent President and Vice President file their personal financial disclosure forms directly with the Office of Government 

Ethics.
188

Appendix G

5. Communications Act

For information on rules concerning rates for purchasing broadcast time, equal access to broadcast media, 

and procedures for filing complaints in this area, contact the Federal Communications Commission, Mass 

Media Bureau, Political Programming Staff, 445 12th Street, SW, Washington, DC 20554 (phone: 888/225-

5322 or 202/418-1440).

6. Hatch Act

For information on the Hatch Act, which regulates political activity by federal employees, contact the Office 

of Special Counsel, U.S. Merit Systems Protection Board, 1730 M Street, NW, Suite 218, Washington, DC 

20036-4505 (phone: 800/854-2824 or 202/804-7002).
189

Appendix H

Glossary

Act – The Federal Election Campaign Act of 1971, as amended (52 U.S.C. §§30101-30145). 100.18. Prior to 

September 1, 2014, the Act appeared in Title 2 of the U.S. Code. A conversion table is available on FEC.gov.

Advisory opinion (AO) – A formal response from the Commission regarding the legality of a specific 

activity proposed in an advisory opinion request (AOR). Part 112. For information on requesting an AO, see 

page ii.

Affiliated committees – Committees and organizations that are considered one committee for purposes 

of the contribution limits. 110.3(a)(1). Affiliated committees include (1) All committees established or 

authorized by a candidate as part of his or her campaign for federal or nonfederal office; (2) All committees 

established, financed, maintained or controlled by the same corporation, labor organization, person, or 

group of persons. 100.5(g)(1) and (2); 110.3(a)(1).

Agent of federal candidate or officeholder – An agent of a federal candidate or officeholder is any person 

who has actual authority, either express or implied, to engage in any of the following activities on behalf of 

the candidate or officeholder:

• To request or suggest that a communication be created, produced or distributed;

• To make or authorize a communication that meets one or more of the “content standards” for 

coordination. See Appendix D, Section 2;

• To request or suggest that any other person create, produce, or distribute any communication;

• To be materially involved in decisions regarding the content, intended audience, means or mode, media 

outlet, timing, frequency, size, prominence or duration of a communication;

• To provide material or information to assist another person in the creation, production or distribution 

of any communication;

• To make or direct a communication that is created, produced or distributed with the use of material or 

information derived from a substantial discussion about the communication with a different candidate; 

or

• To solicit, receive, direct, transfer or spend funds in connection with any election.

109.3(b) and 300.2(b)(3).

Authorized committee – Any political committee, including the principal campaign committee, authorized 

in writing by a federal candidate to receive contributions and make expenditures on his or her behalf. 

100.5(f)(1). Authorized committees are often called “candidate committees” or “campaign committees.”

Bank – A state bank; a federally chartered depository institution (including a national bank); or a 

depository institution insured by the Federal Deposit Insurance Corporation or the National Credit Union 

Administration. 52 U.S.C. §30102(h)(1).

BCRA – The Bipartisan Campaign Reform Act of 2002, Pub. Law No. 107-155, 116 Stat. 81, which amended 

the FECA.
190

Appendix H

Bundled contribution – A contribution forwarded to a reporting committee by a lobbyist/registrant or 

lobbyist/registrant PAC, or received by a reporting committee and credited to a lobbyist/registrant or 

lobbyist/registrant PAC. See 104.22(a)(6). See also Appendix F.

Campaign – A candidate for a federal office, his or her authorized agents, principal campaign committee 

and any other authorized committees.

Campaign committee – Popular term for an authorized committee.

Candidate – An individual seeking nomination for election, or election, to federal office becomes a 

candidate when he or she (or agents acting on his or her behalf) raise contributions that exceed $5,000 or 

make expenditures that exceed $5,000. 100.3(a).

Candidate committee – Popular term for an authorized committee.

Clear and conspicuous – A disclaimer is clear and conspicuous if it gives the observer adequate notice of 

who paid for the ad, is not difficult to read or hear, and the placement cannot be easily overlooked. The 

specific requirements depend upon the medium used. 110.11(c)(1).

