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.
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
- 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 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.
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.
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.”