Guideline for 

Presentation in Good Order 

July 2007 

Prepared by 

Audit Division 

Federal Election Commission 

999 E Street, NW 

Washington, DC 20463 

(800)424-9530 

(202)694-1200 
Commissioners 

Robert D. Lenhard, Chair 

David M. Mason, Vice Chairman 

Hans A. von Spakovsky 

Steven T. Walther 

Ellen L.Weintraub 

Statutory Officers 

Patrina M. Clark, Staff Director 

Thomasenia P. Duncan, General Counsel 

The Guideline was revised by: 

Wanda J. Thomas 

Deputy Assistant Staff Director 

(Presidential Election Campaign Fund) 

Audit Division 

202-694-1200 
 

 

Table of Contents 

Introduction 1 

Overview 2 

Chapter I 

Establishment of Eligibility With Threshold Submission I-1 

Chapter II 

Credit Card Contributions II-1 

Chapter III 

Matching Funds Requests III-1 

Chapter IV 

Resubmissions IV-1 

Chapter V 

Standard Exception Codes for Review of Matching Fund Requests V-1 

Chapter VI 

Guidance Regarding Matchability/Non-Matchability of Types of 

Written Instruments/Discrepancies on Contributor Data File VI-1 
GUIDELINE FOR PRESENTATION IN GOOD ORDER 

INTRODUCTION 

The Federal Election Commission’s Guideline for Presentation in Good Order 

(the “Guideline”) is designed for presidential candidates seeking federal matching funds 

as a supplement to financing their primary campaigns for nomination to the Office of the 

President. Candidates who choose this option are required to follow the Guideline in 

order to receive matching fund payments (comprised of voluntary taxpayer check-off 

dollars). See 11 CFR §9033.1(b)(9), 11 CFR §9034.8(a)(2)(i), 11 CFR §9036.1(b)(7), 11 

CFR §9036.2(b) and 11 CFR §9036.5(c). 

 The Guideline serves a twofold purpose. It enables candidates to maximize their 

access to federal matching funds while streamlining the Commission’s task of reviewing 

matching fund requests (submissions) and certifying to the Secretary of the Treasury that 

the candidate has met all of the requirements that entitle him or her to receive matching 

payments. To achieve these objectives, the Guideline sets forth a uniform format for the 

presentation of submissions, together with specifying a quality of content standard that 

must be met after a Matching Fund Request has been accepted for review. In the 

selection and arrangement of materials, the various questions that have arisen in the 

matching fund program during previous primary election cycles have been taken into 

account and addressed. 

The priorities established by the public financing statutes provide that a shortfall 

in the balance of the Presidential Election Campaign Fund will affect the availability of 

matching funds for primary candidates before it affects the financing of general election 

candidates or nominating conventions. See 26 U. S .C. §9006(c), 26 U. S .C. §9008(a), 

and 26 U. S .C. §9037. Accordingly, Treasury rules set aside funds for the nominating 

conventions and general election candidates prior to depositing funds in the Presidential 

Primary Matching Payment Account. See 26 CFR §701.9006-1 and 26 CFR §701.9037-

1. Thus, if a shortage of primary funds occurs in a particular month, the Treasury 

regulations set forth a formula for determining the amount each candidate will receive as 

partial payment and the amount that will be treated as certified for the next month. All 

eligible primary candidates will receive payments on the same day once a month. 

1 
 

GUIDELINE FOR PRESENTATION IN GOOD ORDER 

OVERVIEW 

A matching fund request (or “submission”) is comprised of ten elements1, each of which 

is discussed separately within this Guideline: 

1. A data file containing all information required by and described in this 

Guideline. 

2. Photocopies or digital images of written instruments and where necessary, 

photocopies or digital images of additional documentation signed by the 

contributor for whom a matching amount is being requested.2 

3. Bank Documentation indicating that the listed contributions were 

deposited into a designated depository. 

4. A listing of all contributions returned by the bank as unpayable (NSF) 

regardless of whether submitted for matching, together with photocopies 

or digital images of the written instruments. 

5. A listing of all refunded contributions, regardless of whether submitted for 

matching. 

6. Documentation as described in this Guideline to support the matchability 

of any contribution received as a result of joint fundraising activities. 

7. Documentation as described in this Guideline to support the matchability 

of any contribution received as a result of entertainment events when such 

contributions are submitted. 

8. A certification signed by the Treasurer, that attests to the fact that all 

information/documentation contained in the submission is accurate and 

complete. 

9. Computerized files, if required pursuant to 11 CFR §9036.1 and 11 CFR 

§9036.2. 

1

 Submissions made after a candidate’s date of ineligibility must also contain a statement of net outstanding 

campaign obligations (NOCO statement). See the Financial Control and Compliance Manual for 

instructions on preparing a NOCO statement. 

2

 Documentation requirements for contributions received by credit card are discussed in Chapter II. 

2 
 

10. At least 85% of the contributions submitted must be matchable. (This 

provision is not applicable to submissions made on the last submission 

date in the year preceding the Presidential election or to submissions made 

during the Presidential year until the candidate’s date of ineligibility. 

Each matching fund request submitted must contain elements 1 to 10 for a determination 

of good order to be made and acceptance for review. Where the initial review of a 

matching fund request indicates that more than 15% of the submitted contributions are 

non-matchable, the submission will be returned to the candidate/committee for corrective 

action as detailed within this Guideline. 

In order for a contribution to be considered matchable on its face, it must meet the 

following criteria. Should the criteria not be met, additional documentation will be 

required to make the contribution matchable.3 See Chapter V for documentation 

requirements for contributions requiring additional documentation. 

1. The contribution must be made via a written instrument, i.e.: check (drawn 

on a personal account). Money orders, cashiers checks, and checks drawn 

on non-personal accounts may be matchable if accompanied by additional 

documentation. (11 CFR §9034.2(a)(1)) Credit card contributions may 

also be matchable. (11 CFR §9034.2(b) 

2. The written instrument must be dated, physically received and deposited 

by the candidate or authorized committee(s) on or after January 1, of the 

year preceding the calendar year of the Presidential election but no later 

than December 31 of the year of the election. (11 CFR §9034.2(a)(4)) 

Credit card contributions must also be received and processed during the 

same time frame. 

3. The contribution must be deposited in a designated campaign depository 

maintained by the candidate’s authorized committee(s). (11 CFR 

§9034.2(a)(3)) 

4. The written instrument must be made payable to the candidate or his/her 

authorized campaign committee(s). (11 CFR §9034.2(c) 

5. The account holder whose name appears imprinted on the check must sign 

the written instrument. In the case of joint accounts, the contribution will 

be considered from the account holder who signs the written instrument. 

(11 CFR §9034.2(c)(1)) (See Chapter V, Exception Code C-2 for 

documentation requirements for contributions from partnerships.) 

3

 This criteria does not to apply to credit card contributions. See Chapter II for matchability of credit card 

contributions. 

3 
 

The following types of contributions are not matchable: 

1. Cash contributions. (11 CFR §9034.3(j)) 

2. In-kind contributions. (11 CFR §9034.3(a)) 

3. A subscription, loan, advance or deposit of money, or anything of value. 

(11 CFR §9034.3(b)) 

4. A contract, promise or agreement, whether or not legally enforceable, such 

as a pledge card. The actual contribution that results from the promise or 

the pledge is matchable if it meets the criteria for a matchable contribution 

noted above. (11 CFR §9034.3(c)) 

5. Contributions that are made or accepted in violation of 2 U.S.C. §441a 

(contributions in excess of the individual’s limitation). 

6. Prohibited funds from a corporation or labor organization. (2 U.S.C. 

§441b). See 11 CFR §110.1(g) for rules applying to contributions from 

limited liability companies. 

7. Prohibited funds from a government contractor. (2 U.S.C. §441c) 

8. Funds from a political committee as defined in 11 CFR §100.5 or any 

group of persons other than those named at 11 CFR §9034.2(c)(3). 

9. Prohibited funds from a foreign national. (2 U.S.C. §441e) 

10. Contributions in the name of another. (2 U.S.C. §441f) 

11. Contributions in the form of the purchase price for an item with significant 

intrinsic and enduring value, such as a watch. (11 CFR §9034.3(g)) 

12. Contributions in the form of the purchase price paid for or otherwise 

induced by a chance to participate in a raffle, lottery, or similar drawing 

for valuable prizes. (11 CFR §9034.3(h)) 

13. Contributions that are made by persons without the necessary donative 

intent to make a gift or made for any purpose other than to influence the 

primary election. (11 CFR §9034.3(i)) 

14. Contributions redesignated for a different election or redesignated for a 

legal and accounting compliance fund pursuant to 11 CFR §9003.3. (11 

CFR §9034.3(k)) 

4 
Chapter I ESTABLISHMENT OF ELIGIBILITY WITH THRESHOLD SUBMISSION 

Chapter I 

ESTABLISHMENT OF ELIGIBILITY WITH THRESHOLD SUBMISSION 

A. GENERAL REQUIREMENTS 

To establish eligibility to receive primary matching fund payments, a 20-state 

threshold submission must be presented, either together with, or preceded by, a letter of 

Candidate and Committee Agreements and Certifications as required by 26 U.S.C. 

§9033(a) and 11 CFR §9033.1 and 11 CFR §9033.2 (“9033 Letter”). The 9033 Letter 

(and any amendments) and the data file for the threshold submission will be placed on the 

public record. The threshold submission must contain a list of contributors within each 

of at least 20 states in which the candidate has received contributions, of which the 

matchable portion must total more than $5,000. (11 CFR §9033.2(b)(3)(i)). A threshold 

submission may be submitted at any time after January 1 of the year preceding the 

election year. 

Upon presentation of the threshold submission, the Audit staff will review the 

following for conformance with the Good Order requirements of the Guideline (11 CFR 

§9036.4(b)): 

(1) Computer files, 

(2) Bank Documentation, 

(3) NSF Listing, 

(4) Contribution Refund Listing, 

(5) Documentation Required for Proceeds from Joint 

Fundraising Events, 

(6) Documentation Required for Proceeds from Entertainment 

Events, and 

(7) Committee Treasurer’s Certification 

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Chapter I ESTABLISHMENT OF ELIGIBILITY WITH THRESHOLD SUBMISSION 

If the threshold submission is found to be in Good Order, the candidate/committee 

will be given a receipt for the submission that acknowledges the date on which it was 

presented to the Commission. The threshold submission data file will be placed on the 

public record. 

If the threshold submission has not been prepared as specified by this Guideline, the 

Audit staff, after consultation and with the concurrence of the Office of General Counsel, 

will return the submission to the candidate/committee for correction. 

B. PRESENTATION OF A THRESHOLD SUBMISSION/TIME REQUIRED FOR 

EXAMINATION 

1. The Commission's regulations at 11 CFR §9033.4(b) specify that, during the 

Presidential election year, the Commission will make an eligibility determination 

generally within 15 business days of receipt of a threshold submission unless the 

provisions of this Guideline (failure to establish eligibility) discussed at Section 

P. of this Chapter are applicable. 

2. During the year preceding the Presidential election year, the regulation cited at 1. 

above specifies that an eligibility determination will be made "as soon as 

practicable" after receipt of a threshold submission. 

C. CERTIFICATION OF ELIGIBILITY AND INITIAL PAYMENT 

1. During the year preceding the election year, the Commission will make an 

eligibility determination only. All certifications of eligibility and amounts to be 

paid for submissions received and reviewed during the year preceding the election 

will be certified by the Commission and forwarded to the Secretary of the 

Treasury in December for payment after January l of the year of the election. 

(11 CFR §9036.1(c)(3)). 

2. During the election year (matching payment period), an initial payment of 

$l00,000 will be certified within 10 business days of the Commission’s 

determination of eligibility. (11 CFR §9036.1(c)(2)). 

3. If an initial payment of $l00,000 was certified upon establishment of eligibility 

during the matching payment period, that amount will be deducted from the 

amount certified for the first non-threshold submission. 

D. CANDIDATE AND COMMITTEE AGREEMENTS AND CERTIFICATIONS 

("9033 Letter") 

1. Pursuant to 26 U.S.C. §9033, 11 CFR §9033.1 and 11 CFR §9033.2, each 

candidate/committee seeking federal matching funds must submit a 9033 letter, 

signed by the candidate, to the Federal Election Commission. To ensure that all 

Page I-2 
 

Chapter I ESTABLISHMENT OF ELIGIBILITY WITH THRESHOLD SUBMISSION 

conditions specified in the Presidential Primary Matching Payment Account Act 

and its governing regulations are completely satisfied, a suggested format for the 

9033 Letter appears at Appendix 1. 

a. In the event the candidate/committee changes the person designated to 

receive federal matching funds or the depository into which the payments 

will be deposited, that information must be submitted to the Commission 

prior to the transfer of any federal funds into a new depository. The 

committee treasurer rather than the candidate may sign such an addendum 

to the original 9033 Letter. (11 CFR §9033.1(b)(8)). The United States 

Treasury will transfer funds only into the depository listed on the 

certification that is received from the Commission. 

b. Because all 9033 Letters and any amendments to original letters are 

placed on the public record, the bank account number should not be 

included with the designation of the depository. That information should 

be transmitted separately by the candidate/committee to the U.S. Treasury. 

2. The 9033 Letter may be submitted at any time after January 1 of the year 

preceding the election. (11 CFR §9036.1(a)). It may precede the threshold 

submission or accompany the threshold submission. No threshold submission 

will be accepted for review and no eligibility determination to receive matching 

payments will be made until such time as the candidate has submitted a signed 

9033 Letter which fully satisfies the provisions of 11 CFR §9033.1 and 11 CFR 

§9033.2. 

3. If the 9033 Letter is found to be incomplete, the Audit staff will notify the 

candidate/committee informally after consultation with the Commission’s Office 

of General Counsel. (11 CFR §9039.2(b)). Where the candidate/committee 

agrees to either supplement or replace the incomplete letter as suggested, the 

Commission or its staff will take no further action. The 9033 Letter will be 

deemed to have been received as of the date the appropriate supplemental 

information or appropriate replacement document is received. 

4. If the candidate/committee disputes the staff determination that the 9033 Letter is 

incomplete as submitted, the Commission will provide, in writing, the legal and 

factual reasons for the determination that the letter does not meet the provisions 

of 26 U.S.C. §9033, 11 CFR §9033.1 and 11 CFR §9033.2. Until such time as the 

matter is resolved, the 9033 Letter will be viewed as yet incomplete and the 

threshold submission will not be considered for review. (11 CFR §9033.2(a)(2)). 

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Chapter I ESTABLISHMENT OF ELIGIBILITY WITH THRESHOLD SUBMISSION 

E. FORMAT FOR THRESHOLD SUBMISSION DATA FILE 

1. The data file for the threshold submission must include at least 20 or more states 

selected by the candidate/committee to establish eligibility.4 (The first nonthreshold submission should then include all matchable contributions submitted in 

the threshold submission, except for those identified as non-matchable during the 

threshold submission review. See Appendix 4a for contributor data file layout. 

11 CFR §9036.2(b)(1)).5 

2. The contributor data file must present the contributors by full name (last name, 

first name, middle initial, and suffix, if any) within each selected state. A 

contributor shall be listed in only one state. 

(11 CFR §9036.1(b)(1). 

F. INFORMATION REQUIRED FOR EACH LISTED CONTRIBUTOR 

1. Each contributor must be listed by full name (i.e., last name, first name, middle 

initial, and suffix, if any), with the contributor's residential address. The 

residential address must include the street number and name, city, state and zip 

code. (11 CFR §9036.1(b)(1)(i)). 

2. Contributors whose aggregate contributions to the candidate/committee during an 

election cycle exceed $200 (regardless of whether all of the contributions are 

submitted) must be further identified by occupation (job title) and name of 

employer. (11 CFR §9036.1(b)(1)(ii)). 

3. Contributions submitted for married individuals must be listed separately, even if 

the contribution is received in the form of one check. (11 CFR §9036.3(c)(1)). 

Contributions drawn on accounts maintained by more than one person must 

contain the signature(s) of each accountholder to whom all or a portion of such 

contribution is attributed. The signature may be on the check or accompanying 

supporting documentation. (11 CFR §9034.2(c)(1)). 

4. The full dollar amount of each contribution submitted for matching purposes and 

date (deposit date plus batch number) must be shown. (11 CFR §9036.1(b)(1)(iii) 

and 11 CFR §9036.1(b)(1)(iv)). 

4

 Where possible the Commission suggests that the candidate/committee include 22-23 states from which 

contributions with matchable portions totaling $5,500 - $6,000 have been received to allow for possible 

errors. 

5

 The threshold submission must be viewed as a submission by which eligibility is established rather than a 

request for a payment of matching funds. Regardless of the verified matchable amount, only an initial 

payment of $100,000 is certified if presented and/or reviewed during the matching payment period. 

Page I-4 
 

Chapter I ESTABLISHMENT OF ELIGIBILITY WITH THRESHOLD SUBMISSION 

5. The matchable dollar amount being submitted must be shown for each listed 

contributor. (11 CFR §9036.1(b)(1)(v)). 

6. The correct aggregate dollar amount of contributions, or portions thereof, 

submitted to date for each contributor must be included. (11 CFR 

§9036.1(b)(1)(vi)). 

