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Appointing a treasurer

Every political committee must designate a treasurer before it can accept contributions or make expenditures. Designate your treasurer on your Statement of Organization (Form 1).

Treasurers must ensure committee reports and statements are complete, accurate and timely. This is a significant responsibility—if there’s an enforcement action against a committee, the treasurer is usually named as a respondent. Treasurers can be found officially (or, in some circumstances, personally) liable for the actions they take.

Treasurers:

  • Sign and file all committee reports and statements.
  • Deposit receipts in the committee’s designated bank within 10 days of receipt.
  • Authorize expenditures or appoint someone else (orally or in writing) to authorize expenditures.
  • Monitor contributions, ensuring they comply with legal limits and prohibitions.
  • Keep records of receipts and disbursements for three years from the filing date of the report to which they relate.

A candidate can choose to act as his or her own committee treasurer.

Treasurer liability

Treasurers are responsible for carrying out the duties listed on this page and should understand these responsibilities (as well as one’s personal liability for fulfilling them) before taking them on. When the Commission brings an enforcement action against a political committee, the treasurer is usually named as a respondent along with the committee itself. Treasurers can be named and found liable in their official capacity as a representative of the committee. Also, treasurers can be named and found liable in their personal capacity if they knowingly and willfully violate the Act or intentionally deprive themselves of the operative facts giving rise to the violation.

Even when an enforcement action alleges violations that occurred during the term of a previous treasurer, the Commission usually names the current treasurer as a respondent in the action.

Vacancy in office

A committee cannot raise or spend funds when there is a vacancy in the office of treasurer. For that reason, the Commission recommends every committee designate an assistant treasurer on its Form 1 who may assume the treasurer’s duties when the treasurer’s office becomes temporarily vacant or when the treasurer is unavailable. The assistant treasurer should be apprised of any filing requirements and, if the committee files electronically, should obtain an electronic filing password as well.

New treasurers

Committees must report a change in treasurer within 10 days of the change. Most do this by filing an amended Form 1. This amended form designates (and is signed by) the new treasurer.

Treasurers can also resign by informing the FEC directly by letter or—in the case of electronic filers—by Form 99.

Committees typically disclose a treasurer’s resignation by naming a replacement. The committee informs the FEC of a change in treasurer by filing an amended Form 1, which is signed by the new treasurer. However, in some circumstances a treasurer simply resigns without the appointing of a replacement by submitting a letter of resignation to the FEC. (Electronic filers use Form 99.) The letter’s stated purpose is to amend the committee’s Form 1 to reflect the resignation of the treasurer as of a particular date. From that date forward, the committee would be rendered dormant until a new treasurer is named using the procedures outlined on this page. Again, the committee would not be able to raise or spend funds while there is a vacancy in the office of treasurer.

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