Fundraising for the PAC
This page outlines the rules that apply to nonconnected PAC fundraising.
Who may be solicited
A nonconnected committee may solicit contributions from anyone in the general public who may lawfully make a contribution in connection with a federal election. Corporations and labor organizations may lawfully contribute to a Super PAC or the non-contribution account of a Hybrid PAC.
Solicitation methods
The most common methods of soliciting contributions for a nonconnected committee are:
Oral solicitations
Solicitations may be made orally—for example, in a speech, a meeting or over the phone.
General public political advertising
The committee may solicit contributions through general public political advertising, such as print or broadcast advertisements, telephone banks, mass mailings and communications placed for a fee on another person’s website, digital device, application or advertising platform.
When making solicitations through public political advertising, however, the committee must include an appropriate disclaimer and authorization notice.
The committee may make solicitations using its own mailing lists.
Fundraising events and items
The committee may raise money by selling fundraising items or tickets to fundraising events. The full price of a fundraising item purchased (such as a t-shirt, a ticket to a fundraising event or a chance at a raffle) counts as the purchaser’s contribution, even if part of the price paid is used to defray the costs of the fundraising program.
Fundraising on the internet
Nonconnected committees may solicit contributions over the internet as long as the solicitation includes the proper disclaimers. They may satisfy this by online confirmation that the contribution complies with the federal limits and prohibitions and is not from a prohibited source.
Committee treasurers are also responsible for examining all contributions received for evidence of illegality and compliance with contribution limits.
Payroll deduction
Administration costs
A nonconnected committee that is sponsored by a non-corporate organization, such as a partnership, may receive contributions from the organization’s partners or employees in the form of payroll deductions. If the costs associated with administering the payroll deduction plan are paid by that sponsor, they are in-kind contributions from the sponsoring organization. If the sponsor cannot contribute (e.g., it is a federal contractor) the committee itself must pay in advance for the cost of the payroll deductions. If the committee pays, it reports the payments as operating expenditures.
Reporting payroll deduction receipts
Once an individual’s deductions aggregate over $200 in a calendar year, report the total amount deducted from the donor’s paychecks during the reporting period on Schedule A. In parentheses indicate the amount that was deducted each pay period. Instead of stating a specific date of receipt, note “payroll deduction” under “Date.” The other itemized information, including the year-to-date total, must be completed for each donor.
Example: Reporting payroll deduction receipts
During an election year, a member of a law partnership authorizes his firm to deduct $15 per pay period (each pay period is two weeks) for the firm’s nonconnected PAC. The PAC, which files FEC reports on a quarterly schedule, includes the partner’s first-quarter contributions ($90 for six pay periods) as “unitemized contributions” on Line 11(a)(ii) in the April quarterly report.
By June 30 (the closing date for the July quarterly report), 13 pay periods have passed, and the partner’s aggregate contributions are $195—still below the $200 itemization threshold. The partner’s second-quarter contributions again are included in “unitemized contributions” in the July report.
By September 30 (the closing date for the October quarterly report), 19 pay periods have passed, and the partner’s contributions reach $285. Now the committee itemizes the total contributions received from the partner during the third quarter ($90), providing the year-to-date total in the appropriate space.
In-kind contributions received from sponsoring organization
When determining whether to itemize an in-kind contribution from the sponsoring organization, itemize it if it exceeds $200 per calendar year, either by itself or when aggregated with other receipts from the same source.
In addition, the value of the in-kind contribution must be reported as an operating expenditure on Line 21(b) (in order to avoid inflating the cash on hand amount).
If the in-kind contribution must be itemized on Schedule A, then it must also be itemized on a Schedule B for operating expenditures.
Fundraising notices
Certain statements by a nonconnected committee must be present on solicitations.