Clearly identified candidate – A candidate is clearly identified when his or her name, nickname, 

photograph or drawing appears or when his or her identity is apparent by unambiguous reference such as 

“the President,” “your Congressman,” or “the incumbent,” or through an unambiguous reference to his or 

her status as a candidate such as “the Democratic presidential nominee” or “the Republican candidate for 

Senate in the State of Texas.” 100.17; 106.1(d).

Commercial vendor – Any person providing goods or services to a candidate or political committee whose 

usual and normal business involves the sale, rental, lease or provision of those goods or services. 116.1(c).

Contribution – A gift, subscription, loan, advance or deposit of money or anything of value given to 

influence a federal election; or the payment by any person of compensation for the personal services of 

another person if those services are rendered without charge to a political committee for any purpose. 

100.52(a) and 100.54. See Chapter 3, “Understanding Contributions.”

Coordinated – Made in cooperation, consultation or concert with, or at the request or suggestion of, a 

candidate, a candidate’s authorized committee or their agents, or a political party committee or its agents. 

109.20.

Coordinated communication – A communication that satisfies a three-pronged test:

• The communication must be paid for by a person other than a federal candidate, authorized 

committee, or a political party committee, or any agents of the aforementioned entities with whom the 

communication is coordinated. (See definition for “Party coordinated communication”);

• One or more of the five content standards set forth in 109.21(c) must be satisfied; and

• One or more of the five conduct standards set forth in 109.21(d) must be satisfied.

• A payment for a communication satisfying all three prongs is an in-kind contribution to the candidate 

or political party committee with which it was coordinated. 109.21. See Appendix D, Section 2.

Coordinated party expenditure – A special type of coordinated expenditure that can be made only by a 

national or state political party committee in connection with the general election of a candidate. These 

coordinated expenditures are subject to a separate set of limits and do not count against the party’s normal 

contribution limits with respect to each candidate. 109.30, and 109.32 through 109.37.
191

Glossary

Corporation – Any separately incorporated entity (other than a political committee that has incorporated 

for liability purposes only). 100.134(l) and 114.12(a). The term corporation covers both for-profit and 

nonprofit corporations and includes nonstock corporations, incorporated membership organizations, 

incorporated cooperatives, incorporated trade associations, professional corporations and, under certain 

circumstances, limited liability companies.

Covered period – For the purposes of 104.22, the covered period for disclosing lobbyist bundling activity 

generally includes the semiannual periods of January 1 through June 30, and July 1 through December 

31, plus the periods that coincide with a reporting committee’s regular quarterly or monthly reporting 

schedule. Note that the covered period may also include the reporting periods for any special or runoff 

elections. Reporting committees that file campaign finance reports on a monthly basis can choose to 

file reports pursuant to the quarterly covered period by notifying the commission in writing. For more 

information, see Appendix F.

Date contribution is made – The date the contributor relinquishes control over a contribution. A 

contribution that is mailed is considered made on the date of the postmark. In the case of an in-kind 

contribution, a contribution is made on the date the goods or services are provided by the contributor. This 

date determines the election limit against which a contribution counts. 110.1(b)(6).

Date contribution is received – The date the campaign (or a person acting on the campaign’s behalf) takes 

possession of the contribution. 102.8(a). This date is used for FEC reporting.

Direct – For purposes of 11 CFR Part 300, to direct means to guide, directly or indirectly, a person who has 

expressed an intent to make a contribution, donation, transfer of funds or otherwise provide anything of 

value, by identifying a candidate, political committee or organization for the receipt of such funds or things 

of value. The contribution, donation, transfer or thing of value may be provided directly or through an 

intermediary. Direction does not include merely providing information or guidance as to the applicability of 

a particular law or regulation. 300.2(n). See Appendix E.

Direct mail – Any mailings made by a commercial vendor or made from a commercial list. 100.87(a), 

100.89(a), 100.147(a) and 100.149(a).

Disbursement – Any purchase or payment made by a political committee or any other person that is 

subject to the Act. 300.2(d).

District or local party committee – Any organization that is part of the official party structure, and is 

responsible for the day-to-day operations of the political party at a level lower than the state level (e.g., city, 

county, ward). 100.14(b).

Donation – A payment, gift, subscription, loan, advance, deposit or anything of value given to a person but 

does not include contributions. 300.2(e).

Draft committee – A political committee established solely to draft an individual or to encourage him or 

her to become a candidate. 102.14(b)(2). See the Campaign Guide for Nonconnected Committees.