7. Each contribution must include the date it was deposited and must be referenced 

to and accompanied by a copy of the bank deposit slip on which it was deposited. 

(11 CFR §9036.1(b)(1)(iii) and 11 CFR §9036.1(b)(3)). The deposit date may be 

used as the reference to the bank deposit slip and must appear on the data file as 

well as on the photocopy or digital image of the written instrument. A batch 

number should be added to the deposit date for referencing multiple deposits on 

the same date. 

G. SUMMARY INFORMATION REQUIRED ON DATA FILE OR SEPARATE 

DOCUMENT 

1. The total dollar amount submitted for each selected state, with a grand total for all 

states. 

2. The number of contributors listed in each selected state, with a grand total of all 

contributors. 

3. An explanation of the method used to reference the contributions to the deposit 

slips and bank documentation must be included. 

H. SUPPORTING DOCUMENTATION FOR REQUESTED AMOUNTS 

1. Full-size photocopies of each written instrument or digital images, legible as to 

date, amount, payee and signature, must be submitted in support of each 

contribution that is to be used for establishing eligibility in each state. (11 CFR 

§9036.1(b)(3)). The term "legible" means that the name of the contributor, the 

name of the recipient/payee, and the date and amount of the contribution can be 

read on a good quality photocopy or digital image of the written instrument. If 

the name of the contributor is imprinted on the instrument, a fully legible 

(decipherable as the name of the listed contributor) signature is not required. 

Photocopies or digital images need include only the front of the written 

instrument, except for third party checks, which require a photocopy or digital 

image of both sides of the check attesting to the endorsement to the 

candidate/committee.6

 The documentation required for credit card contributions 

is discussed in Chapter 2, Credit Card Contributions. 

6

 The contributor in these instances is the individual who last specifically endorsed the written instrument 

without qualification to the candidate/committee and who executed the endorsement to the 

candidate/committee in his or her own hand. 

Page I-5 
 

Chapter I ESTABLISHMENT OF ELIGIBILITY WITH THRESHOLD SUBMISSION 

2. Photocopies of the individual written instruments must be grouped into the same 

order as they are listed on each state's alphabetical list. Digital images do not 

have to be segregated alphabetically by contributor within each state. (11 CFR 

§9036.1(b)(3)). 

3. Each photocopy or digital image of the written instrument must be referenced to 

and accompanied by a copy of the deposit slip on which it was deposited. This 

may be accomplished by using the deposit date with a batch number for multiple 

deposits on a single date. 

(11 CFR §9036.1(b)(3)). 

I. BANK DOCUMENTATION 

1. Documentation which indicates that the listed contributions were deposited into a 

designated depository7 must be provided as follows: 

a. Bank validated deposit slips are acceptable and should be obtained for 

recently deposited contributions for which a bank statement may not be 

available at the time the threshold submission is presented. 

b. Non-bank validated deposit slips plus photocopies of bank statements 

showing the deposit are acceptable. (11 CFR §9036.1(b)(4)). 

J. NSF LISTING 

1. An NSF listing, prepared alphabetically by contributors' full name for each 

selected state, of all checks returned by the bank from the committee's inception 

to date as unpaid (NSF, stop-payments, etc.) must be included with the threshold 

submission regardless of whether the item is submitted for matching. (11 CFR 

§9036.1(b)(5)). A bank statement covering a period two weeks beyond the date 

of redeposit must accompany any check that is returned as non-payable and 

redeposited. The NSF listing may be provided in an electronic format. 

a. In the event that recently deposited contributions become non-payable and the 

bank statement is not yet available, a cut-off bank statement should be 

requested and presented with the threshold submission. Once the bank 

statement is available, it should be submitted. 

2. The following information must be included on the NSF listing for all checks 

returned by the bank as non-payable: 

a. Full name and mailing address of the contributor, 

7

 "Designated Depository" means that, at the time of deposit, the depository was designated pursuant to 11 

CFR §103.2. 

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Chapter I ESTABLISHMENT OF ELIGIBILITY WITH THRESHOLD SUBMISSION 

b. Date and amount of the check, and 

c. Deposit and redeposit (where applicable) dates. 

3. A photocopy of each NSF check (both sides) to which a photocopy of the 

associated debit memo is attached and a copy of the relevant bank statement must 

be provided for each item included on the NSF listing. 

4. In the event a debit memo(s) does not identify the specific NSF item, the amount 

shown on the debit memo(s) must be added to the excess $5,000 eligibility 

threshold for each state in order to ensure that no contribution that became nonpayable to the candidate/committee is included as a matchable contribution and 

used to establish eligibility in any state. (For example, if unidentified debit 

memos total $300, the eligibility threshold amount for each State must exceed 

$5,300 rather than $5,000). 

a. Where the bank statement contains a debit memo which may represent a 

contribution that became non-payable which is not included on the NSF 

listing, and by its omission, a copy of the debit memo is not submitted, the 

Audit staff may request, that the candidate/committee provide the information 

in order to clarify that the debit memo resulted for a reason other than a nonpayable contribution. (11 CFR §9039.2(b)). 

5. If no deposited contributions became non-payable by the bank, a statement to that 

effect, signed by the treasurer, will satisfy the Good Order requirements with 

respect to the NSF listing. 

K. CONTRIBUTION REFUND LISTING 

1. A contribution refund listing, prepared alphabetically by the contributors' full 

name for each selected state, of all contribution refunds made by the 

candidate/committee from inception to date must be included in the threshold 

submission regardless of whether the item is submitted for matching. The 

contribution refund listing may be provided in an electronic format. (11 CFR 

§9036.1(b)(6)) 

2. The following information must be included on the contribution refund listing for 

all refunds: 

a. Full name and mailing address of the contributor, 

b. Deposit date/batch number and full amount of contributor’s check for which 

all or a portion was refunded, 

c. Total amount of contributions received from contributor, and 

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Chapter I ESTABLISHMENT OF ELIGIBILITY WITH THRESHOLD SUBMISSION 

d. Amount of refund. 

3. A photocopy of each refunded contributor check must be provided for each item 

included on the contribution refund listing. 

L. DOCUMENTATION TO SUPPORT THE MATCHABILITY OF 

CONTRIBUTIONS RECEIVED AS A RESULT OF JOINT FUNDRAISING OR 

ENTERTAINMENT EVENTS 

1. If contributions received from joint fundraising activities are included, a copy of 

the joint fundraising agreement, signed by representatives of each participating 

candidate/committee, must accompany the threshold submission. (11 CFR 

§9034.2(c)(7)). Contributions received as the result of joint fundraising are 

matchable for only the percentage of each contribution received as stipulated in 

the joint fundraising agreement. (11 CFR §9034.8(c)(1)). In addition, any 

contribution which has been attributed to the candidate/committee in a percentage 

other than the basic percentage contained in the joint fundraising agreement shall 

be accompanied by documentation showing the re-allocation and the basis or 

reason for the re-allocation. 

2. The full amount of the contribution made to the event must be shown on the 

contributor data file, with the allocated amount (or portion to be submitted) to the 

candidate/committee listed as the amount requested. 

3. If contributions from entertainment events are included, a copy of the promotional 

material and a copy of a ticket at each price must accompany the threshold 

submission. (11 CFR §9034.2(c)(5)). The promotional material and tickets must 

clearly indicate that such purchase represents a contribution to the candidate/ 

committee. (11 CFR §9034.2(c)(5)). 

4. If it is not evident from the face of a written instrument (e.g., the name of the 

payee or a notation) that a contribution was received as a result of a joint 

fundraising or entertainment event, the contributor data file must identify the 

contribution as such. 

M. CERTIFICATION FROM COMMITTEE TREASURER REGARDING THE 

COMPLETENESS AND ACCURACY OF INFORMATION SUBMITTED 

1. Each threshold submission must be accompanied by a certification, signed by the 

committee treasurer, which attests to the fact that all information and 

documentation contained in the submission is complete and accurate. (11 CFR 

§104.14). 

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Chapter I ESTABLISHMENT OF ELIGIBILITY WITH THRESHOLD SUBMISSION 

2. The certification shall also include the following information (see example at 

Appendix 2). 

a. Identification of the type of submission (i.e., threshold submission). 

b. Coverage dates of deposits of submitted contributions. 

N. METHOD OF REVIEW AND NOTICE OF RESULTS 

1. Contributions in the threshold submission will be reviewed on a l00% basis, using 

the standard exception codes described in Chapter V of this Guideline until the 

matchable portion of the contributions totaling more than $5,000 have been 

verified in each of 20 States. (In particular, see exception codes H-1, H-4, and H5 regarding types of contributor data file deficiencies prohibited for establishing 

eligibility). 

O. ELIGIBILITY ESTABLISHED8 

1. Where the threshold submission review determines that a candidate's eligibility to 

receive matching funds has been established, the Audit Division will prepare and 

forward an eligibility report for Commission consideration. 

2. If occurring in the year preceding the election, the candidate/committee will be 

notified either by telephone, e-mail or fax within 1 business day after the 

eligibility report has been considered and advised of the Commission's 

determination. A letter will follow which formally advises the 

candidate/committee of the Commission's acceptance and approval of the 

eligibility report. (11 CFR §9036.1(c)). The letter will also notify the 

candidate/committee of the designated submission and resubmission dates to be 

used during the period of eligibility. After notification, the candidate/ committee 

may begin presenting matching fund requests for review once a month. (11 CFR 

§9036.2(a)). However, during the year before the election, only matching fund 

requests for which the requested amount exceeds $50,000 shall be accepted for 

review. (11 CFR §9036.2(c)). 

8 If the candidate's submission or the submission with the committee's disclosure reports contains patent 

irregularities suggesting the possibility of fraud, the Commission my deny the candidate's eligibility and 

conduct a properly circumscribed investigation under 11 C.F.R. 9039. If, however, there are questions 

about the candidate’s eligibility for public funds that do not rise to the level of patent irregularities 

suggesting the possibility of fraud, the Commission may initially determine that the candidate is eligible 

and conduct an investigation under 11 C.F.R. 9039 to resolve any outstanding questions about the 

candidate's eligibility. The information from an investigation conducted under 11 C.F.R 9039 may be 

used to: 1) determine the candidate's eligibility, 2) suspend additional matching fund payments to a 

candidate, and 3) seek a repayment of public funds that have already been paid to the candidate. 11 C.F.R. 

9039(a)(2). 

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Chapter I ESTABLISHMENT OF ELIGIBILITY WITH THRESHOLD SUBMISSION 

3. Since no payments may be transferred prior to January l of the election year, a 

certification for payment for all submissions reviewed during the year preceding 

the election will be made to the Secretary of the Treasury in December of the year 

before the election. 

4. If eligibility is established during the year of the election, in addition to the steps 

described in O.2. above, a certification of eligibility will be transmitted to the 

Secretary of the Treasury, along with a certification for an initial payment of 

$l00,000 within the ten calendar days as specified at 26 U.S.C. §9036(a) and 11 

CFR §9036.1(c)(2). 

5. The Commission suggests that prior to the initial certification to the Secretary of 

the Treasury, each candidate/committee contact the Office of Financial 

Management Service at the Department of Treasury to arrange for a method of 

payment. The candidate/committee must also transmit by letter to the Department 

of Treasury the bank account number in the designated depository. Any changes 

to the designated depository or account number must be transmitted to the 

Department of Treasury to prevent any delays in the receipt of payments. 

P. FAILURE TO ESTABLISH ELIGIBILITY 

1. If the review of a threshold submission reaches a point where it is determined that 

the candidate/committee has not submitted contributions, the matchable portion of 

which totals more than $5,000, in at least 20 States, the Audit staff will cease the 

review.9 

2. The candidate/committee will be notified by either telephone, e-mail or fax within 

1 business day (followed by written notice) of the results of review for each 

affected state. The Audit Division will prepare the notice after consultation with 

the Office of General Counsel. (11 CFR §9039.2(b)). (See example of notices at 

Appendix 3(a) and Appendix 3(b)). 

3. The notice will advise the candidate/committee on each reviewed state in which 

eligibility was not established, the amounts verified as matchable and nonmatchable, the identity of the contributions and the reasons the contributions were 

determined to be non-matchable for purposes of establishing eligibility. Copies 

of the non-matchable written instruments or contributor listings will accompany 

the notice. 

4. Where possible, representatives of the candidate/committee are encouraged to 

meet with the Audit staff regarding the notice(s) and the applicable Guideline 

9

 For example, if contributions from 23 States were submitted, at the point where it is determined that the 

eligibility requirements were not met in 4 States, the review will stop, regardless of whether 1 or 19 States 

remain. 

Page I-10 
Chapter I ESTABLISHMENT OF ELIGIBILITY WITH THRESHOLD SUBMISSION 

requirements in order to expedite the necessary remedial action throughout the 

threshold submission. 

5. The threshold submission, or necessary portions thereof, will be returned to the 

candidate/committee in order that corrections can be made to all submitted states. 

A receipt identifying documents retained by the Audit staff and those returned to 

the campaign shall be prepared and furnished. 

6. The "generally" 15 business day timeframe specified at 11 CFR §9033.4(b) 

becomes extended by the number of business days required by the 

candidate/committee to correct the threshold submission. This extended time 

begins on the date on which the candidate/committee receives the notice(s) for the 

affected states and ends on the date corrections are presented. 

7. A corrected threshold submission may be presented on any business day 

following its return to the candidate/committee. 

8. When a corrected threshold submission is presented, the initial review will be 

limited to the state(s) for which a notice(s) was sent. If that review determines 

that matchable contributions do not exceed $5,000, the procedure specified at 1. 

through 6. above will again be applicable. 

Q. COMMISSION DETERMINATION OF INELIGIBILITY 

1. If after a second opportunity to correct the threshold submission, the 

candidate/committee fails to meet the eligibility requirements, the Audit staff will 

prepare and forward an eligibility report containing a negative recommendation 

for Commission consideration in making its initial determination in the matter. 

(11 CFR §9033.4(b)). 

2. As provided at 11 CFR §9033.4(a)(2), the Commission shall notify the 

candidate/committee of its initial determination regarding the failure to establish 

eligibility to receive primary matching funds. (Also, see 11 CFR §9033.10(b)). 

3. Within 30 calendar days after service of the Commission's initial determination, 

the candidate/committee may satisfy the threshold requirements or submit written 

legal and factual materials to demonstrate that the eligibility requirements have 

been met. (11 CFR §9033.4(a)(2) and 11 CFR §9033.10(c)). 

Page I-11 
SUMMARY STATE ALPHA LISTING - THRESHOLD SUBMISSION ONLY 

SUBMITTED FOR MATCH

STATE10 AMOUNT 

C

ALABAMA $6,500.00 IOWA $7,250.00 

SUMMARY INFORMATION 

1. Total amount of contributions submitted for Threshold Submission 2. Total count of contributors on Threshold Submission 3. Period covered by Threshold Submission 01-010 Summary listing to include all states submitted in Threshold Submission. 

Page I-12 
 

Chapter II CREDIT CARD CONTRIBUTIONS 

Chapter II 

CREDIT CARD CONTRIBUTIONS 

A. INTRODUCTION 

This chapter deals with the matching of contributions made by credit and debit cards 

including those received via the internet, telephone, or by transaction slip. The 

Commission’s regulation at 11 CFR §9034.2 permits the matchability of such 

contributions as long as sufficient safeguards are in place to provide assurances that only 

permissible contributions are submitted for matching. Although the Commission has not 

mandated a particular set of safeguards that must be followed by all campaigns that 

accept contributions made over the internet, Advisory Opinion 1999-09 (See Appendix 

23) contains procedures that the Commission has determined are adequate to meet the 

requirements of the FECA. Also, documentation must be provided to render the 

contributions matchable. 

B. GENERAL REQUIREMENTS 

1. Each category of credit or debit card transaction described below must be 

processed using a credit card processor or credit card company. 

2. A copy of the processing report from the credit card processor or credit card 

company for each contribution batch processed must accompany each 

submission. The processing reports may be submitted either as photocopies or 

digital images Each entry on the report must be referenced to an entry on the 

credit card processor’s or credit card company’s periodic statement. 

3. In addition, each submission must be accompanied by an electronic file that 

contains the information provided by the contributor at the time the contribution 

was made. At a minimum, the file must contain the full name of the contributor, 

the amount of the contribution, the last four digits of the credit card number (do 

not include the card’s expiration date), and the contribution batch number. This 

file is separate from the contributor data file required under 11 CFR 

§9036.1(b)(2). 

4. In addition to the information described above, the submission must contain 

copies of the statements (monthly, biweekly, etc.) provided by the credit card 

processor and/or credit card company for each merchant account used to accept 

any credit or debit card contribution. 

Page II-1 
Chapter II Credit Card Contributions 

5. The submission must also include copies of bank statements for all accounts into 

which the credit or debit card contributions were deposited. 

C. CONTRIBUTIONS RECEIVED VIA THE INTERNET 

1. All contributions made via the Internet shall be subject to billing address 

verification by the credit card company or the candidate’s credit card processor. 

The verification must be based upon, at a minimum, characters from the street 

address and the zip code, and the card expiration date. 

2. The certification letter signed by the treasurer must attest to the fact that a method 

of billing address verification is in place. Further, the treasurer must certify that 

contributions will not be accepted unless the billing address verification system 

reports an exact match with the information provided by the contributor. 

