July Reporting Reminder
The following reports are due in July:
- All principal campaign committees of House and Senate candidates must file a quarterly report by July 15, 2014. The report covers financial activity from April 1 (or the day after the closing date of the last report) through June 30. If the committee filed a pre-primary report covering a portion of that period, the July Quarterly should pick up where that report left off.
- Principal campaign committees of Presidential candidates must file a report by July 15, if they are quarterly filers, or by July 20, if they are monthly filers. The quarterly report covers activity from April 1 (or the day after the closing date of the last report) through June 30. The monthly report covers the month of June.
- National party committees, political action committees (PACs) following a monthly filing schedule and state, district and local party committees that engage in reportable “federal election activity” must file a monthly report by July 20. This report covers activity for the month of June. 11 CFR 104.5. Other PACs and party committees must file a quarterly report by July 15, covering activity through June 30. If the committee filed a pre-primary report covering a portion of that period, the July Quarterly should pick up where that report left off.
Since the July 20 deadline falls on a weekend in 2014, monthly filers using methods other
than electronic filing or registered, certified or overnight mail must ensure that their reports are received by the Commission’s (or the Secretary of the Senate’s) close of business on the last business day before the deadline (i.e., Friday, July 18).
The Commission will host reporting webinars for candidates on June 19 and for PACs and party committees on June 25 to help filers prepare their reports.
Notification of Filing Deadlines
In addition to publishing this article and the online reporting tables, the Commission notifies committees of filing deadlines through reporting reminders called prior notices. Prior notices are distributed exclusively by electronic mail. For that reason, it is important that every committee update its Statement of Organization (FEC Form 1) to disclose a current email address. Each committee may list up to two email addresses. To amend Form 1, electronic filers must submit Form 1 filled out in its entirety. Paper filers should include only the committee’s name, address, FEC identification number and the updated or changed portions of the form.
The Commission provides reminders of upcoming filing dates as a courtesy to help committees comply with the filing deadlines set forth in the Federal Election Campaign Act (“the Act”) and Commission regulations. Committee treasurers must comply with all applicable filing deadlines established by law, and the lack of prior notice does not constitute an excuse for failing to comply with any filing deadline.
Under the Commission’s mandatory electronic filing regulations, individuals and organizations that receive contributions or make expenditures, including independent expenditures, in excess of $50,000 in a calendar year—or have reason to expect to do so—must file all reports and statements with the FEC electronically.[fn1] Reports filed electronically must be received and validated by the Commission by 11:59 p.m. Eastern Time on the applicable filing deadline. 11 CFR 100.19(c). Electronic filers who instead file on paper or submit an electronic report that does not pass the Commission’s validation program by the filing deadline will be considered nonfilers and may be subject to enforcement actions, including administrative fines. 11 CFR 104.18(a)(2) and (e).
Senate committees and other committees that file with the Secretary of the Senate are not subject to the mandatory electronic filing rules, but, in addition to their official report filed with the Secretary of the Senate, the committees may file an unofficial copy of their reports with the Commission in order to speed disclosure.
The Commission’s electronic filing software, FECFile, is free and can be downloaded at http://www.fec.gov/elecfil/updatelist.html. All reports filed after March 13, 2014, must be filed in Format Version 184.108.40.206. Reports filed in previous formats will not be accepted. Filers may also use commercial or privately developed software as long as the software meets the Commission’s format specifications, which are available on the Commission’s website. Committees using commercial software should contact their vendors to ensure their software meets the latest specifications.
Timely Filing for Paper Filers
Registered and Certified Mail. Reports sent by registered or certified mail must be postmarked on or before the mailing deadline to be considered timely filed. A committee sending its reports by certified or registered mail should keep its mailing receipt with the U.S. Postal Service (USPS) postmark as proof of filing because the USPS does not keep complete records of items sent by certified mail. A committee sending its report by registered mail should keep its proof of mailing. Note that a certificate of mailing from the USPS is not sufficient to prove that a report is timely filed using registered, certified or overnight mail. See 2 U.S.C. §434(a)(5) and 11 CFR 100.19 and 104.5(e) and (i).
Overnight Mail. Reports filed via overnight mail [fn2] will be considered timely filed if the report is received by the delivery service on or before the mailing deadline. A committee sending its reports by Express or Priority Mail, or by an overnight delivery service, should keep its proof of mailing or other means of transmittal of its reports. See 2 U.S.C. §434(a)(5) and 11 CFR 100.19 and 104.5(e).
Other Means of Filing. Reports sent by other means—including first class mail and courier—must be received by the FEC (or the Secretary of the Senate) before close of business on the filing deadline. See 11 CFR 100.19 and 104.5(e).
Forms may be downloaded at http://www.fec.gov/info/forms.shtml and are available from FEC Faxline, the agency’s automated fax system (202/501-3413). The 2014 Reporting Schedule is also available on the FEC’s website at http://www.fec.gov/info/report_dates_2014.shtml. For more information on reporting, call the FEC at 800/424-9530 or 202/694-1100.
State, District and Local Party Committees
State, district and local party committees that engage in reportable “federal election activity” must file on a monthly schedule. See 11 CFR 300.36(b) and (c)(1). Other committees may file on a quarterly basis in 2014. See 11 CFR 104.5(c)(1)(i).
National Party Committees
National committees of political parties must file on a monthly schedule. 2 U.S.C. §434(a)(4)(B) and 11 CFR 104.5(c)(4).
Political Action Committees
PACs (separate segregated funds, nonconnected committees, hybrid committees and independent expenditure-only committees, aka Super PACs) that filed on a semi-annual basis in 2013 file on a quarterly basis in 2014. Monthly filers continue on the monthly schedule. PACs may change their filing schedule, but must first notify the Commission in writing. Electronic filers must file this request electronically. A committee may change its filing frequency only once a year, and after giving notice of change in filing frequency to the Commission and receiving an approval notice, all future reports must follow the new filing frequency. 11 CFR 104.5(c).
For more information on 2014 reporting dates:
- Call and request the reporting tables from the FEC at 800/424-9530 or 202/694-1100;
- Fax the reporting tables to yourself using the FEC’s Faxline (202/501-3413, document 586);
- Visit the FEC’s web page at http://www.fec.gov/info/report_dates_2014.shtml to view the reporting tables online.
1 The regulation covers individuals and organizations required to file reports of contributions and/or expenditures with the Commission, including any person making an independent expenditure. 11 CFR 104.18(a). Disbursements for “electioneering communications” are not considered “expenditures” and thus do not count toward the $50,000 threshold for mandatory electronic filing. See 11 CFR 104.18(a).
2 “Overnight mail” includes Priority or Express Mail having a delivery confirmation, or an overnight service with which the report is scheduled for next business day delivery and is recorded in the service’s online tracking system.
(Posted 06/11/2014; By: Katherine Carothers)
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