Earmarked contribution – A contribution that the contributor directs (either orally or in writing) to or 

on behalf of a clearly identified candidate or authorized committee through an intermediary or conduit. 

Earmarking may take the form of a designation, instruction or encumbrance, and it may be direct or 

indirect, express or implied. 110.6. See also definition for “Bundled contribution” and Appendix A.
192

Appendix H

Election – Any one of several processes by which an individual seeks nomination for election, or election, 

to federal office. They include: a primary election, including a caucus or convention that has authority to 

select a nominee; a general election; a runoff election; and a special election held to fill a vacant seat. 100.2.

Election cycle – The period beginning the day after the previous general election for a given federal office 

and ending on the date of the general election for that office. The number of years in an election cycle 

differs according to the federal office sought. The election cycle spans:

• Two years for House candidates;

• Four years for Presidential candidates; and

• Six years for Senate candidates.

See 100.3(b).

Election year – A year in which there are regularly scheduled elections for federal office (i.e., evennumbered years).

“Established, financed, maintained or controlled” – See Appendix E and 300.2(c) for a list of the factors 

considered by the Commission in determining whether an entity is directly or indirectly established, 

financed, maintained or controlled by, or acting on behalf of, a federal candidate, officeholder or agent. See 

also AOs 2006-04 (Tancredo), 2005-02 (Corzine II) and 2004-33 (Ripon).

Electioneering communication – Any broadcast, cable or satellite communication that (1) refers to a 

clearly identified candidate for federal office; (2) is publicly distributed within certain time periods before 

an election; and (3) is targeted to the relevant electorate. 100.29. See Appendix D.

Expenditure – A purchase, payment, distribution, loan, advance, deposit, or gift of money or anything of 

value made for the purpose of influencing a federal election. A written agreement to make an expenditure is 

also considered an expenditure. 100.111 and 100.112. See Chapter 8.

Express advocacy – Unambiguously advocating the election or defeat of a clearly identified federal 

candidate. There are two ways that a communication can be defined as express advocacy (candidate 

advocacy): by use of certain “explicit words of advocacy of election or defeat” and by the “only reasonable 

interpretation” test. See 100.22. See Appendix D, Section 3, for a full explanation of the two ways that 

express advocacy can be defined.

FECA – The Federal Election Campaign Act of 1971, as amended (52 U.S.C. §§ 30101–30145). 100.18. 

Sometimes referred to as “the Act.”

FEC identification number – Number assigned to a political committee upon registration with the FEC. 

Used for identification purposes with the FEC only, this number is not a taxpayer identification number.

Federal funds – Funds that comply with the limits, prohibitions and reporting requirements of the FECA. 

300.2(g). See Chapters 3, 4 and 5.

Federal office – President, Vice President, Senator and the following members of the House of 

Representatives: Representative, Delegate (the District of Columbia, Guam, American Samoa, Northern 

Mariana Islands, Virgin Islands) and Resident Commissioner (Puerto Rico). 100.4.

Federal officeholder – An individual elected to or serving in the office of President or Vice President of the 

United States, or a Senator or Representative in, or a Delegate or Resident Commissioner, to the Congress of 

the United States. 113.1(c) and 300.2(o).
193

Glossary

Federally permissible funds – Contributions or donations that do not exceed the Act’s limits or come from 

sources prohibited by the Act. See definition for “Federal funds.”

Foreign national – (1) An individual who is not a citizen of the United States or a national of the United 

States and has not been lawfully admitted to the U.S. for permanent residence, as defined in 8 U.S.C. 

§1101(a)(20); or (2) a foreign principal, as defined in 22 U.S.C. §611(b). 110.20(a)(3).

Government contractor – A person who enters into a contract, or is bidding on such a contract, with any 

agency or department of the United States government and is paid, or is to be paid, for services, material, 

equipment, supplies, land or buildings with funds appropriated by Congress. 115.1.

HLOGA – The Honest Leadership and Open Government Act of 2007, Pub. Law No. 110-81, 121 Stat. 735, 

which amended parts of the FECA.

Identification – For purposes of recordkeeping and reporting, a person’s full name and address and, in the 

case of an individual, his or her occupation (principal job title or position) and employer (organization or 

person by whom an individual is employed) as well. 100.12, 100.20 and 100.21.