3. A document containing the information input by the contributor onto the 

processing company’s web page must be provided. At a minimum the 

information should include the contributor’s full name, address, the date of the 

contribution, the amount of the contribution, the type of credit or debit card used 

(Visa, MasterCard, American Express, Discover, etc.) and last four digits of the 

contributor’s credit or debit card account number. This document may be 

submitted as either a photocopy or digital image. 

4. A copy (such as a screen scrape) of the electronic form(s) used to process 

contributions made via the internet must be provided to insure that the safeguards 

described in section C.5. below have been adequately addressed. 

5. The method of documenting the permissibility of the contribution must be 

provided to the Commission for review on a case-by-case basis. As noted above, 

although the Commission is not mandating a particular method to document the 

permissibility of these contributions, Advisory Opinion 1995-09 and Advisory 

Opinion 1999-09 include procedures and safeguards that the Commission deems 

adequate. Following is a listing of the acceptable procedures. 

a. The contribution solicitation form on the Web page contains clear and 

conspicuous language that informs the prospective contributor of the 

source restrictions and contribution limitations. This includes, but is 

not limited to, informing the contributor: (1) of the $2,300 contribution 

limitation and (2) that contributions are not permissible from 

corporations, labor unions, and national banks, (including through 

corporate or other entity credit cards) or from persons contributing in 

the name of another; or from foreign nationals and government 

contractors. 

Page II-2 
Chapter II Credit Card Contributions 

b. The prospective contributor will have to successfully complete an 

electronic form and transmit that form to the Committee for 

processing. This form will contain, but not be limited to, the 

contributor’s name as it appears on the credit or debit card, the billing 

address, the last four digits of the credit or debit card number, the 

expiration date of the card, the contributor’s residential address, and 

the amount of the contribution. Should the contributor fail to fully 

complete the form, the form will be rejected and the contributor will 

be prompted to provide the missing information. 

c. To screen for possible corporate or business entity cards, if the address 

provided by the contributor is different than the billing address, the 

contributor will be notified that corporate or business entity credit 

cards are not acceptable and that the contribution must represent 

personal funds. The contributor will have the option of canceling the 

transaction or proceeding. 

d. The contributor will be required to check a series of boxes to confirm 

the legality of the contribution. These will include, but not be limited, 

to: (1) confirmation that the contribution is made from his or her own 

funds and not those of another; (2) the contribution is not made from 

the funds of a corporation, labor organization or national bank; (3) the 

contributor is not a Federal government contractor or foreign national 

(which includes individuals who lack permanent resident status in the 

United States); and (4) the contribution is made on a personal credit or 

debit card for which the contributor has a legal obligation to pay and is 

made neither on a corporate or business entity card nor on the card of 

another. If any information is missing the form will be rejected. 

e. Once the form is successfully completed, the data will be sent directly 

to the credit card processor where the contributor information, 

including the billing address, account number, and expiration date, 

will be verified and the transaction processed. 

D. CONTRIBUTIONS RECEIVED VIA TELEPHONE 

In addition to the information contained in B above, credit or debit card contributions 

made by telephone must be accompanied by and referenced to a statement signed by 

the contributor which includes the contributor’s full name, address, the date of the 

contribution, the amount of the contribution, the type of credit or debit card used 

(Visa, MasterCard, American Express, Discover, etc.) and the last four digits of the 

contributor’s credit card number, and an affirmation that the contribution represents 

the contributor’s personal funds. This statement may be submitted as a photocopy or 

digital image. The statement signed by the contributor will provide assurance of the 

permissibility of the contribution. 

Page II-3 
Chapter II Credit Card Contributions 

E. CONTRIBUTIONS RECEIVED VIA TRANSACTION SLIP 

In addition to the information contained in B. above, the submission must contain a 

copy of the transaction slip signed by the contributor. The copies of the transaction 

slips may be either photocopies or digital images. The copy of the signed transaction 

slip will provide assurance of the permissibility of the contribution. 

F. CREDIT CARD CHARGE BACKS OR DISPUTED CHARGES 

Each submission must contain a listing of all credit or debit card contributions that 

were charged back to the candidate’s accounts or disputed by the cardholder 

regardless of whether the item is submitted for matching. The listing may be 

submitted electronically. Each contribution must be referenced to and accompanied 

by copies of the contribution processing batch report where it was initially deposited 

and to the entry on the credit card processor’s statement or the credit card company’s 

statement where the reversal was posted. 

G. REFUNDED CONTRIBUTIONS 

Each submission must contain a listing of all refunds made by crediting the 

contributor’s credit or debit card account regardless of whether the item is submitted 

for matching. The listing may be submitted electronically. Each contribution refund 

must be referenced to and accompanied by copies of the contribution processing 

batch report where it was initially deposited and to the entry on the credit card 

processor’s statement or the credit card company’s statement where the refund was 

posted. 

Page II-4 
 

Chapter III MATCHING FUND REQUESTS 

Chapter III 

MATCHING FUND REQUESTS 

A. GENERAL INFORMATION 

1. Designated Submission Dates 

Once a candidate's eligibility to receive payments from the Presidential Primary 

Matching Payment Account has been established by the Commission, the 

candidate/committee may begin to present matching fund requests once a month 

on dates designated by the Commission. (11 CFR §9036.6). A matching fund 

request must be submitted by 5:00 P.M. on a designated submission date. During 

the "matching payment period" payments to eligible candidates/committees will 

be certified, upon completion of review, once a month on dates to be determined 

and published by the Commission. 

Although no federal matching payments can be transferred before January l of the 

year of the election, the Commission will accept one matching fund request per 

month that requests in excess of $50,000 for review during the year preceding the 

year of the election. At the conclusion of each review, the candidate/committee 

will be advised of the certifiable amount for each submission. The total amounts 

will be certified to the Secretary of the Treasury in December of the year 

preceding the election with payment made after January l of the year of the 

election. (11 CFR §9036.2(c)). 

2. Final Submission Date 

The final date for presenting a matching fund request is the first Monday in 

March of the year after the election. (11 CFR §9036.6). 

B. DETERMINATION OF GOOD ORDER UPON PRESENTATION 

1. Upon presentation of a matching fund request, the Audit staff will review the (1) 

contributor data file, (2) written instruments/digital images, (3) bank 

documentation, (4) NSF listing, (5) contribution refund listing, (6) documentation 

required for proceeds from joint fundraising, (7) documentation required for 

proceeds from entertainment events, and (8) committee treasurer's certification for 

conformance with the Good Order requirements of the Guideline. (11 CFR 

§9036.4(a)). If found to be in Good Order, the candidate/committee will be given 

Page III-1 
Chapter III MATCHING FUND REQUESTS 

a receipt for the submission which acknowledges the date on which it was 

presented to the Commission. 

2. If the matching fund request has not been prepared as specified by this Guideline, 

the Audit staff, after consultation and with the concurrence of the Office of 

General Counsel, will return the submission to the candidate/committee for 

correction. The candidate/committee will be advised by a notice listing the 

reasons for the determination that the submission was not in Good Order. (See 

example of Notice of Failure to Meet Standards of Good Order at Appendix 5a). 

Where a submission can be corrected and presented within five (5) business days 

after the date on which the determination that the Good Order standards were not 

met, it will be accepted for review. (11 CFR §9036.4(a)(1)). 

3. In order to ensure that the Commission’s staff resources are efficiently utilized, a 

“quality of content” standard has been established as part of the Good Order 

requirements. (11 CFR §9036.4(a)(2)). Only matching fund requests where the 

initial review indicates that at least 85% of the submitted contributions are 

matchable will be accepted and payment amounts certified. This standard does 

not apply to submissions made on the last submission date of the year preceding 

the election through the date of the candidate’s ineligibility. Corrected 

submissions and resubmissions will be received in accordance with 11 CFR 

§9036.4 and 11 CFR §9036.5. A submission will not be considered corrected 

until the projected dollar value of non-matchable contributions has been reduced 

to no more than 15% of the amount requested. 

C. TYPES OF REVIEW 

1. Each matching fund request is subjected to a two-part review using statistical 

sampling techniques. (11 CFR §9036.4(b)). The comparison review (contributor 

data file compared to written instrument) identifies non-matchable contributions 

as described in exception codes A to H, the aggregation review identifies nonmatchable contributions covered by exception code J. Based upon the results of 

the sample review, a dollar value reduction, together with an error rate, will be 

calculated for each exception code. (11 CFR §9036.4(b)). The dollar value 

reduction is calculated in the following manner: Number of errors divided by 

sample size, multiplied by the amount requested. (See Section P. of this chapter 

regarding Summary of Review Results). 

D. CONTRIBUTIONS REQUIRING ADDITIONAL DOCUMENTATION 

1. Contributions that are received by a candidate/committee without the additional 

documentation required for matching should be deposited and withheld from 

submission by the candidate/committee until the required additional 

documentation is obtained from the contributor or appropriate source. After the 

documentation is received, the contribution and documentation should be 

submitted for matching. (See FEC Financial Control and Compliance Manual for 

Page III-2 
Chapter III MATCHING FUND REQUESTS 

Presidential Candidates Receiving Primary Election Financing, Chapter IV for 

discussion of a system for processing “later matchable contributions.” (Also see 

11 CFR §9036.3). 

2. Appendices 7-22 of this Guideline include suggested formats for obtaining the 

required additional documentation for contributions drawn on certain types of 

non-personal accounts and/or where the signature of the contributor is omitted. 

The Commission's and the candidate/committee's experience in past election 

cycles with respect to the formatting of the additional documentation has been 

that, if the contributor to whom it is sent for signature is presented with options 

regarding the contribution, the required information may not be obtained. It is 

suggested that conflicting statements be avoided because all or none may be 

checked and signed. Therefore, the suggested formats that appear in the 

Appendices present a positive statement to be signed by the contributor. The 

formats also request an explanation if the positive statement is inaccurate. For the 

most part, the inaccuracy would be with respect to the fact that the contribution 

has been attributed to the wrong individual (in which case the proper contributor 

may be identified and submitted for matching) or that it is from prohibited 

sources. 

E. INFORMATION REQUIRED FOR EACH LISTED CONTRIBUTOR 

1. Each contributor must be listed by full name (i.e., last name, first name, middle 

initial, and suffix (Jr., Sr., III, etc.), if any) with the contributor's mailing address. 

The mailing address must include the street number and name (or box number), 

city, state and zip code. See Appendix 4 for contributor file requirements. (11 

CFR §9036.2(b)(1)). 

2. Contributions submitted for joint accountholders must be recorded separately, 

even if the contribution is received in the form of one check. (11 CFR 

§9036.3(c)(1)). However, contributions drawn on accounts maintained by more 

than one person must contain the signature(s) of each accountholder to whom all 

or a portion of such contribution is attributed. The signature may be on the check 

or accompanying supporting documentation. (11 CFR §9034.2(c)(1)). 

3. The full dollar amount of each contribution submitted and date (deposit date plus 

batch number) must be included (11 CFR §9036.1(b)(1)(iii) and 11 CFR 

§9036.1(b)(1)(iv). 

4. The dollar amount being submitted for matching must be shown for each listed 

contribution. (11 CFR §9036.1(b)(1)(v)). 

5. The correct aggregate dollar amount of contributions submitted for matching to 

date for each contributor must be included. (11 CFR §9036.1(b)(1)(vi)). The 

aggregate total is to include all contributions submitted for matching regardless of 

whether any are rejected as non-matchable or later become NSF. 

Page III-3 
 

 

Chapter III MATCHING FUND REQUESTS 

6. Each contribution must include the date it was deposited and must be referenced 

to the bank deposit on which it was deposited. (11 CFR §9036.1(b)(1)(iii) and 11 

CFR §9036.1(b)(3)). The deposit date may be used as the reference to the bank 

deposit (as well as on the copy of the written instrument). A batch number should 

be added to the deposit date for referencing multiple deposits on the same date. 

7. Where copies of written instruments are being submitted in deposit batch order 

(as described at G.4 of this chapter), the contributor data file must also include the 

sequence number assigned to each contribution within the deposit batch. 

8. If not evident on the face of the written instrument, each contribution received as 

a result of joint fundraising activities and/or entertainment events must be 

annotated as such. 

F. SUMMARY INFORMATION REQUIRED ON CONTRIBUTOR DATA FILE OR 

SEPARATE DOCUMENT 

1. The total amount of contributions requested to be matched. 

2. The total number of contributors contained on the contributor data file must be 

provided. 

3. An explanation of the method used to reference the contributions to the deposit 

slips and bank documentation must be included. 

G. SUPPORTING DOCUMENTATION FOR REQUESTED AMOUNTS 

1. Full-size photocopies or digital images of each written instrument, legible as to 

account holder, if the check is imprinted with the account holder’s name, date, 

amount, payee and signature(s), must be submitted in support of each contribution 

for which a matching amount is being requested. The term “legible” means that 

the name of the contributor, the name of the recipient/payee, and the date and 

amount of the contribution can be read on the photocopy or digital image of the 

written instrument. If the name of the contributor is imprinted on the written 

instrument or digital image, a fully legible (decipherable) signature is not 

required. Copies and scanned images need include only the front of the written 

instrument, except for third party checks, which require a photocopy or scanned 

image of both sides of the check attesting to the endorsement to the 

candidate/committee.11 

11 The contributor in these instances shall be the individual who last specifically endorsed the Written 

Instrument without qualification to the Candidate/Committee and who executed the endorsement to the 

Candidate/Committee in his or her own hand. 

Page III-4 
Chapter III MATCHING FUND REQUESTS 

2. Legible and full-size photocopies or digital images of the written instruments and 

any additional documentation required by this Guideline may be submitted in the 

same order as they are listed on the contributor data file or as described in G.4. 

below. (11 CFR §9036.2(b)(1)(vi)). 

3. Each photocopy or digital image of the written instruments must be referenced to 

the deposit on which it was deposited. This may be accomplished by using the 

deposit date with a batch number for multiple deposits on a single date. 

(11 CFR §9036.2(b)(1)(vi)). 

4. As an option to an alphabetical arrangement, photocopies or digital images of the 

written instruments may be batched in deposits of 50 contributions or less and 

cross-referenced by deposit number and a sequence number within each deposit. 

a. Batch deposits shall be arranged in chronological order by month, day, and 

ascending batch numbers. Additional documentation for contributions 

batched by deposit should be submitted in alphabetical order and referenced 

to the sequence number at which the contributor's name is listed. 

b. Where a "later matchable" contribution may be withheld and submitted at a 

later date than those contained in a batch deposit, upon its submission, only a 

copy or scanned image of the written instrument is required, provided the 

correct deposit date reference is entered onto the contributor data file. 

H. BANK DOCUMENTATION 

1. Documentation must be provided as follows which indicates that the contributions 

listed were deposited into a designated depository: 

a. Bank validated deposit slips are acceptable and should be obtained for 

recently deposited contributions for which a bank statement may not be 

available at the time the matching fund request will be submitted. 

b. Non-bank validated deposit slips plus photocopies of bank statements 

showing the deposit are acceptable. (11 CFR §9036.1(b)(4)). 

Page III-5 
 

Chapter III MATCHING FUND REQUESTS 

I. NSF LISTING12 

1. A straight alphabetical listing of all contributors whose checks were returned by 

the bank to date (or within the period covered by the submission) as unpaid (NSF, 

stop-payments, etc.) must be included with each matching fund request regardless 

of whether the contributions were submitted for matching. (11 CFR 

§9036.2(b)(1)(iii) and 11 CFR §9036.4(c)). This listing may be filed in an 

electronic format. For the purpose of compiling the NSF listing, a check should 

not be considered NSF until the candidate/committee has stopped its efforts to 

receive payment on it, such as redepositing after its first rejection and then it 

being twice rejected as non-payable by the bank. A contribution represented by 

such a check should not be included in a matching fund request until it has been 

paid. If it is the candidate/committee's practice to make no redeposit of an NSF 

check(s), the contributor's name will be immediately placed on the NSF listing. 

2. The following information must be included on the NSF listing for all checks 

returned by the bank as non-payable: 

a. Full name and mailing address of the contributor; 

b. Date and amount of the check; 

c. Deposit and redeposit (where applicable) dates; and 

d. If previously submitted for matching, the submission number on which the 

check was included. 

3. A photocopy or scanned image of each NSF check (both sides) to which the 

associated debit memo is attached and a copy of the relevant bank statement must 

be provided for each item included on the NSF listing. 

4. If no deposited contributions became non-payable by the bank during the period 

covered by the submission, a statement to that effect, signed by the treasurer, will 

satisfy the Good Order requirements with respect to the NSF listing. 

J. CONTRIBUTION REFUND LISTING13 

1. A straight alphabetical listing of all contributors to whom contribution refunds 

have been issued for the period covered by each matching fund request must be 

included, regardless of whether the contributions were submitted for matching. 

(11 CFR §9036.2(b)(1)(iv)). This listing may be filed in an electronic format. 

12 See Chapter II, Credit Card Contributions, for information required to be provided for credit card 

charge backs. 

13 See Chapter II, Credit Card Contributions, for information required to be provided for refunds of 

contributions made by credit card. 

Page III-6 
Chapter III MATCHING FUND REQUESTS 

2. The following information must be included on the Contribution Refund Listing 

for all refunds: 

a. Full name and mailing address of the contributor; 

b. Deposit and full amount of contributor's check for which all or a portion was 

refunded; 

c. Total amount of contributions received from contributor; 

d. Amount and date of refund check; and 

e. An indication of which matching fund submission the contribution was 

included in. 

