Multistate independent expenditures

When party committees make independent expenditures, they must follow the guidelines for reporting them on monthly, 24-hour and/or 48-hour reports using Schedule E of the Form 3X.

When an independent expenditure (IE) is made in support of or opposition to a presidential primary candidate and is publicly distributed or otherwise disseminated in six or more states but does not refer to any particular state, the reporting requirements for multistate independent expenditures apply. For independent expenditures distributed in fewer than six states, there is no change in reporting requirements.

Reporting multistate independent expenditures on monthly reports depends on the timing of the expenditure distribution and the payment made. Learn more about these scenarios:

• Disseminating and paying for independent expenditures in the same reporting period
• Paying for an independent expenditure first and disseminating in a later reporting period
• Disseminating an independent expenditure first and paying in a later period
• Estimating independent expenditures

Learn more about filing 24-hour reports and 48-hour reports using Form 3X.

Disclosing multistate independent expenditures on Form 3X

Party committees making multistate independent expenditures report them using Schedule E of Form 3X. The multistate independent expenditure must be disclosed as a single expenditure (i.e., without allocating it among states) and must indicate in the State field the state with the next upcoming presidential primary among those states where the independent expenditure is distributed. In addition, memo text must be used to indicate the states where the communication is distributed. If more than one state where the communication is publicly distributed or otherwise disseminated are holding primaries on the same date, any one of these states may be indicated in the State field, with the others listed in memo text.

To itemize the multistate independent expenditure, the filer must disclose:

• Name and address of the payee
• Date of public distribution/dissemination and/or the date of disbursement or obligation (depending on the timing of the expenditure distribution and the payment made)
• The full amount of the expenditure
• Purpose of the independent expenditure
• Candidate supported or opposed, including the candidate’s name, office sought, election, and the state of the next upcoming presidential primary
• The total amount expended or obligated in the aggregate during the calendar year, per election, per office sought

2. SCHEDULE E: MEMO TEXT

In addition to reporting on Schedule E, party committees must use memo text to indicate the specific states where the multistate independent expenditure is distributed.

Multistate independent expenditure, publicly distributed or disseminated in the following states: New Hampshire, Vermont, Massachusetts, Maine, Rhode Island, Connecticut and New York.

Aggregating

Independent expenditures are aggregated toward the various reporting thresholds on a per-election basis, within the calendar year, per office sought (race). For multistate independent expenditures made in support of or opposition to a presidential primary candidate, the expenditures must be aggregated using the date of the next upcoming presidential primary election among the presidential primary elections to be held in the states in which the independent expenditure is publicly distributed or disseminated. That state’s election date will be used for purposes of determining whether 24 or 48-hour reports must be filed.

Reporting with FECFile

To add independent expenditures to a report, go to the Summary Page tab, right click on “Line 24 Independent expenditures” and select “new.” Enter the independent expenditure information following the above guidelines for selecting the state of the next upcoming presidential primary election. Include memo text by going to the Disbursements tab, right-clicking on the independent expenditure, and choosing “Memo Text” from the available options. Use memo text to list the states where the multistate independent expenditure is distributed.