Identification number – See definition for “FEC identification number.”

Independent expenditure – An expenditure for a communication that expressly advocates the election or 

defeat of a clearly identified candidate and that is not made in cooperation, consultation or concert with, or 

at the request or suggestion of, any candidate, or his or her authorized committees or agents, or a political 

party committee or its agents. 100.16. See Appendix D.

Independent expenditure-only political committees (IEOPCs) – Political committees that make 

only independent expenditures that may solicit and accept unlimited contributions from individuals, 

corporations, labor organizations and other political committees. They may not accept contributions from 

foreign nationals, federal contractors, national banks or federally chartered corporations. See AO 2010-11 

(Commonsense Ten). IEOPCs, popularly known as “super PACs,” must register with the Commission and 

comply with all applicable reporting requirements of the Act. See Appendix E.

In-kind contribution – A contribution of goods, services or property offered free or at less than 

the usual and normal charge. The term also includes payments made on behalf of, but not directly 

to, candidates and political committees (except for independent expenditures or non-coordinated 

communications).100.52(d).

Joint contribution – A contribution made by more than one person on a single check or other written 

instrument. 110.1(k)(1).

Joint fundraising – Fundraising conducted jointly by a political committee and one or more other 

committees or organizations. See Appendix C.

Labor organization – An organization, agency or employee representative committee or plan, in which 

employees participate and which exists for the purpose of dealing with employers on grievances, labor 

disputes, wages, hours of employment or working conditions. 114.1(d).

Leadership PAC – A political committee that is directly or indirectly established, financed, maintained or 

controlled by a federal candidate or officeholder which is neither an authorized committee nor affiliated 

with the candidate’s authorized committee. The term does not include a political party committee. 100.5(e)

(6).
194

Appendix H

Limited liability company (LLC) – A business entity that is recognized as a limited liability company under 

the laws of the state in which it is established. LLCs that are treated as partnerships under the IRS code may 

make contributions. LLCs that have publicly traded stock or are treated as corporations under the IRS code 

are prohibited from making contributions. 110.1(g) See Appendix B.

Lobbyist/registrant – A person who is:

• A current registrant under the Lobbying Disclosure Act, or

• An individual who is named on a current registration or report filed under the Lobbying Disclosure Act. 

See 104.22. See also Appendix F.

Lobbyist/registrant PAC – Any political committee that a lobbyist/registrant “established or controls” as 

defined in 104.22. See Appendix F.

Local party committee – See definition for “District or local party committee.”

Mass mailing – A mailing by U.S. mail or facsimile of more than 500 pieces of mail matter of an identical 

or substantially similar nature within any 30-day period. This does not include electronic mail or other 

internet communications. 100.27. See definition for “Public communication.”

Memo entry – Supplemental or explanatory information on a reporting schedule. The dollar amount 

in a memo entry is not incorporated into the total figure for the schedule. A memo entry is often used 

to disclose additional information about an itemized transaction that is included in the total receipts or 

disbursements for the current report or a previous report.

Memo text – A field offered in FECFile software and some commercial software to allow a committee to 

provide additional text to describe a particular transaction it is reporting.

Multicandidate committee – A political committee that has been registered sat least 6 months, has more 

than 50 contributors and, with the exception of state party committees, has made contributions to at least 5 

candidates for federal office. 100.5(e)(3).

MUR (Matter Under Review) – An FEC enforcement action, initiated by a sworn complaint or by an 

internal administrative action.

National committee – An organization that, by virtue of the bylaws of a political party, is responsible for 

the day-to-day operation of the political party at the national level, as determined by the Commission. 

100.13.

National party committees – Political committees established and maintained by a national political party. 

A party’s national committee, House campaign committee and Senate campaign committee are defined as 

national party committees. 110.1(c)(2). See also AO 2006-36 (Green Senatorial Campaign Committee).

Negative entry – An amount entered on a reporting schedule that is subtracted from the total balance for 

that schedule. Parentheses around a number indicate a negative entry.

Net debts outstanding – The total of a campaign’s unpaid debts incurred with respect to an election plus 

estimated costs to liquidate the debts plus costs of terminating political activity (if appropriate), minus cash 

on hand, and receivables and the amount of personal loans aggregating in excess of $250,000 per election. 