K. DOCUMENTATION TO SUPPORT THE MATCHABILITY OF 

CONTRIBUTIONS RECEIVED AS A RESULT OF JOINT FUNDRAISING OR 

ENTERTAINMENT EVENTS 

1. If contributions received from joint fundraising activities are included, a copy of 

the joint fundraising agreement, signed by representatives of each participating 

candidate/committee, must accompany the submission. (11 CFR §9034.2(c)(7)). 

Contributions received as the result of joint fundraising are matchable for only the 

percentage of each contribution received as stipulated in the joint fundraising 

agreement. (11 CFR §9034.8(c)(1)). In addition, any contribution that has been 

attributed to the candidate/committee in a percentage other that the basic 

percentage contained in the joint fundraising agreement shall be accompanied by 

documentation showing the re-allocation and the basis or reason for the reallocation. (11 CFR §9034.2(c)(7)). 

2. The full amount of the contribution made to the event must be shown on the 

contributor data file, with the allocated amount (or portion to be submitted) to the 

candidate/committee listed as the amount requested. 

3. If contributions from entertainment events are included, a copy of the promotional 

material and a copy of a ticket at each price must accompany the submission. (11 

CFR §9034.2(c)(5)). The promotional material and tickets must clearly indicate 

that such purchase represents a contribution to the candidate/committee. (11 CFR 

§9034.2(c)(5)). 

4. If it is not evident from the face of a written instrument (e.g., the name of the 

payee or a notation) that a contribution was received as a result of a joint 

fundraising or entertainment event, the contributor data file must identify the 

contribution as such. 

Page III-7 
Chapter III MATCHING FUND REQUESTS 

L. CERTIFICATION FROM COMMITTEE TREASURER REGARDING THE 

COMPLETENESS AND ACCURACY OF ALL INFORMATION SUBMITTED 

1. Each matching fund request, and re-submission, or any statement of net 

outstanding campaign obligations (NOCO statement) must be accompanied by a 

certification, signed by the committee treasurer, which attests to the fact that all 

information and documentation contained in the submission is complete and 

accurate. (11 CFR §104.14). 

2. The certification shall also include the following information (see example at 

Appendix 2): 

a. Identification of the type of submission; 

b. Coverage dates of deposits of submitted contributions; and 

c. For submissions/resubmissions made in the year preceding the presidential 

election year up to and excluding the last submission date in that year, and for 

submissions/resubmissions made after the candidates date of ineligibility an 

acknowledgment of the ramifications if, after the initial review, less than 85% 

matchable contributions have been submitted. (See 11 CFR §9036.2(d)(2)) 

M. METHODS OF REVIEW 

1. Where appropriate, and in accordance with Commission approved procedures, 

matching fund requests of sufficient size (generally 500 or more contributions) 

will be reviewed by statistical sampling. (11 CFR §9036.4(b)). All others will be 

reviewed on an l00% basis. When submissions are reviewed using statistical 

sampling, an error rate will be calculated for exception codes A-J based upon the 

errors found in the sample. A dollar-value reduction will be calculated and 

applied to the amount requested. 

2. The evaluation of a matching fund request consists of two types of reviews: a 

comparison review (contributor data file compared to written instrument) and an 

aggregation review. Both reviews are conducted using the Standard Exception 

Codes described in Chapter V of this Guideline. 

N. ADJUSTMENTS TO AMOUNT REQUESTED 

1. As part of its review procedures, the Audit staff will determine if the amount 

requested as provided by the candidate/committee pursuant to F.1. of this Chapter 

is correct. 

2. In the event a different amount is calculated, whether due to errors or NSF 

contributions or other reasons, the candidate/committee will be advised of the 

amount of the adjustment and the reasons. This information will be included on 

Page III-8 
Chapter III MATCHING FUND REQUESTS 

the Summary of the Results of the Review (see P. of this Chapter) that is 

furnished to the candidate/committee upon completion of the review. 

O. REJECTION CRITERIA - ERROR RATE IN EXCESS OF 15% 

1. For submissions/resubmissions made in the year preceding the presidential 

election year up to but excluding the last submission/resubmission date in that 

year, and for submissions/resubmissions made after the candidate's date of 

ineligibility if the initial statistical sampling review of a matching fund request 

produces an error rate in excess of 15%, no further processing on the submission 

will be done. The matching fund request, either in its entirety or the relevant 

portions, will be returned to the candidate/committee for corrective action. 

2. The Audit staff will contact the committee treasurer or appropriate committee 

representative to advise on the results of the initial review. 

3. The candidate/committee will be furnished with the results of the initial review by 

a summary that will list the amounts rejected as non-matchable and the calculated 

error rates for each type of exception code noted during the review. An inventory 

of items returned or retained by the Commission will also be included. (See 

example at Appendix 5(b)). 

4. The candidate/committee will have 5 business days to correct and return the 

submission in order that it be reviewed and certified on the next regularly 

scheduled certification date for the original submission. If not corrected and 

submitted within 5 business days, the committee may return the submission, 

however it will be considered received on the next regularly scheduled 

submission date. The committee has the option of withdrawing the submission 

and the matchable contributions submitted on the rejected submission can be 

included in the next regularly scheduled submission. (See 11 CFR 

§9036.4(a)(3)). 

P. SUMMARY OF RESULTS OF REVIEW 

1. Upon completion of the review of a matching fund request, the 

candidate/committee will be notified of the results of the review by a Summary of 

the Results of the Review and other pertinent certification information. (11 CFR 

§9036.4(b)). (See copy of Summary at Appendix 6). 

2. The summary includes the amounts rejected under each exception code and the 

error rate calculated for each. 

3. If the review was done by statistical sampling, only the Summary is furnished to 

the candidate/committee. However, the specific contributions determined to be 

errors in the sample may be identified if the candidate/committee requests them in 

writing. Once the rejected contributions have been identified to the 

Page III-9 
Chapter III MATCHING FUND REQUESTS 

candidate/committee, the submission may not be withdrawn and resubmitted. If 

the candidate/committee believes any contribution was in fact matchable as 

submitted, the candidate/committee may dispute the Commission's determination 

in the matter(s) using the procedures outlined in Sections F and G. of Chapter IV 

of this Guideline. If the committee demonstrates that any contributions among the 

sample items determined to be non-matchable are matchable as originally 

submitted, the Audit staff will calculate a new error rate and amount rejected. 

4. Where an l00% review was conducted, a listing and copies of the non-matchable 

contributions, identifying the exception code applied to each, will accompany the 

Summary. 

5. Where an adjustment for previously matched contributions which became NSF or 

contributions refunded was necessary, the Summary will identify the total amount 

of NSF and refunded items, the submission(s) in which they were matched, and 

the percentage of dollars matched in the submission(s). The amount of the 

adjustment is then based on the matchable percentage of those previous 

submission(s). 

6. Where an adjustment to the amount requested was necessary as described in N. 

above, the reason(s) for the adjustment will be included on the Summary. 

Page III-10 
 

 

 

 

 

 

Chapter IV RESUBMISSIONS 

Chapter IV 

RESUBMISSIONS 

A. GENERAL INFORMATION 

Candidates/committees may present resubmissions for review on the designated 

submission dates each month. Regardless of size, no more than one resubmission may be 

presented on each designated date. Payment for a resubmission will be certified on the 

next designated certification date. 

A resubmission must be accompanied by a certification, signed by the committee 

treasurer, which attests to the fact that all information and documentation contained in the 

resubmission is complete and accurate. (11 CFR §104.14). 

Where a statistical review was conducted, two (2) options for resubmissions are available 

and are discussed in C. below. For the resubmission of rejected contributions where a 

100% review was conducted, the method of resubmission is presented at D. (11 CFR 

§9036.5(a)). 

B. FINAL RESUBMISSION DATE 

11 CFR §9036.5(b) of the Commission's regulations establishes the first Tuesday of 

September of the year following the election as the final date on which a resubmission 

may be presented for review and certification for payment. Because the Department of 

Treasury obligates funds to the Presidential Primary Matching Payment Account (and the 

Presidential Election Campaign Fund) by fiscal year, the final date as specified permits 

both the Federal Election Commission and the Treasury to close out their functions 

related to public funding at the end of fiscal year after the year of the election. 

C. RESUBMISSION OF MATCHING FUND REQUESTS REVIEWED ON A 

SAMPLE BASIS 

As described in Chapter III, where a matching fund request has been reviewed by 

statistical sampling, the candidate/committee will receive only a summary result of 

review. Based upon the number of errors (non-matchable contributions) in the sample, 

the summary identifies only the dollar value and percentage reduction applied under each 

exception code. For submissions reviewed by statistical sampling, there are two (2) 

options available for resubmission, each with a different resulting payment: 

Page IV-1 
 

 

Chapter IV RESUBMISSIONS 

1 Resubmission of Entire Matching Fund Request for Restoration of Dollars Originally 

Rejected 

a. If this option is selected, the candidate/committee must review the original 

matching fund request for errors of the type identified on the summary results 

of review and either make corrections to the contributor data file or obtain 

additional documentation from the contributor, whichever is appropriate. 

With this option the entire submission must be resubmitted after all 

corrections have been made. In reviewing the resubmission, the audit staff 

will reevaluate the sample results from the original submission review. 

Where corrections to errors identified in the sample increase the matchable 

amount of the original submission, an additional amount will be certified on 

the next scheduled certification date. 

b. Only contributions included on the original matching fund request may be 

included on a resubmission. (11 CFR §9036.5(c)). The original amount 

requested may not be increased. However, where a contribution cannot be 

rendered matchable by either correcting the database or obtaining additional 

documentation from the contributor, the contribution may be deleted, which 

then decreases the total amount requested. With each resubmission the 

candidate/committee must provide a statement that the corrections have been 

made to contributor records and the database. (11 CFR §9036.5(c)(6)). 

c. Photocopies of the written instruments or scanned images and bank 

documentation need not be provided with a resubmission unless it is 

necessary to supplement the original set of documentation (e.g., where 

missing written instruments or insufficient additional documentation caused 

the original error to occur). However, if the candidate/committee wishes to 

resubmit a complete set of documentation, it will be accepted. (11 CFR 

§9036.5(c)(1)). 

d. The candidate/committee will receive a summary results of review just as for 

a regular submission. 

2. Resubmission of Rejected Sample Contributions for Payment of Only Matchable 

Face Value 

a. In this option, the candidate/committee chooses not to resubmit the matching 

fund request in its entirety. Instead, the candidate/committee may request, in 

writing, the identification of the specific contributions in the sample that were 

rejected as non-matchable, together with the reason(s) for each rejection. 

They may then be resubmitted for payment by using the procedures described 

in section D. of this Chapter (Resubmission of Matching Fund Requests 

Reviewed on an 100% Basis). 

Page IV-2 
 

 

 

Chapter IV RESUBMISSIONS 

b. The format for a resubmission comprised of specific sample contributions is 

the same as that specified in D. below of this Chapter. 

c. Resubmissions are to contain only contributions that were previously 

submitted and rejected. With each resubmission of specific items, the 

candidate/committee must provide a statement that the corrections have been 

made to contributor records and the database. (11 CFR §9036.5(c)(6)). 

d. Payments certified for contributions included on a resubmission of rejected 

sample items or those reviewed l00% (as described in sub-Chapter D. below) 

are limited to only the matchable face value of the written instruments. (See F 

and G below and 11 CFR §9036.5(e) and 11 CFR §9036.5(f) for procedures 

regarding disputed determinations of matchability). 

D. RESUBMISSION OF MATCHING FUND REQUESTS REVIEWED ON AN 

l00% BASIS 

After the review of a matching fund request where each submitted contribution was 

reviewed, the candidate/committee will be notified of any contributions determined to be 

non-matchable. This notice shall be comprised of the summary results of review, plus a 

listing of the rejected contributions and copies of the associated written instruments, 

identified by the exception code under which each was rejected. If clarifying additional 

documentation is obtained from the contributor or the candidate/committee's contribution 

records are corrected, the rejected contributions may be resubmitted as specified below. 

The requirements for a resubmission of this type follow below: 

1. Each resubmission must follow the format as specified for regular submissions 

described in Chapter III. of this Guideline and, in addition: 

a. The resubmitted contribution must be referenced to the original 

submission number. 

b. The contributor's aggregate dollar amount for a specific item resubmission 

should reflect the aggregate amount in the original submission, plus any 

subsequent contributions submitted for matching on regular matching fund 

requests that were presented before the resubmission. Where subsequent 

contributions were received, each aggregate total must be presented 

separately. (11 CFR §9036.5(c)(4)). 

2. The resubmission must include a statement that the candidate/committee has 

corrected its contributor records (including the database for those committees 

using computerized systems). If future matching fund requests demonstrate these 

changes were not made, the contributions will again be determined as nonmatchable and the appropriate adjustment will be made to the next payment 

certified. In the absence of any further payments, a repayment will be requested 

pursuant to 26 U.S.C. §9038(b)(l) and 11 CFR §9038.2(b)(l)). 

Page IV-3 
 

 

 

Chapter IV RESUBMISSIONS 

E. NOTICE OF RESULTS OF REVIEW 

1. Following the review of any resubmission that is comprised of specific rejected 

contributions, the identity of which were requested in writing by the 

candidate/committee, a summary result of review will be furnished to the 

candidate/committee. The summary will advise on the amount of payment to be 

certified to the candidate/committee for the resubmission. Such payment will be 

certified with the payment for the next matching fund request payment. 

2. For any contributions that were determined to be yet non-matchable, the summary 

will be accompanied by a listing of the rejected contributions, identified by the 

exception code(s) under which each was rejected as non-matchable. Copies of the 

written instruments, also identified by the appropriate exception code(s), will be 

attached to the listing. 

3. If the candidate/committee can obtain the additional documentation required for 

matchability (described in Chapter V of this Guideline) for any twice rejected 

contribution, the contribution(s) may again be placed on a resubmission list, 

identified by the original submission number and the resubmission number. 

4. If the candidate/committee believes the contribution(s) is matchable as first 

submitted and/or resubmitted, rather than resubmitting the contribution(s) a 

second time, the procedures specified at 11 CFR §9036.5(e) and 11 CFR 

§9036.5(f) and described below at F. should be followed. 

F. DISPUTED DETERMINATIONS OF MATCHABILITY 

1. If, after either being furnished copies of rejected contributions (as for a 100% 

review) or obtaining specific rejected sample items from either a submission or 

resubmission of an entire submission, the candidate/committee believes any 

contribution(s) was in fact matchable as submitted, the candidate/committee may 

dispute the Commission's determination in the matter(s). 

2. The candidate/committee must submit, within 30 business days of receipt of the 

identity of the rejected contributions, written legal or factual reasons as to why the 

contribution was in fact matchable as first submitted. The Commission will 

consider the material submitted by the candidate/committee and make a final 

determination within 30 business days of receipt of the candidate/committee's 

material. (See G. below for discussion of restoration of dollar reduction vs. only 

matchable face value upon dispute of matchability). (11 CFR §9036.5(e) and 11 

CFR §9036.5(f)). 

Page IV-4 
Chapter IV RESUBMISSIONS 

G. RESTORATION OF DOLLAR REDUCTION VS. MATCHABLE FACE VALUE 

ONLY 

Chapter V of this Guideline sets forth the matchability requirements for all contributions 

that may be submitted for matching purposes. It further details certain additional 

documentation that must be obtained from the listed contributor in order to render some 

types of contributions matchable. In reviewing matching fund requests, the standards 

described under each exception code are consistently applied to each contribution 

reviewed and must be met in order for the contribution to be viewed as matchable upon 

submission. Where the candidate/committee chooses to dispute the Commission's initial 

determination of non-matchability of a specific contribution and submits additional 

documentation or legal and factual reasons to satisfactorily demonstrate matchability, the 

Commission will calculate a new error rate and amount rejected. If the 

candidate/committee is unable to demonstrate that a rejected contribution was matchable 

as resubmitted, the Commission will certify only the matchable face value of the disputed 

contributions. 

Page IV-5 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

Chapter V 

STANDARD EXCEPTION CODES FOR 

REVIEW OF MATCHING FUND REQUESTS 

GENERAL 

Through its regulations and this Guideline, the Commission has established certain 

standards regarding the matchability of contributions to ensure to the greatest extent 

possible that only those that represent the personal funds of the contributor for whom 

matching funds are requested are in fact matched with federal dollars. Exceptions to the 

matchability requirements are discussed in this Chapter and are identified by assigned 

alphabetical/numerical codes. 

The standard exception codes described in this Guideline may not be the sole source for 

determining that a contribution is non-matchable. Commission procedures provide that 

information obtained during an inquiry conducted under 11 CFR §9039.3 may also be 

used as the source for determining the matchability of any contribution submitted for 

matching purposes. 

In carrying out the Commission's responsibilities under the Act, Commission staff may 

contact representatives of the candidate/committee to discuss questions and to request 

documentation concerning a campaign's activities of any submissions made. 

(See 11 CFR §9039.2(b)). 

