Earmarked contributions
When a political committee receives and forwards an earmarked contribution to a candidate or a candidate’s authorized committee, the PAC is serving as a conduit. The PAC must forward the earmarked contribution to the recipient candidate committee within 10 days of receiving the contribution.
In addition to reporting this activity on the relevant report, the PAC will also give a special transmittal report to the authorized committee receiving the contribution. The report includes all of the information that the candidate committee will need for its own records and to report receiving the earmarked contributions.
Reporting on PAC forms
On its regularly scheduled reports, the PAC will report receiving and forwarding earmarked contributions on Schedules A and B.
If the earmarked contribution was:
- Transmitted through the PAC’s account, it must be disclosed on the reporting schedules for itemized receipts (Schedule A) and itemized disbursements (Schedule B).
- Transmitted in the form of the original contributor’s check, it must be reported as a memo entry on Schedules A and B.
Step 1: Reporting receiving an earmarked contribution
Political action committees report receiving earmarked contributions on Form 3X, Line 11. The line number used to report a contribution given through a conduit depends on who is giving the original contribution. For example, an original contribution that comes from an individual is reported on Line 11(a)(i) while an original contribution that comes from a political action committee is reported on Line 11(c).
On Schedule A, the PAC itemizes:
- The name and mailing address of each person making an earmarked contribution, including earmarked contributions of $200 or less
- The occupation and employer of each individual making an earmarked contribution exceeding $200
- The candidate designated by the contributor as the recipient of the contribution
- The amount of the earmarked contribution
- The election designated by the contributor, if any
- The date the contribution was received by the conduit
The PAC received a contribution from Simone that was earmarked for Gambino for Senate. Since the PAC deposited the contribution in its bank account, it reports Simon’s contribution on Line 11(a) along with her information, the date the contribution was received, the amount, the designation, and a clear notation that the contribution was “Earmarked for Gambino for Senate.
Step 2: Reporting forwarding an earmarked contribution
Political action committees report forwarding earmarked contributions on Form 3X, Line 23.
On Schedule B, the PAC itemizes:
- The candidate designated by the contributor
- The date the contribution was forwarded to the candidate
- The amount forwarded to the candidate
- The election designated by the contributor, if any
- The name of the contributor
- A notation of whether the contribution was passed on in cash, by the contributor’s check or by the conduit’s check
- A statement indicating that the conduit’s limit was also affected, if appropriate
The PAC reports giving the contribution from Simone to Gambino for Senate on Line 23. The PAC reports the committee’s name and information, the date the contribution was forwarded to the candidate, the amount, the designation, and the name of the contributor.
Undeposited contributions
If the committee forwards the contribution without depositing it first, the committee must itemize the same information listed in Steps 1 & 2 as memo entries. These entries should indicate that the contribution was passed on in the form of the contributor's original check and, if appropriate, should indicate that the conduit’s limits for that candidate were affected.
The PAC did not deposit the contribution from Amelia into its account, and so it shows the earmarked contribution on Schedule A as a memo entry.
The PAC also shows giving the earmarked contribution to Gambino for Senate on Schedule B as a memo entry since it did not deposit the contribution from Amelia into its account.
Transmittal report
Along with the funds, the conduit must also forward to the recipient candidate committee a transmittal report containing information that the candidate’s campaign committee will need for its own records and reports.
Contributions exceeding $50
When an earmarked contribution exceeds $50, the accompanying transmittal report must contain the name and mailing address of the original contributor, the date the contribution was received by the conduit and the amount. The report should also state the election designated by the contributor, if any.
Contributions exceeding $200
When an earmarked contribution exceeds $200, the accompanying report must contain the full name and mailing address of the contributor, the contributor’s occupation and name of employer, the date the contribution was received by the conduit and the amount. The report should also state the election designated by the contributor, if any.
Reporting with FECFile
To enter a receiving an earmarked contribution, go to the Summary Page tab, right click on the appropriate Line 11 and select ”new.” If the contribution did not pass through the committee’s bank account, check the “memo” box.
To enter forwarding an earmarked contribution to the candidate committee, go to the Summary Page tab, right click on “Line 23 Contributions to other federal candidates and political committees” and select “new.” If the contribution did not pass through the committee’s bank account, check the “memo” box.