110.1(b)(3)(ii). See Chapter 4, Section 8, “Contributions to Retire Debts.”
195

Glossary

Nonconnected committee – Any committee which conducts activities in connection with an election, 

but which is not a party committee, a candidate’s authorized committee, or a separate segregated fund. 

106.6(a).

Nonelection year – A year in which there is no regularly scheduled federal election (i.e., odd-numbered 

years).

Nonfederal election – An election for a state or local office.

Nonfederal funds – Funds that are not subject to the limitations or prohibitions of the Act. 300.2(k).

Nonpartisan, tax-exempt, debate staging organization – An organization staging candidate debates which 

is exempt from federal taxation under 26 U.S.C. § 501(c)(3) or (4) and which does not support, endorse or 

oppose candidates or political parties. 110.13(a)(1) and 114.4(f).

Ongoing committee – A political committee that has not terminated and does not qualify as a terminating 

committee. 116.1(b).

Operating expenditures – A committee’s day-to-day expenditures for items such as rent, overhead, 

administration, personnel, equipment, travel, advertising and fundraising. 106.1(c).

PAC – Acronym for political action committee; see definition for “Political action committee.”

Party committee – A political committee that represents a political party and is part of the official party 

structure at the national, state or local level. 100.5(e)(4).

Party coordinated communication – A communication that satisfies a similar three-pronged test as 

for a “coordinated communication” (see definition of “Coordinated communication”). The first prong 

requires that the communication be paid for by a political party committee or its agents, and the second 

and third prongs require that one of several content and conduct standards be satisfied. A payment for 

a communication satisfying all three prongs is either an in-kind contribution to, or a “coordinated party 

expenditure” on behalf of, the candidate with whom it was coordinated. 109.37.

Person – An individual, partnership, political committee, association, corporation, labor organization, or 

any other organization or group of persons, not including the federal government. 100.10.

Personal funds of candidate – Generally, assets which an individual had at the time he or she became a 

candidate and had:

• Legal right of access to or control over; and either

• Legal and rightful title; or

• An equitable interest.

Personal funds also include certain categories of income and other funds received by the candidate. 100.33.

Personal use of campaign funds – Any use of funds in a campaign account of a candidate (or former 

candidate) to pay for a commitment, obligation or expense (of any person) that would exist irrespective of 

the candidate’s campaign or responsibilities as a federal officeholder. 113.1(g). See Chapter 8.

Political action committee (PAC) – Popular term for a political committee that is neither a party 

committee nor an authorized committee of a candidate. PACs directly or indirectly established, 

administered or financially supported by a corporation or labor organization are called separate segregated 

funds (SSFs). PACs without such a corporate or labor sponsor are called nonconnected PACs. See definition 

for “financially supported” in “Separate segregated fund.”
196

Appendix H

Political committee – An entity that meets one of the following conditions:

• An authorized committee of a candidate (see definition for “Candidate”).

• A state party committee or nonparty committee, club, association or other group of persons that 

receives contributions or makes expenditures, either of which aggregate over $1,000 during a calendar 

year.

• A local unit of a political party (except a state party committee) that: (1) receives contributions 

aggregating over $5,000 during a calendar year; (2) makes contributions or expenditures either of 

which aggregate over $1,000 during a calendar year; or (3) makes payments aggregating over $5,000 

during a calendar year for certain activities which are exempt from the definitions of contribution and 

expenditure (100.80, 100.87 and 100.89; 100.140, 100.147 and 100.149).

• Any separate segregated fund upon its establishment. 100.5.

Principal campaign committee – An authorized committee designated by a candidate as the principal 

committee to raise contributions and make expenditures for his or her campaign for a federal office. 

100.5(e)(1). See definition for “Authorized committee.”

Prohibited sources – Those entities that are prohibited from making contributions or expenditures in 

connection with, or for the purpose of influencing, a federal election. 110.4(b), 110.20, 114.2 and 115.2. 

See Chapter 5.

Public communication – A communication by means of any broadcast, cable or satellite communication, 

newspaper, magazine, outdoor advertising facility, mass mailing or telephone bank to the general public, 

or any other form of general public political advertising. The term general public political advertising does 

not include communications made over the internet, except for communications placed for a fee on another 

person’s website. 100.26, 100.27 (definition of “Mass mailing”) and 100.28 (definition of “Telephone 

bank”).