While not answering every question that may arise with respect to whether a contribution 

will be deemed matchable or non-matchable, the Commission considers the information 

contained herein regarding certain types and appearances of written instruments to 

greatly benefit the candidate/committee in its decisions as to whether or not a specific 

contribution, while permissible under the Act, should be included in a matching fund 

request. Because of the dollar reduction that may result from inclusion of non-matchable 

contributions, the information discussed in this Chapter should be considered where a 

doubt might exist. (Also see Chapter VI for examples of matchability situations). 

Each exception code is broken into sub-categories and provides the candidate/committee 

with more definitive information as to why certain contributions will not (or did not) 

meet the matchability requirements as detailed in this Guideline. Except for 

contributions that are never matchable, each is discussed with respect to the specific 

requirements for matchability and any additional documentation that will be required in 

order to render a contribution matchable.14 

14 See 11 CFR §9039.2(b) which provides that, upon the request of the Commission's Audit Division 

and/or Office of General Counsel, the original additional documentation bearing the original signature of 

the contributor must be submitted. 

Page V-1 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

As stated in prior chapters, because of the statistical sampling procedures used in the 

matching fund review process, the Commission recommends that candidates/committees 

submit only those written instruments that are clearly matchable. If upon receipt, a 

written instrument may be matchable if accompanied by additional documentation signed 

by the contributor, the Commission recommends that these be held for submission until 

the appropriate documentation has been obtained. 

An immediately matchable contribution is one that is drawn on an individual's personal 

account and is signed by the identified accountholder. The written instrument bears a full 

date (month, day, year) reflecting that it was written on or after January 1, of the year 

prior to the election, but no later than December 31 of the year of the election (provided it 

was also deposited on that date), is made payable to the candidate or an authorized 

committee for a presidential campaign, is signed by the account holder and has identical 

numerical and written amounts. Further, all of the above information can be read on the 

photocopy or scanned image submitted. 

Any contribution that does not conform to that described above should be questioned 

with respect to its immediate matchability or whether any of the exception codes may 

apply, thereby rendering it "later matchable" (that which may become matchable upon 

obtaining the appropriate signed additional documentation) or "never matchable." 

Contributions drawn on written instruments that are payable for amounts in excess of 

$2,300, are matchable up to $250. The candidate/committee need not supply evidence of 

a refund or a redesignation of the excessive amount. In order to submit the excessive 

portion for another contributor, the reattribution provisions for joint contributions 

contained at 11 CFR §110.1(k) must be met, together with the appropriate matchability 

requirements of this Guideline. 

The Commission's regulations at 11 CFR §9034.2 contain the matchability requirements 

for contributions. Non-matchable contributions are discussed at 11 CFR §9034.3. 

Insufficient documentation which may render some contributions non-matchable is 

described at 11 CFR §9036.3. The Guideline further details those criteria in discussing 

the matchability requirements under the standard exception codes. 

Page V-2 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE A 

NON-MATCHABLE CONTRIBUTIONS 

EXCEPTION CODE A-1 

CONTRIBUTIONS WRITTEN ON ACCOUNTS MAINTAINED BY A 

CORPORATION, LABOR ORGANIZATION OR GOVERNMENTCONTRACTOR 

(11 CFR §9034.3(d)) 

A contribution bearing a reference that the check is drawn on an account maintained by a 

corporation (such as Corp., LTD., Inc., P.C., P.A., LLC15), a labor organization, or 

government contractor is non-matchable, even if it represents personal funds earmarked 

by a contributing individual. (11 CFR §9034.3(d) and 11 CFR §9034.3(f)). This 

provision extends to an individual's account, such as a professional person's account, 

which indicates the professional practice is incorporated. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Such a contribution 

should not be submitted for matching. No additional documentation will render such a 

contribution matchable. 

EXEMPTION: A contribution, drawn on an individual's apparent personal account that 

also contains the name of a corporation or labor organization (i.e., as part of the mailing 

address), is matchable. 

15 A Limited Liability Company (LLC) that elects to be treated as a corporation by the Internal Revenue 

Service pursuant to 26 CFR §301.7701.3 or an LLC with publicly traded shares, is considered a 

corporation pursuant to 11 CFR §114. 

Page V-3 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE A-2 

CONTRIBUTIONS WRITTEN ON ACCOUNTS OF POLITICAL 

COMMITTEES/ORGANIZATIONS 

(11 CFR §9034.3(d)) 

A contribution, drawn on an account maintained by any type of political committee or 

organization, including the campaign committee of a non-federal candidate, is nonmatchable even if it represents personal funds earmarked by a contributing individual. 

(11 CFR §9034.3(f)). 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Such a contribution 

should not be submitted for matching. No additional documentation will render such a 

contribution matchable. 

EXEMPTION: A contribution on an account that represents an employee participation 

plan established pursuant to 11 CFR §114.11 is matchable providing the requirement 

described below is met. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: A contribution 

drawn on the account of a political committee that represents the personal contribution 

from an individual made through an employee participation plan is matchable providing 

the contributor's signature is either on the written instrument or additional 

documentation. (See suggested format for letter to obtain the required additional 

documentation for such a contribution that appears at Appendix 7). 

Page V-4 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE A-3 

WRITTEN INSTRUMENTS REPRESENTING REFUNDS 

AND/OR LOANS; CURRENCY 

(11 CFR §9034.3(b), 11 CFR §9034.3(c), and 11 CFR §9034.3(j)) 

A receipt representing a refund of any type, an unforgiven loan, or received in the form 

of currency, either United States or foreign, is non-matchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Receipts of the type 

described above should not be submitted for matching. However, a loan, made by an 

individual, which subsequently is forgiven, either in whole or in part, by the individual is 

matchable, providing the written instrument is matchable in every other respect AND a 

statement, signed by the contributor, is submitted which acknowledges the original loan, 

the date on which the loan was forgiven, and the amount of the original loan forgiven and 

contributed to the candidate/committee. (See suggested format for obtaining the required 

additional documentation that appears at Appendix 8). 

Page V-5 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE A-4 

EXCESSIVE PORTIONS OF CONTRIBUTIONS DRAWN ON 

SINGLE WRITTEN INSTRUMENTS THAT ARE MADE 

PAYABLE FOR AN AMOUNT GREATER THAN $2,300 

(11 CFR §9034.3(e) and 11 CFR §9034.2(c)(1)(iii)) 

The portion of a contribution in excess of $2,300 where the amount of the written 

instrument is made payable for an amount greater than $2,300, is non-matchable, except 

for contributions where the excessive portion has been attributed to another contributor 

provided such reattribution was effected as provided at 11 CFR §110.1(k). 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS FOR 

CONTRIBUTION WHERE EXCESSIVE PORTION HAS BEEN ATTRIBUTED TO 

ANOTHER CONTRIBUTOR: The portion in excess of $2,300 of a single written 

instrument imprinted with the names of more than one individual may be attributed 

among the individuals provided the contributors are notified by the committee of how the 

contribution was attributed within 60 days of receipt of the contribution (See 11CFR § 

110.1(k)(3)(ii)(B)(1) and (3). The amount of the contribution from the individual who 

signed the check is immediately matchable. In order to submit the portion of the 

contribution from the other individual the committee must provide a copy of the 

notification sent within 60 days to the contributors. In addition additional documentation 

bearing the signatures of all contributors to whom any portion of the excessive amount 

has been attributed, including the signature of the individual who signed the contribution 

check must also be submitted. (See suggested format for obtaining the required 

information on the additional documentation that appears at Appendix 11.) 

In the case of a check received in excess of $2,300 with only one signatory, the 

requirements at 11 CFR §110.1(k)(3) must be met. As evidence that the contributor 

reattribution was made within 60 calendar days from the date of receipt, the additional 

documentation (reattribution letter) must be either accompanied by (1) a copy of the 

envelope bearing the postmark and the contributor's name or return address or other 

identifying code; (2) a copy of the additional documentation (reattribution letter) with a 

date stamp indicating the date of the committee's receipt; or (3) a copy of the additional 

documentation (reattribution letter) dated by the contributor. 

These provisions for reattribution are not applicable to partnership contributions as a 

partnership contribution is limited to $2,300. (11 CFR §110.1(e)). 

Page V-6 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE A-5 

CONTRIBUTIONS MADE PAYABLE TO OTHER THAN 

THE CANDIDATE OR AN AUTHORIZED COMMITTEE 

(11 CFR §9034.2(c)) 

A written instrument made payable to an individual (except for a third party check) other 

than the candidate/committee, regardless of any position the individual may have with 

the campaign organization, is non-matchable. A written instrument made payable to an 

entity other than the candidate/committee or an authorized committee, or containing a 

dual payee, is non-matchable unless the payee name represents the name of a function 

sponsored and authorized by the candidate/committee and a copy of the solicitation 

material to the event is included with the submission. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: A written 

instrument made payable to an individual other than the candidate or containing a dual 

payee should not be submitted for matching. No additional documentation will render 

such a contribution matchable. A written instrument made payable to an entity other than 

the candidate/committee may be submitted for matching providing the payee name 

represents a function that was authorized and sponsored by an authorized committee, 

providing a copy of the solicitation material to the event is included as additional 

documentation for the contribution or with the submission.16 

16 Where there is more than one contribution made payable to an event or function, one copy of the 

solicitation material will suffice to support the matchability of all contributions that may be included. 

Page V-7 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE A-6 

MISCELLANEOUS NON-MATCHABLECONTRIBUTIONS17 

1. A contribution from a foreign national is non-matchable. (2 U.S.C. §441e and 

11 CFR §9034.3(e)). 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: A contribution 

from an individual whose mailing or residential address is outside of the United 

States or its territories shall be accompanied by additional documentation signed by 

the listed contributor, which acknowledges that he or she is a citizen of the United 

States or has been admitted as a permanent resident. (See suggested format for 

obtaining the required information for matchability on the additional documentation 

at Appendix 9). 

2. A contribution that is made without the necessary donative intent or made for the 

purpose other than to influence the result of a primary election is non-matchable. (11 

CFR §9034.3(i)). 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: A written 

instrument which bears an indication that its purpose was for other than a political 

contribution to the presidential campaign of the candidate/committee shall be 

accompanied by a statement, signed by the contributor, which identifies the specific 

written instrument (type, number, date and amount) and acknowledges that it 

represents his/her contribution to the presidential campaign of the 

candidate/committee. 

3. A contribution received in the form of the purchase price paid for or otherwise 

induced by a chance to participate in a raffle, lottery, or a similar drawing for 

valuable prizes is non-matchable. (11 CFR §9034.3(h)). 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Such a 

contribution should not be submitted for matching. No additional documentation will 

render such a contribution matchable. 

17 This Exception Code sub-category will be applied to any other type of non-matchable contribution not 

described within this Guideline, but to which the provisions of the Commission's regulations may apply. 

Page V-8 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE B 

SAME WRITTEN INSTRUMENT SUBMITTED MORE THAN ONCE 

EXCEPTION CODE B-l 

THE SAME WRITTEN INSTRUMENT IS LISTED OR SUBMITTED 

MORE THAN ONCE FOR MATCHING IN DIFFERENT SUBMISSIONS 

OR THE SAME SUBMISSION FOR THE SAME CONTRIBUTOR 

(11 CFR §9036.3(c)(3)) 

A contribution(s) submitted for a contributor which was previously matched in its 

entirety or up to $250 or listed twice in the same or a different submission is nonmatchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Such a contribution 

should not be submitted for matching. 

Page V-9 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE B-2 

THE SAME WRITTEN INSTRUMENT IS LISTED OR SUBMITTED 

MORE THAN ONCE FOR MATCHING IN DIFFERENT SUBMISSIONS 

OR THE SAME SUBMISSION FOR A DIFFERENT CONTRIBUTOR18 

A contribution supported by a written instrument which was previously submitted and 

matched in its entirety for one individual and that is later submitted for a different 

contributor is non-matchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: A written 

instrument(s) which has been previously matched in its entirety for one individual may 

not be submitted again for attribution, either whole or in part, to another individual. Only 

a different contribution or one with a remaining unmatched portion may be matched for 

another individual, as long as any appropriate additional documentation (as described 

within this Guideline) is provided.19 

18 This Exception Code does not apply to Written Instruments in excess of $250 where the portion in 

excess of $250 is being attributed to and submitted for another individual. (See Appendix 10 for a 

suggested format for obtaining the required information on the Additional Documentation, from the 

contributor to whom a portion is being attributed.) 

19 Candidate/Committees that submit contributions attributed in full to one contributor and, at a later date, 

reattribute an unmatched portion to a different contributor must ensure that contribution records and Title 2 

Disclosure Reports are appropriately amended. 

Page V-10 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE C 

INSTRUMENTS DRAWN ON OTHER THAN PERSONAL 

ACCOUNTS OF CONTRIBUTORS OR ACCOUNTS WHICH 

APPEAR TO CONTAIN OTHER THAN PERSONAL FUNDS 

EXCEPTION CODE C-l 

WRITTEN INSTRUMENTS DRAWN ON APPARENT 

UNINCORPORATED BUSINESS ACCOUNTS20 

(11 CFR §9034.2(c)(3) and 11 CFR §9036.3(a)) 

A contribution made by a written instrument drawn on an account identifying a business 

entity as the accountholder, although not incorporated, is non-matchable unless all 

requirements described below are met. 

MATCHABILITYAND/OR RESUBMISSION REQUIREMENTS: The written 

instrument, or accompanying additional documentation, must be signed by each 

individual to whom all or a portion of such contribution is attributed. A statement, 

signed by each individual, must be included by which each contributor acknowledges the 

contribution by amount and date (deposit date plus batch number and the amount and/or 

portion to be attributed).21 The contributor must also state that: 

1. The contribution represents his or her personal funds, and 

2. The account on which the contribution is drawn is not maintained or controlled by 

an incorporated entity. 

Further, if a contributor cannot readily be associated with a written instrument (e.g., 

surname Jones as the contributor of a check drawn on the account of Doe Pencil Co.), the 

signed additional documentation shall specifically acknowledge the written instrument by 

identifying the accountholder name and check number. (See Appendix l2 for a suggested 

format for obtaining all information required on the additional documentation.) 

20 A Limited Liability Company (LLC) with a single natural person member that does not elect to be 

treated as a corporation by the Internal Revenue Service pursuant to 26 CFR §301.7701-3 shall be 

attributed only to that single member. 

21 In Advisory Opinion 1980-67, the Commission concluded that the attribution of any portion of such 

contributions to any person who is not a partner or member of the unincorporated association or business, 

including any spouse who is not a partner or member, is not permitted. 

Page V-11 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE C-2 

WRITTEN INSTRUMENTS DRAWN ON NON-PERSONAL 

ACCOUNTS MAINTAINED BY ENTITIES SUCH AS A PARTNERSHIP, 

GROUP, ASSOCIATION OR WHICH APPEAR TO BE OTHER THAN 

AN INDIVIDUAL'S PERSONAL ACCOUNT 

(11 CFR §9034.2(c)(3) and 11 CFR §9036.3(a)) 

A contribution made by a written instrument drawn on an account maintained by a 

partnership22, group, association, or which appears to be other than a personal account is 

non-matchable unless all requirements described below are met. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: The written 

instrument, or accompanying additional documentation, must be signed by each 

individual to whom all or a portion of such contribution is attributed.23 A statement, 

signed by each individual, must be included on which each contributor acknowledges the 

contribution by check number, amount, date and the amount and/or portion to be 

attributed). Each contributor must also state that: 

1. The contribution represents his or her personal funds, 

2. The account on which the contribution is drawn is not maintained or controlled by 

an incorporated entity, and 

3. He/she is a partner in the partnership or a member of the unincorporated 

association or business. 

Further, if a contributor cannot readily be associated with a written instrument (e.g., 

surname Jones as the contributor of a check drawn on the account of Smith & Smith), the 

signed additional documentation shall additionally acknowledge the written instrument 

by identifying the accountholder name. (See Appendix 13 for a suggested format for 

obtaining the information required on the additional documentation.) 

22 A contribution by a Limited Liability Company (LLC) that elects to be treated as a partnership by the 

Internal Revenue Service pursuant to 26 CFR §301.7701-3, or does not elect treatment as either a 

partnership or a corporation pursuant to that section, shall be considered a contribution from a partnership 

pursuant to 11CFR §110.1(e). 

23 In Advisory Opinion 1980-67, the Commission concluded that the attribution of any portion of such 

contributions to any person who is not a partner or member of the unincorporated association or business, 

including any spouse who is not a partner or member is not permitted. Further, under 11 CFR §110.1(e), 

partnership contributions are limited to $2,300. 

Page V-12 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE C-3 

WRITTEN INSTRUMENTS DRAWN ON 

TRUST, ESCROW, OR ESTATE ACCOUNTS 

(11 CFR §9034.2(c)(2) and 11 CFR §9036.3(a)) 

A contribution which is drawn on a trust, escrow, or estate account is non-matchable 

unless accompanied by additional documentation as described below and signed by each 

contributor to whom all or a portion of the contribution is being attributed. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: A written 

instrument drawn on a trust, escrow, or estate account must be accompanied by additional 

documentation signed by each contributor to whom all or a portion of the contribution is 

being attributed, together with the check number, amount and date of the contribution. 

The documentation must specify that: 

1. The contributor has equitable ownership of the account, and 

2. The account contains the personal funds of the contributor. 

(See Appendix 14 for a suggested format for obtaining all information required on the 

additional documentation.) 

