Paying for an IE first and disseminating in a later reporting period
A PAC can pay for an independent expenditure and then disseminate the IE in a later reporting period. The committee has two options for reporting this activity, in addition to filing any 24 or 48-hour reports that may be required.
Reporting on PAC forms
PACs report independent expenditures on Form 3X, Schedule E supporting Line 24. The committee itemizes any independent expenditure that exceeds the $200 itemization threshold, or that, when aggregated on a per-election and per-office sought basis within the calendar year, exceeds $200. This includes independent expenditures that were previously disclosed on 24 and 48-hour reports using Schedule E.
Option 1: Report the initial expenditure as an operating expenditure
On the report covering the payment:
Report the independent expenditure as a disbursement on Schedule B, supporting Line 21(b) in the report during which the payment is made.
The PAC reports spending $13,000.00 on a TV advertisement on Schedule B, Line 21(b) of the 2018 April Monthly Report (covering 3/1/18 – 3/31/18). It includes the vendor's name, address, date of disbursement, and amount spent. The committee also includes a clear purpose of disbursement, "Pre-payment for television ad."
On the report covering the dissemination:
Report the independent expenditure and its date of dissemination on Schedule E, supporting Line 24, in the report during which the independent expenditure is disseminated.
To itemize an 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
- Amount
- Purpose of the 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
- Aggregate amount during the calendar year per election, per office sought
The PAC disseminated an independent expenditure supporting Elizabeth Monroe on 4/12/18. The PAC reports this activity on Schedule E of the 2018 May Monthly Report (covering 4/1/18 – 4/30/18). The PAC discloses the payee’s name and address, the date of dissemination, the amount of the independent expenditure, the aggregate for this election and race in this calendar year, and a clear purpose, “Television advertisement - see Schedule B.” The PAC also includes that the independent expenditure was made to support Elizabeth Monroe in the 2018 primary election for Virginia’s Senate seat.
The PAC also itemizes the previous expenditure on Schedule B, supporting Line 21(b). The amount will be a negative entry to prevent deflating the committee’s cash on hand since the entry has been moved to Schedule E, supporting Line 24.
The PAC discloses the independent expenditure as a negative entry on Schedule B, supporting Line 21(b). It includes the vendor’s name and address, date, amount spent as a negative entry, and a purpose of disbursement linking the negative entry to the independent expenditure disclosed on Schedule E, “TV ad (IE paid 3/2/18, see Schedule E).”
Option 2: Report the initial expenditure as an independent expenditure
As an alternative, PACs can report the independent expenditure on Schedule E in the report during which the payment is made.
The PAC paid for an independent expenditure supporting Elizabeth Monroe on 3/2/18. The PAC reports the independent expenditure on the 2018 April Monthly Report (covering 3/1/18 - 3/31/18) using Schedule E. The PAC discloses the payee’s name and address, the payment date since that is the only known date, the amount of the independent expenditure, the aggregate for this race in this calendar year, and a clear purpose, “Pre-payment for television advertisement.” The PAC also includes that the independent expenditure was made to support Elizabeth Monroe in the 2018 primary election for Virginia’s Senate seat.
Certification
Schedule E requires a certification, under penalty of perjury, that the expenditure meets the standards for independence.
Reporting with FECFile
To add operating expenditures to a report, go to the Summary Page tab, right click on “Line 21(b) Other federal operating expenditures” and select “new.”
To add independent expenditures to a report, go to the Summary Page tab, right click on “Line 24 Independent expenditures” and select “new.”