Reattributed contribution – The portion of an excessive contribution that has been attributed in writing to 

another contributor and signed by both contributors. 110.1(k)(3)(ii). See Chapter 4, Section 7.

Receipt – Anything of value (money, goods, services or property) received by a political committee.

Redesignated contribution – The portion of a contribution (usually excessive) that has been designated 

by the contributor, in writing, to an election other than the one for which the funds were originally given. 

110.1(b)(5).

Refunded contribution – A contribution is refunded when the recipient committee first deposits 

the contribution and later sends the contributor a check for the entire amount (or a portion) of the 

contribution. See 103.3(b). Compare with definition of “Returned contribution.”

Restricted class – Those persons, including the executive and administrative personnel, members or 

stockholders (and the families of each) within a corporation or labor organization, who may be solicited 

for contributions to the organization’s separate segregated fund at any time and who may receive certain 

communications from the organization. 114.1(j); 114.3(a); 114.5(g); 114.7(a) and (h); and 114.8(c), (h) 

and (i).

Returned contribution – A contribution is returned when the recipient committee sends the original check 

(or other negotiable instrument) back to the contributor, without depositing it. See 103.3(a). Compare with 

definition of “Refunded contribution.”
197

Glossary

Runoff election – An election held after a primary or a general election when no candidate wins the 

previous election. 100.2(d).

Separate segregated fund (SSF) – A political committee established, administered or financially supported 

by a corporation or labor organization, popularly called a corporate or labor political action committee or 

PAC. See 114.1(a)(2)(iii). The term “financially supported” does not include contributions to the SSF, but 

does include the payment of establishment, administration or solicitation costs. 100.6(b).

Solicit – For the purposes of 11 CFR Part 300, to solicit means to ask, request or recommend, explicitly 

or implicitly, that another person make a contribution, donation, transfer of funds or otherwise provide 

anything of value. A solicitation is an oral or written communication that, construed as reasonably 

understood in the context in which it is made, contains a clear message asking, requesting or recommending 

that a person make a contribution, donation, transfer of funds or otherwise provide anything of value. A 

solicitation may be made directly or indirectly. The context includes the conduct of persons involved in the 

communication. A solicitation does not include mere statements of political support or mere guidance as to 

the applicability of a particular law or regulation. 300.2(m). See Appendix E.

Special election – A primary, general or runoff election that is not a regularly scheduled election and that is 

held to fill a vacancy in a federal office. 100.2(f).

State party committee – A committee which, by virtue of the bylaws of a political party or the operation 

of state law is part of the official party structure and is responsible for the day-to-day operation of the 

party at the state level, including an entity that is directly or indirectly established, financed, maintained or 

controlled by that organization, as determined by the Commission. 100.14(a).

Telephone bank – More than 500 telephone calls of an identical or substantially similar nature within any 

30-day period. This does not include e-mail or other internet communications transmitted over telephone 

lines. 100.28 See Appendix D.

Terminating committee – A political committee that is winding down its activities in preparation for filing 

a termination report. A terminating committee has ceased to receive contributions or make expenditures 

(other than for debt retirement purposes or winding down costs). 116.1(a).

Trade association – A membership organization consisting of persons engaged in a similar or related 

line of commerce. A trade association is organized to promote and improve business conditions in that 

line of commerce and not to engage in a regular business for profit. No part of the net earnings of a trade 

association may inure to the benefit of any member. 114.8(a).

Unauthorized committee – A political committee that has not been authorized in writing by any candidate 

to solicit or receive contributions or to make expenditures on behalf of a candidate, or that has been 

disavowed under 100.3(a)(3). 100.5(f)(2).

Unauthorized single-candidate committee – A political committee not authorized by any candidate, which 

makes contributions or expenditures on behalf of only one candidate. 100.5(e)(2) and (f)(2).

Usual and normal charge – With regard to goods provided to a political committee, the term refers to the 

price of those goods in the market from which they ordinarily would have been purchased at the time they 

were provided. With regard to services, the term refers to the hourly or piecework charge for the services at 

a commercially reasonable rate prevailing at the time the services were rendered. 100.52(d)(2).
2–00006