Page V-13 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE C-4 

WRITTEN INSTRUMENTS DRAWN ON INDIVIDUALS' PERSONAL 

ACCOUNTS WHICH BEAR A USAGE DESIGNATION 

(11 CFR §9034.2(c)(3) and 11 CFR §9036.3(a)) 

A contribution that is drawn on an individual's personal account which bears a 

designation indicating the account is used for a specific purpose is non-matchable if the 

designation indicates the account may be used for commercial or business purposes, such 

as "Office Account," "Business Account," etc. unless accompanied by additional 

documentation, signed by the contributor, which contains the information described 

below. (See Appendix 15a for a listing of designations that must be accompanied by 

additional documentation. A listing of matchable designations requiring no additional 

documentation, provided the appearance of the check is solely personal,

24 appears at 

Appendix 15b). 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Additional 

documentation signed by the contributor must accompany the written instrument, which 

specifies that: 

1. The account contains only his or her personal funds, and 

2. The account is not funded for his or her use by an incorporated entity. 

(See Appendix l6 for a suggested format for a letter to obtain all information required on 

additional documentation for such a contribution.) 

24 The "personal appearance of a check" means the size is approximately 2 3/4" x 6", contains an apparent 

residential address and has no provision for charts of accounts or other business-usage details. 

Page V-14 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE C-5 

INADEQUATE DOCUMENTATION FOR MATCHABILITY 

(11 CFR §9036.3(d)) 

A written instrument, although accompanied by additional documentation, is nonmatchable if all information specified by this Guideline under the matchability and/or 

resubmission requirements is not included on the required additional documentation.25 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: An additional 

statement signed by the contributor that supplements or replaces the original 

documentation must accompany the written instrument. 

The resubmission requirements as detailed for this Exception Code are not applicable to a 

contribution effected by money order, cashier's check, traveler's check or other similar 

negotiable instrument as such resubmission is prohibited under 11 CFR §9034.2(c)(4). 

25 The application of this Exception Code will be in addition to the one that pertains to the Written 

Instrument. For example, the application of Exception Codes "C-1, C-5" means the contribution was 

drawn on a business account that was accompanied by additional documentation; however, the additional 

documentation did not contain the information required by this Guideline. 

Page V-15 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE D 

SIGNATURE DISCREPANCIES ON PERSONAL ACCOUNTS 

EXCEPTION CODE D-l 

SIGNATURE OTHER THAN ACCOUNT HOLDER 

(11 CFR §9034.2(c)(l)(i) and 11 CFR §9036.3(a)) 

A contribution drawn on a personal account maintained by an individual(s), signed by an 

individual whose name is not imprinted on the face of the instrument, irrespective of the 

signatory's surname, is non-matchable unless additional documentation signed by the 

contributor, which includes the required information as described below, accompanies 

the written instrument. (This exception code is applicable when the listed contributor is 

the accountholder who did not sign the written instrument or the listed contributor signed 

the written instrument but is not identified as the accountholder). 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Where the listed 

contributor is the one who signed the written instrument, but who is not identified as an 

accountholder, the written instrument must be accompanied by additional documentation 

signed by the listed contributor, which acknowledges the contribution by (1) amount and 

date, (2) the identification of the account on which the contribution was drawn, (3) check 

number, and (4) states that the account represents his or her personal funds. 

If the listed contributor is the identified accountholder who did not sign the written 

instrument, the written instrument must be accompanied by additional documentation 

signed by the listed contributor, which acknowledges the contribution by amount and 

date and states that the contribution was to be regarded as his or her contribution. (See 

Appendix l7 and Appendix l8 for suggested formats for letters to obtain the required 

additional documentation from the contributor. 

Page V-16 
 

 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE D-2 

SIGNATURE DISCREPANCY ON A JOINT ACCOUNT 

(Amount of contribution does not exceed $2,300) 

(11 CFR §9034.2(c)(l) and 11 CFR §9036.3(a)) 

A contribution drawn on a personal account maintained by more than one individual 

which is attributed totally or in part to the accountholder whose signature does not appear 

on the check is non-matchable unless the required additional documentation described 

below accompanies the written instrument. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: In order to be 

attributed to the accountholder whose signature does not appear on the written 

instrument, additional documentation signed by the contributor, to whom all or a portion 

of the contribution is to be attributed, must accompany the written instrument that states 

(1) the amount of the contribution being attributed to him or her, (2) the date of the 

check, and (3) the check number. (See Appendix l9 for a suggested format for a letter to 

obtain the required additional documentation from the contributor.)26 

For a resubmission, unless restricted by the contribution limitations of 2 U.S.C. §441a, 

the candidate/committee may attribute the entire contribution to the signatory. If the 

contributor name is changed, the candidate/committee's contribution records (including 

the database for those committees using computer services) must be corrected. A 

statement that the contributor records and/or database have been changed must 

accompany the resubmission. 

If such a statement has been included and a future submission demonstrates the 

correction(s) was not made, the appropriate adjustment will be applied to the next 

payment certified. In the absence of any further payments, the amount will be requested 

as a repayment pursuant to 26 U.S.C. §9038(b)(l) and 11 CFR §9038.2(b)(l). 

26 Since this situation deals with a contribution that is not excessive the rules at 11CFR §110.1k do not 

apply. 

Page V-17 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE E 

OMITTED, INCOMPLETE, OR OBLITERATED 

INFORMATION REQUIRED 

FOR MATCHABILITY ON THE WRITTEN INSTRUMENT 

(11 CFR §9034.2(c) and 11 CFR §9036.3(a)(3)) 

The following information on the written instrument, if omitted, incomplete, obliterated, 

or cannot be read due to a poor photocopy or scanned image of the written instrument, 

will cause a contribution to be non-matchable. 

The written instrument lacks: Code 

1. Contributors Signature (E-l) 

2. Committee/Candidate as Payee (E-2) 

3. Amount of the Contribution (E-3) 

4. Date on Instrument (To include Month, Day, Year) (E-4) 

A written instrument that omits or contains incomplete, obliterated, or information that 

cannot be read with respect to the contributor's signature, the candidate/committee as 

payee (or for third party checks, the endorsement to the candidate/committee), or the 

amount and date is non-matchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: When either the 

date, payee, signature, or amount is omitted, incomplete, obliterated, or the information 

cannot be read due to a poor photocopy or scanned image of a written instrument, 

additional documentation, signed by the contributor, must accompany the written 

instrument. For purposes of obtaining the date on which a written instrument was made 

payable to the candidate/committee, at a minimum for matchability, the month and year 

must be provided. Such signed statement must acknowledge the contribution by 

identifying the type of written instrument, the check number, and provide the omitted, 

incomplete, obliterated, or unreadable information required for matching purposes. (See 

Appendix 20 for a suggested format for a letter to obtain required additional 

documentation.) 

The resubmission requirements as detailed for this exception code are not applicable to a 

contribution effected by money order, cashier's check, traveler's check or other similar 

negotiable instrument as such resubmission is prohibited under 11 CFR §9034.2(c)(4). 

Page V-18 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE F 

REQUESTED AMOUNTS EXCEED THE AMOUNT 

OF THE CONTRIBUTION RECEIVED FROM THE CONTRIBUTOR 

EXCEPTION CODE F-1 

REQUESTED AMOUNT EXCEEDS THE 

AMOUNT CONTAINED ON THE WRITTEN INSTRUMENT(S) 

(11 CFR §9036.3(b)(l)) 

A contribution for which the amount requested for matching on the contributor data file 

exceeds the amount of the written instrument is non-matchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: The contributor 

data file, in listing an amount for which matching funds are being requested, must reflect 

an amount no higher than the amount for which the written instrument is made payable or 

for which the depository will credit27 the candidate/committee's account. 

For a resubmission, the contributor data file must be adjusted to reflect the correct 

amount being submitted for matching. Additionally, the candidate/committee's 

contributor records (including the data base for those committees using computer 

services) must be corrected. A statement must accompany the resubmission contributor 

data file that indicates the contributor records and/or database have been corrected. 

Where such a statement has been included and a future submission demonstrates the 

correction(s) was not made, the appropriate adjustment will be applied to the next 

payment certified. In the absence of any further payments, the amount will be requested 

as a repayment pursuant to 26 U.S.C. §9038(b)(l) and 11 CFR §9038.2(b)(1). 

27 If the numeric and written amounts on a written instrument differ, it is assumed that the lesser of the two 

amounts will be credited by the depository to the candidate/committee's account. 

Page V-19 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE F-2 

REQUESTED AMOUNT EXCEEDS THE AMOUNT OF THE 

CONTRIBUTION RECEIVED FROM THE LISTED CONTRIBUTOR 

A contribution for which the amount requested for matching on the contributor data file 

represents the full matchable amount for which the written instrument is made payable, 

but there are indications that the written instrument represents contributions from more 

than one individual is non-matchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: The contributor 

data file in listing an amount for which matching funds are being requested, must reflect 

an amount no higher than the amount of the contribution received from the contributor.28 

28 Examples of contributions to which Exception Code F-2 would be applicable are (1) one that is drawn 

on a partnership for $500 with $250 requested in matching funds for the contributor. The additional 

documentation required to support the matchability of a partnership contribution is signed by the 

contributor who acknowledges that only $100 is attributable to him or her, and (2) a contribution on which 

the accountholder has indicated that the contribution is also from another individual(s), such as an entry on 

the memo line "also from Jane and Joe." In such an instance, only one-third of the amount may be 

submitted for the contributor who signed the Written Instrument. 

Page V-20 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE G 

DISCREPANCIES BETWEEN WRITTEN INSTRUMENTS AND/OR 

DOCUMENTATION AND CONTRIBUTOR DATA FILE 

EXCEPTION CODE G-l 

OMITTED WRITTEN INSTRUMENT 

(11 CFR §9036.3(b)(2)) 

A contribution for which a matching amount is requested that is not supported by a copy 

of the written instrument is non- matchable.29 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: A copy of the 

written instrument by which the contribution was effected must be obtained and 

submitted in support of each amount requested. 

29 Where copies of the written instruments are being submitted in deposit batch order as provided at 

Chapter III.G.4., this exception code will be applied in instances where there is a deposit batch as 

referenced on the contributor data base, however, no written instrument from the listed contributor is 

contained within the batch. 

Page V-21 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE G-2 

WRITTEN INSTRUMENT SUBMITTED DOES NOT SUPPORT THE LISTED 

CONTRIBUTION FOR WHOM THE AMOUNT IS REQUESTED 

(11 CFR §9036.3(b)(2)) 

A contribution for which a matching amount is requested that is supported by a written 

instrument containing neither the printed name (as in the accountholder identification) or 

the signature of the listed contributor is non-matchable.30 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: To be attributed to 

an individual who is not identified on the written instrument as either the accountholder 

(regardless of surname) or signatory, a statement, signed by the contributor to whom the 

contribution is being attributed, all or in part, must accompany the written instrument. 

The contributor must acknowledge the type of written instrument (check, money order, 

etc.) by which the contribution was made, the accountholder or, for a cashier's check, 

money order, etc., the issuer, and the check or serial number. The contributor must also 

state the date and the amount of the contribution that is to be attributed to him or her. 

The contributor must also include the fact that the account contains (or instrument was 

purchased with) his or her personal funds. (The suggested format that appears at 

Appendix l9 for joint account signature discrepancies is appropriate for obtaining the 

required additional documentation for such a contribution). 

The resubmission requirements as detailed for this exception code are not applicable to a 

contribution effected by money order, cashier's check, traveler's check, or other similar 

negotiable instrument as such resubmission is prohibited under 11 CFR §9034.2(c)(4). 

30 For example, this Exception Code will generally be applied in instances where a personal check, 

identifying John Doe as the accountholder and also signed by John Doe, is the Written Instrument 

submitted for Jane Doe. In this situation, while there is in fact a submitted Written Instrument that can be 

associated with Jane Doe, it does not support a matching request for Jane Doe, since in all appearances it is 

a contribution from John Doe. (See also 11 CFR §104.8(d)). 

Page V-22 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE G-3 

WRITTEN INSTRUMENT CANNOT BE ASSOCIATED 

WITH LISTED CONTRIBUTOR 

(11 CFR §9036.3(b)(3)) 

A contribution for which a matching amount is requested that is supported by a written 

instrument that cannot be associated with the listed contributor is non-matchable.31 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: To be attributed to 

an individual who is not identified in any manner on the written instrument as either the 

accountholder, remitter, or signatory, a statement, signed by the contributor to whom the 

contribution is being attributed, all or in part, must accompany the written instrument. 

The contributor must fully acknowledge the type of written instrument (check, money 

order, etc.) by which the contribution was made, the accountholder or, for a cashier's 

check, money order, etc., the issuer, signatory or remitter/purchaser, and the check or 

serial number. The contributor must also state the date of the written instrument and the 

amount of the contribution that is to be attributed to him or her. The statement must also 

include the fact that the account contains (or the written instrument was purchased with) 

his or her personal funds. (See Appendix 21 for a suggested format for a letter to obtain 

the required additional documentation.) 

The resubmission requirements as detailed for this exception code are not applicable to a 

contribution effected by money order, cashier's check, traveler's check or other similar 

negotiable instrument as such resubmission is prohibited under 11 CFR §9034.2(c)(4). 

31 This exception code will generally be applied in instances where the written instrument bears no name, 

either as an accountholder, remitter, or signatory, as that of the listed contributor. For example, if a 

personal check which identifies only John Doe as the accountholder represents a joint contribution from 

Mr. Doe and also Jane Smith, the written instrument supporting the matching fund request cannot be 

associated with Ms. Smith. Therefore, additional documentation signed by Ms. Smith which fully 

identifies the written instrument by which her contribution was made is necessary. (Also see 11 CFR 

§104.8(d)). 

Page V-23 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE G-4 

TYPE OF WRITTEN INSTRUMENT SUBMITTED WITHOUT REQUIRED 

AND/OR COMPLETE ACCOMPANYING DOCUMENTATION 

(11 CFR §9034.2(c)(4)) 

A contribution received in the form of a money order, cashier's check, traveler's check, or 

other similar negotiable instrument that, upon initial submission, lacks the contributor's 

signature and additional documentation also signed by the listed contributor which 

specifies that the instrument was purchased with his/her personal funds, and further 

identifies the name of the issuer, the date and amount of the contribution, the check or 

serial number is non-matchable. (See Appendix 22 for a suggested format for a letter to 

obtain the required information that must accompany the initial submission.) 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Such a contribution 

may not be resubmitted. No additional documentation that supplements any of that 

described above will render the contribution matchable. 

Page V-24 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE G-5 

DOCUMENTATION FOR CONTRIBUTIONS RECEIVED AS A RESULT 

OF JOINT FUNDRAISING OR ENTERTAINMENT EVENTS 

(11 CFR §9034.2(c)(5) and 11 CFR §9034.2(c)(7) 

A contribution received as a result of a joint fundraising event for which either no copy 

of the joint fundraising agreement, solicitation material, or an explanation of any 

reallocated amount has been submitted is non-matchable. 

A contribution received as a result of an entertainment event for which either no copy of 

the promotional material or no copy of a ticket at each price has been submitted is nonmatchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: When contributions 

received as a result of a joint fundraising event are submitted for matching purposes, a 

copy of the joint fundraising agreement and the solicitation material for each event must 

accompany the matching fund request. A contribution that has been attributed to the 

candidate/committee in a percentage higher than that specified in the fundraising 

agreement must be accompanied by additional documentation showing the reallocation 

and the basis or reason for the reallocation. 

When contributions received as a result of entertainment events, such as concerts or 

motion pictures, are submitted for matching purposes, a copy of the promotional material 

and a copy of a ticket at each price must accompany the matching fund request. Further, 

the promotional material and ticket(s) must clearly indicate that the ticket purchase price 

represents a contribution to the Presidential candidate. 

Page V-25 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE H 

MISCELLANEOUS CONTRIBUTOR DATA FILE DISCREPANCIES 

EXCEPTION CODE H-l 

MAILING ADDRESS OMITTED, INCOMPLETE, OR INCORRECT 

(11 CFR §9036.3(c)(l)) 

A contribution from an individual whose listing on the contributor data file omits or 

contains an incomplete or incorrect mailing address is non-matchable. For the 

threshold submission only: a contribution from an individual whose listing on the 

contributor data file contains a non-residential address, such as a postal box number in a 

metropolitan area or an apparent business address, is non-matchable for purposes of 

establishing eligibility in a State. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: The contributor 

data file must present each contributor whose contribution is being submitted for 

matching with a full mailing address (street and number, city, and state). For the 

threshold submission only: the preceding information must be that of the listed 

contributor's residential address. 

The contributor records including the contributor database must be supplemented and/or 

corrected. Where a contribution is being resubmitted, the resubmission contributor data 

file must contain, or be accompanied by, a statement to the effect that the 

candidate/committee's contributor records have been corrected. If such a statement has 

been included and a future submission demonstrates the correction(s) was not made, the 

appropriate adjustment will be applied to the next payment certified. In the absence of 

any further payments, the amount will be requested as a repayment pursuant to 26 U.S.C. 

§9038(b)(l) and 11 CFR §9038.2(b)(l). 

