Contributions received through conduits
An earmarked contribution is a contribution that a contributor directs (either orally or in writing) to a clearly identified candidate or authorized committee through an intermediary or conduit. Committees report information about both the original contributor and the conduit that handled the contribution.
Reporting on candidate forms
House and Senate committees report contributions received through conduits on Form 3, Schedule A. The line number used to report a contribution given through a conduit depends on who is giving the original contribution. An original contribution that comes from an individual is reported on Line 11(a)(i) while an original contribution that comes from a political action committee is reported on Line 11(c).
For example, Mary Smith gives a $2,500 contribution to the Mount Vernon Association PAC with instructions to give the contribution to Martha Washington’s committee.
Mary Smith is the original contributor. Since she’s an individual, her contribution is reported on Line 11(a)(i). It is itemized on Schedule A because Mary contributed in excess of $200 during the election cycle. The Date of Receipt is the day that she gave the contribution to the conduit, Mount Vernon Association PAC. The committee included a note that the contribution was earmarked through the conduit.
Mount Vernon Association PAC is the conduit and is reported as a memo item supporting Mary Washington’s contribution. The Date of Receipt will be the date that the conduit gave the contribution to the committee. This date may be later than the date disclosed with Mary’s information. The committee disclosed the total amount earmarked through the conduit. The notation "total earmarked through conduit: limit not affected" is important to show that the PAC did not have direction or control over which committee receives the contribution, and so the PAC’s contribution limit is not affected.
Reporting with FECFile
Enter the original contribution on the appropriate line of the Summary Page. Right click on the entry and click “transaction split” to create the memo item for the conduit’s information.
