Disseminating an IE first and paying in a later reporting period
A PAC can disseminate an independent expenditure and then pay for the IE in a later reporting period. In addition to filing any 24 or 48-hour reports that may be required, the committee reports the independent expenditure as an outstanding debt until the expenditure is paid.
Reporting on PAC forms
Part 1: Reporting the dissemination of an independent expenditure
When a PAC disseminates an independent expenditure and then pays for it in a later reporting period, the committee reports the independent expenditure on Form 3X, Schedule E in addition to reporting the debt incurred on Schedule D.
The PAC discloses the dissemination of the independent expenditure as a memo entry on Schedule E, supporting Line 24.
To itemize this independent expenditure, the committee discloses:
- Name and address of payee if the payment or disbursement exceeds the $200 aggregate threshold for itemization
- Date of dissemination
- The payment date if known (if unknown, leave the field blank)
- Amount
- Purpose of expenditure (e.g. radio, television, newspaper ad)
- Candidate supported or opposed, including the candidate’s name, office sought, state and district (if applicable), and election for which the disbursement was made
- Total amount expended in the aggregate during the calendar year per election, per office sought
- Memo item box – check this box if the IE was disseminated, but not paid for during the reporting period
The PAC reports disseminating the independent expenditure on Schedule E of the 2018 June Monthly Report (covering 5/1/18-5/31/18). Since the independent expenditure has been disseminated but not yet paid for, the PAC checks the “Memo Item” box. The PAC discloses the payee’s name and address, the date of dissemination since that is the only date known, the amount of the independent expenditure, the aggregate for this election and race in this calendar year, and a clear purpose, “TV Ad.” The PAC also includes that the independent expenditure was made to support Louisa Adams in the 2018 primary election for Massachusetts’ Senate seat.
The PAC also discloses the IE as a debt on Schedule D, supporting Line 10 in the report that covers the IE’s dissemination.
The PAC disseminated an independent expenditure on 5/11/18 and hasn’t paid for it yet. The PAC reports a debt owed to Blue Star Productions on the 2018 June Monthly Report (covering 5/1/18-5/31/18) using Schedule D, supporting Line 10. The committee includes the address and a clear debt purpose, "TV Ad." The committee shows an outstanding balance beginning this period of $0, $14,500 was incurred this period, $0 payments were made, and the outstanding balance at the close of this period is $14,500.
The committee will continue reporting the debt on Schedule D until the debt is paid
Learn more about reporting debts.
Part 2: Reporting paying for an independent expenditure
When the PAC pays for the independent expenditure on a subsequent report, the PAC itemizes the IE on Schedule E again, this time as a regular entry.
The PAC pays for the independent expenditure on 6/17/18, on the 2018 July Monthly Report (covering 6/1/18-6/30/18) as a regular entry (not a memo item). The PAC discloses the payee’s name and address, the date of dissemination and date of disbursement since both are known, the amount of the independent expenditure, the aggregate for this election and race in this calendar year, and a clear purpose, “TV Ad.” The PAC also includes that the independent expenditure was made to support Louisa Adams in the 2018 primary election for Massachusetts’ Senate seat.
The PAC will also show the debt payment on Schedule D.
The PAC also shows the debt payment to Blue Star Productions on Schedule D, supporting Line 10. It shows the vendor's address and clear debt purpose, "TV Ad." Additionally, the committee shows the $14,500 debt outstanding at the beginning of the period, $0 incurred this period, $14,500 paid this period, and $0 outstanding at the close of this period.
Learn more about reporting debt payments.
Certification
Schedule E requires a certification, under penalty of perjury, that the expenditure meets the standards for independence.
Reporting with FECFile
To add independent expenditures to a report, go to the Reports tab and select the report covering the independent expenditure. Next, go to the Summary Page tab, right click on “Line 24 Independent expenditures” and select “new.”