Page V-26 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE H-2 

CONTRIBUTOR'S NAME SPELLED INCORRECTLY 

(11 CFR §9036.3(c)(l)) 

A contribution from an individual whose name on the contributor data file is spelled 

incorrectly is non-matchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: The contributor 

data file must present each contributor's full name (last name, first name, middle initial, 

and suffix, if any) spelled correctly. Where a contribution rejected under this exception 

code is being resubmitted, the resubmission contributor data file must contain, or be 

accompanied by, a statement to the effect that the candidate/committee's contributor 

records including the contributor database have been corrected. Where such a statement 

has been included and a future submission demonstrates the correction(s) was not made, 

the appropriate adjustment will be applied to the next payment certified. In the absence 

of any further payments, the amount will be requested as a repayment pursuant to 26 

U.S.C. §9038(b)(l) and 11 CFR §9038.2(b)(l). 

Page V-27 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE H-3 

MORE THAN ONE CONTRIBUTOR IS LISTED PER LINE ITEM 

AND SEQUENCE NUMBER (E.G., MR. AND MRS.) 

(11 CFR §9036.3(c)) 

Contribution(s) from individuals whose listings are merged (e.g., Mr. and Mrs. John Doe) 

on the contributor data file at the same line and sequence number are non-matchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Each contributor 

must be listed on the contributor data file separately. 

Although a single written instrument may represent a contribution from more than one 

individual (e.g., Mr. and Mrs.), each must be listed separately. The contributor data file 

and the contributor records including the contributor data file must be corrected to reflect 

separate listings. Where a contribution rejected under this exception code is being 

resubmitted, the resubmission contributor data file must contain, or be accompanied by, a 

statement to the effect that the contributor records including the contributor data file have 

been corrected. Where such a statement has been included and a future submission 

demonstrates the correction(s) was not made, the appropriate adjustment will be applied 

to the next payment certified. In the absence of further payments, the amount will be 

requested as a repayment pursuant to 26 U.S.C. §9038(b)(l) and 11 CFR §9038.2(b)(1). 

Page V-28 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE H-4 

OMITTED OR INADEQUATE OCCUPATION AND NAME OF EMPLOYER 

FOR LISTED CONTRIBUTOR - THRESHOLD SUBMISSION ONLY 

(11 CFR §9036.1(b)(1)(ii)) 

A contribution from an individual whose aggregate contributions exceed $200 during the 

election cycle (regardless of whether submitted) and for which the contributor data file of 

the threshold submission omits or inadequately describes the contributor's occupation 

and/or name of employer is non-matchable for purposes of establishing eligibility in a 

State. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Each contributor 

whose contribution(s) is to be used to establish eligibility in a State and whose aggregate 

contributions to the candidate/committee exceed $200, must be adequately identified on 

the threshold submission contributor data file by occupation (job title or position) and 

name of employer just as it is required by 2 U.S.C. §434(b)(3)(A) and 11 CFR 

§104.3(a)(4)(i) for disclosure reports. In order to attribute the contribution(s) toward 

meeting a State's threshold (exceeding $5,000), the contributor data file must be 

supplemented and/or corrected. For this purpose, only the contributor data file for the 

particular State(s) need be supplemented and/or corrected. 

Page V-29 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE H-5 

SAME CONTRIBUTOR LISTED IN MORE THAN ONE 

STATE - THRESHOLD SUBMISSION ONLY 

(11 CFR §9033.2(b)(3)) 

Contributions from a contributor who is listed in the threshold submission as a resident of 

more than one state are non-matchable for purposes of establishing eligibility in one of 

the state(s). 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Contributions from 

an individual contributor can be used to establish eligibility in only one state. The 

appropriate state shall be the one in which the contributor was residing on the date on 

which the earliest written instrument is dated. 

The contributor data file and data base must be supplemented and/or corrected to show 

the contributor in only the state of his or her actual residence on the date the earliest 

contribution was made. Where a contribution is being resubmitted, the contributor data 

file must contain, or be accompanied by, a statement to the effect that the 

candidate/committee's contributor records including the database have been corrected. 

For this purpose, only the contributor data file for the particular states involved need be 

corrected. 

Page V-30 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE I 

BANK DOCUMENTATION AND DEPOSIT DATE DISCREPANCIES 

EXCEPTION CODE I-l 

DEPOSIT DATE REFERENCE OMITTED ON WRITTEN 

INSTRUMENT AND CONTRIBUTOR DATA FILE (11 CFR §9036.3(b)(4)) 

A contribution for which the supporting copy of the written instrument and/or the 

contributor data file omits the required date of deposit is non-matchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Each contribution 

submitted for matching must be referenced as appropriate to the correct date of deposit 

on both the contributor data file and/or the supporting copy of the written instrument. 

Page V-31 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE I-2 

CONTRIBUTION NOT TRACEABLE TO BANK 

DOCUMENTATION AS REFERENCED 

(11 CFR §9036.3(b)(4)) 

A contribution that is referenced, either on the written instrument or contributor data file, 

to a deposit date/batch number that cannot be traced to the bank documentation is nonmatchable.32 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Each contribution 

must be referenced to the correct deposit date/batch number as identified on the bank 

documentation (bank statement, validated deposit slip, and batched written instruments). 

 This exception code will be applied in instances where no deposit batch bearing the number of 

the referenced deposit date/batch has been submitted 

Page V-32 

32
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE I-3 

NO BANK STATEMENT TO SUPPORT UNVALIDATED DEPOSIT SLIP 

(11 CFR §9036.3(b)(4)) 

A contribution referenced to a deposit where the only bank documentation submitted is a 

copy of an unvalidated deposit slip is non-matchable.33 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: A contribution 

referenced to a deposit for which no bank statement is submitted (or not yet available) to 

reflect proof of deposit into the depository must be supported by a copy of a validated 

deposit slip. In the absence of the validated deposit slip, a copy of the bank statement is 

required. 

33 This error occurs most commonly where the bank statement listing the deposit has not yet been received 

by the candidate/committee. When contributions are being submitted for matching shortly after their 

receipt, validated deposit slips must be obtained for submission in order to document that they were 

actually deposited. 

Page V-33 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE I-4 

AMOUNT OF TOTAL CONTRIBUTION EXCEEDS AMOUNT 

OF REFERENCED DEPOSIT 

(11 CFR §9036.3(b)(4)) 

A contribution referenced to a deposit where the amount of the total contribution exceeds 

the total amount of the deposit is non- matchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Each contribution 

submitted for matching must be referenced to the correct deposit on the bank 

documentation. 

Page V-34 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE I-5 

CONTRIBUTION DEPOSITED INTO AN UNDESIGNATED DEPOSITORY 

(11 CFR §101.1, 11 CFR §102.2(a)(2), 11 CFR §103.2, and 11 CFR §9034.2(a)(3) 

A contribution deposited into a depository that was not a designated depository at the 

time of receipt of the matching fund submission is non-matchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: Each contribution 

submitted for matching must be deposited into a depository that has been designated 

pursuant to 11 CFR §101.1 on the candidate/committee's Statement of Organization or by 

amendment pursuant to 11 CFR §102.2(a)(2). 

Such contribution should not be submitted for matching. No additional documentation 

will render such a contribution matchable. 

Page V-35 
Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE J 

AGGREGATION ERRORS 

EXCEPTION CODE J-l 

$250 PREVIOUSLY MATCHED FOR LISTED CONTRIBUTOR 

(11 CFR §9036.3(c)(2)) 

A contribution from an individual for whom $250 has been previously requested and 

matched is non-matchable. 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: A contribution 

from an individual for whom $250 has previously been requested and matched cannot be 

resubmitted. 

Page V-36 
 

Chapter V STANDARD EXCEPTION CODES FOR REVIEW OF MATCHING FUND 

REQUESTS 

EXCEPTION CODE J-2 

FULL AMOUNT REQUESTED CAUSES MORE THAN $250 TO 

BE MATCHED FOR LISTED CONTRIBUTOR 

(11 CFR §9036.3(c)(2)) 

A contribution from an individual that causes more than $250 to be requested and 

matched for the listed contributor is non-matchable.34 

MATCHABILITY AND/OR RESUBMISSION REQUIREMENTS: The contributor 

data file must request only an amount that will not cause more than $250 to be requested 

in matching for any one contributor. When determining a contributor's correct aggregate 

total, all amounts submitted, regardless of whether any contribution was rejected as nonmatchable or became NSF must be included. Where an incorrect aggregate total on the 

contributor list (and the candidate/committee contributor records) causes more than $250 

to be requested and matched for the listed contributor in the current submission, the 

amount requested must be adjusted downward so that the $250 threshold is not exceeded. 

The contributor data file and contributor data file must be corrected in order that only the 

amount yet matchable for the contributor is requested. 

Where a contribution rejected under this exception code is being resubmitted, the 

resubmission contributor data file must contain, or be accompanied by, a statement to the 

effect that the candidate/committee's contributor records including the contributor data 

file have been corrected. Where such a statement has been included and a future 

submission demonstrates the correction(s) was not made, the appropriate adjustment will 

be applied to the next payment certified. In the absence of any further payment, the 

amount will be requested as a repayment pursuant to 26 U.S.C. §9038(b)(1) and 11 CFR 

§9038.2(b)(1). 

34 This exception code differs from J-l in that a portion of the amount requested is matchable as the $250 

threshold was not exceeded until the current matching fund request was made. 

Page V-37 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

Chapter VI 

GUIDANCE - RE: MATCHABILITY/NON-MATCHABILITY OF TYPES 

OF WRITTEN INSTRUMENTS/DISCREPANCIES ON CONTRIBUTOR DATA 

FILE 

GENERAL 

While the Exception Codes described in the preceding chapter describe the requirements 

to be met by both the written instruments and contributor data file for matchability, the 

Commission, through its administration of previous matching fund programs, recognizes 

that not each contribution will be clearly matchable or non-matchable per those 

requirements. This chapter presents situations involving types of written instruments and 

the information appearing on them. The situations are described under the possible 

Exception Code that might be considered as applicable and, in chart form, advises 

whether such a contribution may be viewed as "Immediately Matchable," "Later 

Matchable," or "Never Matchable." Again, candidates/committees are urged to withhold 

from submission any contribution for which the matchability may be in doubt until 

complete additional documentation as described in Chapter V. of this Guideline has 

been obtained. 

Page VI-1 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

I N D E X 

POSSIBLE 

EXCEPTION EXAMPLE PAGE 

SUBJECT CODE NO. NO. 

ADDITIONAL DOCUMENTATION 

Containing only date and amount G-3 2 VI-24 

Identifying different contribution C-5 2 VI-16 

Inadequate for signature discrepancy D-1 3 VI-17 

Signed by one having power of attorney D-1 2 VI-17 

Signed by other than to whom sent C-5 1 VI-16 

Supports non-matchability C-5 3 VI-16 

AMOUNTS OF WRITTEN INSTRUMENTS 

Discrepancies: 

Amount requested in excess of matchable 

portion F-2 1 VI-22

Bearing only written or numeric amount E-3 3 VI-20 

Numeric/written amounts disagree E-3 2 VI-20 

ATTRIBUTION TO ANOTHER CONTRIBUTOR 

Conflicting statements – Re: attribution B 3 VI-13 

Portion previously matched B 2 VI-13 

Which of multiple contributions from one 

contributor are matchable for another B 1 VI-13 

To non-partner in a partnership or nonmember on unincorporated association or 

business C-2 4 VI-15

Written instruments previously matched B 2 VI-13 

BUSINESS CHECKS/ACCOUNTS 

Altered accountholder C-1 3 VI-14 

Business appearance of personal check C-1 4 VI-14 

Having appearance of personal check C-1 1 VI-14 

Typed statements for matchability C-1 2 VI-14 

Page VI-2 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

POSSIBLE 

EXCEPTION EXAMPLE PAGE 

SUBJECT CODE NO. NO. 

CASH MANAGEMENT/MUTUAL FUNDS ACCOUNTS 

No signature of contributor A-1 5 VI-8 

With signature of contributor A-1 4 VI-8 

CASHIER'S CHECKS - See Money Orders/Cashier's Checks 

CONTRIBUTOR DATA FILE 

Amounts requested F 1, 2 VI-22 

Mailing address H-1 1 VI-25 

CONTRIBUTORS 

Deleted G-1 1 VI-23 

Hyphenated name H-2 1 VI-26 

No association with written instrument G-3 1 VI-24 

Misspelled – impact on alphabetical list H-2 1 VI-26 

CORPORATE CHECKS/ACCOUNTS 

Named professional individual with initials 

P.A., P.C., or LLC A-1 3 VI-8 

Represents contribution through corporate/ 

labor employee participation plan A-2 4 VI-9 

When named in accountholder identification A-1 6 VI-8 

With personal funds statement A-1 1 VI-8 

With statement – Re: non-incorporated 

status A-1 2 VI-8 

DATES OF CONTRIBUTIONS 

Discrepancies in: 

Absent or incomplete E-4 3 VI-21 

Dated prior to January 1 of the year 

preceding the year of the election E-4 1 VI-21 

Omitted year E-4 2 VI-21 

Page VI-3 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

SUBJECT 

POSSIBLE 

EXCEPTION 

CODE 

EXAMPLE 

NO. 

PAGE 

NO. 

EMPLOYEE PARTICIPATION PLAN 

Contributions drawn on accounts of A-2 4 VI-9 

EXCESSIVE CONTRIBUTIONS 

Caused by more than one contribution A-4 4 VI-10 

Excessive portion – refunded A-4 2 VI-10 

Excessive portion – reattributed A-4 1 VI-10 

Single written instrument from more than 

one contributor A-4 3 VI-10 

Personal check A-4 1 VI-10 

Money order or similar written instrument A-4 3 VI-10 

FOREIGN CONTRIBUTIONS 

Foreign address and foreign bank account A-6 1 VI-12 

U.S. address and foreign bank account A-6 2 VI-12 

ILLEGIBLE SIGNATURE E-1 3 VI-19 

JOINT ACCOUNTS 

Changing contributor records D-2 3 VI-18 

Two names as one signatory D-2 1 VI-18 

LABOR ORGANIZATION 

When named in accountholder identification A-1 6 VI-8 

LOANS 

Contribution upon forgiveness A-3 1 VI-10 

Page VI-4 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

POSSIBLE 

EXCEPTION EXAMPLE PAGE 

SUBJECT CODE NO. NO. 

MAILING ADDRESS 

Corporation, labor organization or trade 

association named in account holder I.D. A-1 6 VI-8 

Foreign A-6 1 VI-12 

Erroneous city or state H-1 3 VI-25 

Of contributor’s bank H-1 2 VI-25 

Omitted street and number H-1 4 VI-25 

Spouse’s business address H-1 1 VI-25 

MONEY ORDERS/CASHIER'S CHECKS 

Representing multiple contributions from: 

Members of political organization A-2 2 VI-9 

Two or more individuals A-4 3 VI-10 

MUTUAL FUNDS ACCOUNTS – See Cash Management Accounts 

P.A. (PROFESSIONAL ASSOCIATES) 

Following named professional individual A-1 3 VI-8 

P.C. (PRIVATE CORPORATION) 

Following named professional individual A-1 3 VI-8 

LLC (Limited Liability Company) 

Following named professional individual A-1 3 VI-8 

PARTNERSHIP CHECKS/ACCOUNTS 

Additional documentation supports nonmatchability C-5 3 VI-16 

Attribution to non-partner spouse C-2 4 VI-15 

Designated drawing account C-2 1 VI-15 

Requested amount in excess of attributed 

amount 

F-2, 

C-2 

1 

2 

VI-22 

VI-15 

Page VI-5 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

SUBJECT 

POSSIBLE 

EXCEPTION 

CODE 

EXAMPLE 

NO. 

PAGE 

NO. 

PAYEE ON WRITTEN INSTRUMENT 

Discrepancies: 

Absent E-2 1 VI-20 

Dual payee A-5 5 VI-11 

Payable to cash A-5 4 VI-11 

Payable to House/Senate authorized 

committee A-6 3 VI-12 

Payable to individual A-5 2 VI-11 

Payable to political party organization A-5 1 VI-11 

Proper contributor A-5 3 VI-11 

PERSONAL CHECKS/ACCOUNTS 

Accountholder’s signature executed by 

another D-1 3 VI-17 

Business appearance of C-1 4 VI-14 

Facsimile signature D-1 5 VI-17 

Incomplete signature D-1 4 VI-17 

Joint accounts D-2 1, 2, 3 VI-18 

Power of attorney, signed by one having D-1 2 VI-17 

Signature other than accountholder D-1 1 VI-17 

POLITICAL COMMITTEES/ORGANIZATIONS 

Representing candidate’s personal 

contribution A-2 3 VI-9 

Contribution drawn on account of A-2 1 VI-9 

Earmarked through A-2 1 VI-9 

Drawn on employee participation plan A-2 4 VI-9 

Contribution from members of A-2 2 VI-9 

POWER OF ATTORNEY 

Written instrument/additional 

documentation signed by D-1 2 VI-17 

Page VI-6 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

SUBJECT 

POSSIBLE 

EXCEPTION 

CODE 

EXAMPLE 

NO. 

PAGE 

NO. 

"SPLIT" CONTRIBUTIONS B 1, 2, 3 VI-13 

(Also see attribution to another contributor) 

SIGNATURES ON WRITTEN INSTRUMENTS 

Facsimile D-1 5 VI-17 

Illegible E-1 3 VI-19 

Incomplete D-1 4 VI-17 

Joint accounts D-2 1, 2, 3 VI-18 

TRADE ASSOCIATION 

When named in accountholder identification A-1 6 VI-8 

Page VI-7 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: A-1 Description of Written Instrument or Situation: 

Prohibited Corporate/Labor Contributions 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. Corporate check with additional documentation from 

owner/contributor stating that the account contains and/or represents his/her personal funds. 

X 

1. Regulations at 11 CFR §9

matching if transmitted opersonal funds statement

2. “Inc.” appears after business name on check. 

Additional documentation from contributor states account is not maintained by an incorporated entity and account contains and/or represents his/her personal funds. 

X 

2. Matchable only if further 

contributor provides date be incorporated and chec

3. Named professional individual (doctor, dentist, etc.) 

whose name is followed by letters such as P.A. or P.C. 

X 

3. In most instances, verific

Secretary of State determincorporated his/her prac

4. Cash Management or Mutual Funds Accounts that 

bear the business firm name, usually a corporation, but which actually represents the contributor’s personal funds, and contains the contributor’s signature. 

X 

4. This contribution is matc

5. Cash Management or Mutual Funds Account as 

described in 4. above, with the contributor’s name printed or typed but bearing no signature. 

X 

5. Additional documentatio

acknowledging the contr

6. Corporation, Labor Organization, or Trade 

Association identified as part of the mailing address under the name of the accountholder on what appears to be a personal check. 

X 

6. This contribution is matc

drawn on a personal accoaccount holder uses the cmailing address. . 

Page VI-8 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: A-2 Description of Written Instrument or Situation: 

Political Committee and Earmarked Contributions 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. Check, drawn on political committee or organization 

account, is signed by Treasurer. Additional documentation contains signature of earmarking contributor. 

X 

1. Regulations at 11 CFR §9

matching of any earmarkconduit’s account. 

2. Money order, accompanied by additional 

documentation, signed by an individual stating the money order represents contributions from various members of the organization. X 

2. Money order does not rep

the individual for submisAdditional documentatioattributed to the various initial submission, toget

documentation required 

3. Check drawn on campaign fund of an individual who 

is (or was) either a federal, state, or local candidate is signed by the named candidate. Additional documentation states the account represents his/her personal funds. 

X 

3. Regulations at 11 CFR §9

matching of contributionon the account of a politi

4. Check drawn on an Employee Participation Plan 

(EPP), with the individual contributor’s name typed or imprinted, but signed by the executor of the Plan. 

X 

4. Additional documentatio

contributor must be obta

Page VI-9 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: A-3 Description of Written Instrument or Situation: 

Refunds and Loans 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. A check, originally received as a loan from an 

individual, is forgiven, becoming a contribution X 

1. Additional documentatio

original loan, the date thamount forgiven must b

Possible Exception Code: A-4 Description of Written Instrument or Situation: 

Excessive Contributions 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. Check is payable in an amount exceeding $2,300 and 

is annotated to indicate that it represents a joint contribution (e.g. “for Mr. & Mrs.” on the memo line). Only one signature appears on the check. X X 

1. May be immediately mat

matchable in every other documentation to obtain contributors is being obtcalendar days of receipt submitted and matched) 

2. Check is payable in an amount exceeding $2,300, 

amount over $2,300 has been refunded. X 2. The first $2,300 may be s

$250. 

3. Money order in excess of $2,300 accompanied by 

additional documentation signed by two or more individuals that fully acknowledges their contribution and the amount to be attributed to each. 

X 

3. A written instrument of a

contributions from more additional documentation 11 CFR §104.8(d). 

4. A $2,300 contribution is received and processed. The 

contributor data file requests an amount less than $250 in matching funds. X X 

4. Contributor data file indi

$100 received and previoThe first $2,300 may be $250. 

Page VI-10 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCHABLE Possible Exception Code: A-5 Description of Written Instrument or Situation: 

Payee Discrepancies 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. Written instrument is made payable to a party 

committee (National, State, or local) with memo entry containing the candidate/committee name. 

X 

1. Written instruments mus

candidate or an authorizenotations on their face. (

2. Written instrument is made payable to a campaign 

worker with memo entry containing the candidate/ committee name. X 

2. Same as 1. above. If end

committee by the campamust be viewed as the cathe original maker. 

3. Written instrument is made payable to an individual. 

Both sides of the instrument attest to the endorsement to the candidate/committee. However, the recorded contributor is the accountholder or original remitter. X 

3. The individual who exec

contributor. The recordecontribution. Additional the Guideline in which thacknowledges the contrib

see Exception Codes G-2 

4. Written instrument is made payable to “Cash” with a 

memo entry containing the candidate/committee name. 

X 

4. Same as 1. above. 

5. Written instrument is made payable to the candidate 

and another individual or an entity other than the authorized committee. X 

5. To demonstrate donative 

must be made payable to (Exemption: Contributi– see Chapter III.K.) 

Page VI-11 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: A-6 Description of Written Instrument or Situation: 

Miscellaneous Non-Matchable Contributions 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

Possible Foreign Contributions: 1. Contributor has foreign address and maintains account 

at either a foreign or U.S. bank. X 

1. Statement from the contr

verify that he/she is a citpermanent resident of th

2. Written instrument is drawn on bank in a foreign 

country and contains no accountholder I.D.; contributor provides a U.S. address. 

X 

2. Only currency of a foreig

States is prohibited. (11C

Questionable Donative Intent: 3. Candidate is also a candidate for another federal 

office. Written instrument is made payable to the Senate or House committee of the candidate 

X 

3. Payee is not an authorize

presidential primary cambe matched. 

Page VI-12 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: B Description of Written Instrument or Situation: 

Same Written Instrument Submitted more than Once 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. Five contributions of $100 are “split” by obtaining 

additional documentation from the spouse of the original contributor for whom the first three were submitted and matched for $250. All five contributions are submitted later for the spouse listing each at $50. 

X 

1. Not matchable as submit

Contributions #3, #4, and matching in the amount maximum allowable, conand additional documentreattribute contributions 

2. Contribution of $500 has been submitted and matched 2. Exception code B applies 

for $250 for one spouse. Additional documentation is previously matched for $obtained to attribute 50% to the other spouse and X documentation, this situa

$250 is requested on a later submission supported by contributor for whom the a copy of the same written instrument. may be submitted. 

3. Additional documentation sent to attribute a portion of 

an original contribution to another individual contains two statements: (1) the contribution is solely the original contributor’s and (2) a portion of the original contribution should be attributed to another individual. The original contributor returns the additional documentation with both statements checked. 

X 

3. Can not be submitted for 

statement (1) signed by tover statement (2). Corrdocumentation with only 

be obtained before subm

Page VI-13 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: C-1 Description of Written Instrument or Situation: 

Contributions Drawn on Apparent Business Accounts 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. Accountholder is identified as: 

SMITH FARMS John Smith 

John Smith signs the written instrument. 

X 

1. Additional documentatio

drawn on business accouas accountholder (even tpersonal check) governs 

2. Written instrument has all the information needed to 

support matchability typed on its face and is signed by contributor. X 

2. Additional documentatio

the information. Someoncontributor can place typthe instrument. 

3. Written instrument has business name crossed-out and 

the contributor’s name is printed or typed above the accountholder I.D. 

X 

3. Additional documentatio

business account must b

4. Written instrument identifies an individual and his/her 

occupation description as part of the accountholder I.D.; address appears to be non-residential. The instrument appears to be a business check with a memo entry indicating the contribution is a business expense. 

X 

4. Same as 3. above; the add

required because of the bthe face of the instrumen

5. Written instrument accountholder I.D. same as 4. 

above. The address may or may not be residential and there is no evidence of business usage. 

X 

5. May be submitted for ma

documentation. 

Page VI-14 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: C-2 Description of Written Instrument or Situation: 

Contributions Drawn on Partnership, Group or 

Association Account 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. Written instrument drawn on partnership account is 

identified as the drawing account of the identified partner who is listed as the contributor 

X 

1. Partnership drawing acco

represent the individual p

2. Written instrument for $2,500 drawn on a partnership 

with accompanying documentation indicating that the contribution is to be equally attributed to ten partners. X 

2. May be submitted and m

partner providing signatuover the $2,300 contribuCFR §110.1(e)) is to be r

3. Written instrument for $500 drawn on a partnership is 

properly attributed in the amount of $125 for each of four partners. Additional documentation is received from one partner and the full amount of the contribution is attributed to him/her, with $250 requested for matching. 

X 

3. Evidence suggests the pa

the amount of $125. The adjusted and only $125 iAdditional documentatioother partners for later suException Code F-2). 

4. Written instrument for $500 drawn on a partnership 

that is submitted for matching, with the required additional documentation, for one partner. A reattribution of $250 is made to the spouse of the partner and submitted for matching. 

X 

4. In Advisory Opinion 198

concluded that no portiocould be attributed to an partner. 

Page VI-15 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: C-5 Description of Written Instrument or Situation: 

Inadequate Additional Documentation 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. Additional documentation sent for signature is 

returned signed by someone other than the contributor. 

X 

1. Additional documentatio

individual to whom it wathe written instrument. 

2. Additional documentation returned by the contributor 

acknowledges a contribution was made but provides a different amount, date and check number from the written instrument being submitted. 

X 

2. Similar to 1. above; addit

and sent to the contributo

contribution being subm

3. On the additional documentation returned by the 

contributor, the “personal funds” statement is altered to read “partnership funds”. 

X 

3. Additional documentatio

matchability of a contrib

Page VI-16 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: D-1 Description of Written Instrument or Situation: 

Signature Other than Accountholder 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. A personal check, drawn on an account identifying 

only one individual as the accountholder, is signed by another individual. Accompanying documentation signed by the accountholder advises that the individual who signed the instrument is also a joint tenant of the account. 

X 

1. The contribution is drawn 

attributed to the signator

2. A personal check and accompanying documentation is 

signed by an individual who has power of attorney for the identified accountholder/contributor. 

X 

2. The signature of the acco

the additional documentacontribution must be obt

3. A personal check bears an indication that the signature 

corresponding to the name of the identified accountholder was executed by someone other than the accountholder, i.e. “/S/” following the signature. 

X 

3. Same as described in 2. a

4. A personal check contains only the last name of the 

identified accountholder. X 

4. For personal checks it is 

contained on the instrumand is accepted by the fin

5. A personal check contains only a “facsimile” 

signature (i.e. stamped) on the signatory line. X 5. Same as described in 4. a

Page VI-17 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: D-2 Description of Written Instrument or Situation: 

Signature Discrepancy on Joint Account 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. A check drawn on a joint tenant account is signed by 

one of the accountholders for both (i.e. “John and Jane Smith”). 

X 

1. Additional documentatio

contributor/signatory mu

2. A contribution as described in 1. above is attributed 

equally to both accountholders. X 2. Additional documentatio

the signature of the non-

3. A solicitation sent to John Smith results in a 

contribution drawn on a joint tenant account that is signed by Jane Smith. John Smith is the named contributor on the committee’s records and matching fund submission. 

X 

3. The individual who signe

presumed to be the contrmust be changed to refleadditional documentation 

John’s signature and ack

Page VI-18 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: E-1 Description of Written Instrument or Situation: 

Written Instrument Lacks Contributor’s Signature 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. A money order, cashier’s check, or similar written 

instrument bears only the typed name of the contributor. 

X 

1. The signature of the cont

documentation must acc

submission. 

2. A money order representing an equal joint 

contribution from two individuals bears the signature of one contributor but only the typed name of the second contributor. The required additional documentation has been obtained from both individuals. 

X (a) X (b) 

2.(a). The contribution for ththe money order is matchable

(b). Even though the requ

for the second contributocontribution is not matchthe individual was not ooriginally submitted for 

3. A check having no printed accountholder 

identification bears an illegible signature. 

X 

3. Additional documentatio

identifies the contributor signature on the instrumeThe signature on the addbe the same as on the inssignature. 

4. A personal check signed by the accountholder 

contains a notation on the memo line that the contribution is for another individual. X 

4. Additional documentatio

individual’s contribution contains his/her personal individual must be obtaiidentified under Exceptio

Page VI-19 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: E-2 Description of Written Instrument or Situation: 

Omitted Payee 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. The payee line of the written instrument was left 

blank by the contributor X 

1. Regulations at 11 CFR §

instruments to be made phis/her authorized comm

Possible Exception Code: E-3 Description of Written Instrument or Situation: 

Discrepancy in Amount of Written Instrument 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. The numeric and written amount on the copy of the 

written instrument cannot be determined. X 1. The copy of the written i

amount requested for ma

2. The numeric and written amounts on the written 

instrument do not agree X X 2. Provided the contributor 

lesser amount, the contri

3. The written instrument contains only a written or 

numeric amount but not both. X 3. There is no discrepancy i

negotiate the instrument 

Page VI-20 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: E-4 Description of Written Instrument or Situation: 

Discrepancy in Date on Written Instrument 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. The written instrument is dated prior to January 1 of 

the year preceding the calendar year of the Presidential election. 

X 

1. Regulations at 11 CFR §9

Instrument must be datedeposited on or after Janthe calendar year of the P

Exception: If the instru

or early February of the year of the Presidential ethe instrument is the prioerror on the part of the crecent year change and tmatchable. 

2. The written instrument, made payable to the candidate 

rather than the committee, bears a December date but omits the year. 

X 

2. Despite the date of depos

the instrument provides ncontribution was receiveaccordance with the reguis a dual federal candidatcommittee was in operatcontribution was intendecampaign. See 3. below

3. The written instrument is not dated. 

X 

3. Additional documentatio

contributor that acknowlmonth and year that the c

Page VI-21 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: F-1 Description of Written Instrument or Situation: 

Requested Amount Exceeds the Amount of the Written 

Instrument 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. The contributor data file requests more in matching 

funds than the amount of the written instrument. X 

1. The contributor data file 

corrected to request the ainstrument. 

Possible Exception Code: F-2 Description of Written Instrument or Situation: 

Requested Amount Exceeds the Amount of the 

Contribution from the Listed Contributor 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. A check in the amount of $500 is drawn on a 

partnership account and identifies the attribution to be $125 from each of four partners. Additional documentation is received from one partner and the full amount is attributed to him/her with $250 requested in matching funds. 

X 

1. The written instrument an

indicates the partner madThe contributor records mrequested in matching fudocumentation should be partners for later submis

Page VI-22 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: G-1 Description of Written Instrument or Situation: 

Omitted Written Instrument 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. In place of a copy of the written instrument, a sheet is 

inserted indicating that the contribution has been deleted. An entry for the contributor remains on the contributor data file. 

X 

1. When a contribution has 

data file must be correctethe controlling factor in rwritten instruments only amounts. 

Possible Exception Code: G-2 Description of Written Instrument or Situation: 

Written Instrument does not Support the Request for the 

Listed Contributor 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. A check identifying Jane Smith as the sole 

accountholder and signed by Jane Smith is the written instrument submitted to support a matching fund request for John Smith who resides at the same address. 

X 

1. The submitted written ins

matching fund request. Edocumentation from Joh

the contributor data file sSmith as the contributor, previously matched for $

2. A check signed by the accountholder contains a 

notation on the memo line that the contribution is for another individual. X 

2. Additional documentatio

individual’s contribution contains his/her personal individual must be obtai

Page VI-23 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: G-3 Description of Written Instrument or Situation: 

Written Instrument cannot be Associated with Listed 

Contributor 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. A written instrument identifying John Smith as the 

accountholder or remitter is submitted to support a matching fund request for Mary Jones. X 

1. Additional documentatio

in which Mary Jones ackwas made by a check draSmith and states that the funds must be obtained. 

2. A written instrument in the amount of $500 on which 

the contributor is neither identified as an accountholder or remitter/purchaser is submitted in support of a $50 matching fund request. Additional documentation acknowledges only that the contributor made a contribution of $50 on a given date. 

X 

2. As described in 1. above

written instrument by whadditional documentation 

amount and date of a conassurance the submitted that supports the matchin

Page VI-24 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: H-1 Description of Written Instrument or Situation: 

Incorrect, Incomplete or Omitted Mailing Address 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. On a regular submission, the mailing address listed for 

Jane Smith is actually the business address of John Smith. X 

1. It is presumed that the co

through the listed mailinresidential address is on

Submission. 

2. On a regular submission, the mailing address listed for 

a contributor is that of a bank at which the individual’s account is maintained because there was no address imprinted in the accountholder identification. 

X 

2. The contributor data base 

address at which the indi

3. On a regular submission, the mailing address listed on 

the contributor data file is different (erroneous street name or number, city or state) than the mailing address on the written instrument. 

X 

3. Although matchable, data 

aggregation errors. 

4. The mailing address on the contributor data base 

omits the street name and number. X 

4. If the contributor is listed 

city having more than onaddress (including street 

Page VI-25 
Chapter VI GUIDANCE REGARDING MATCHABILITY OF CONTRIBUTIONS 

EXAMPLES OF WRITTEN INSTRUMENTS – IMMEDIATE, LATER OR NEVER MATCH

Possible Exception Code: H-2 Description of Written Instrument or Situation: 

Incorrect Alphabetization 

Immed. 

Match 

Later 

Match 

Never 

Match 

Action R

Matchability 

1. Misspelling of a contributor’s name. X 1. Contributors’ names mus

data file in order to be m

Page VI-26