Paying the connected organization in advance
When an SSF pays its connected organization in advance for using the organization’s resources and facilities (as required by the FEC’s anti-facilitation regulations), the SSF reports this as an operating expenditure.
Reporting on PAC forms
Separate Segregated Funds report making advance payments to their connected organizations on Form 3X, Line 21(b).
The PAC shows the advance payment to its connected organization, Critical Reason, on Line 21(b). It includes the connected organization’s complete address, the date the advance was paid, the candidate receiving the in-kind contribution, and a clear purpose of disbursement, “use of meeting room/staff time.”
Then, when the resource or facility is actually used on behalf of a campaign, the SSF must itemize payment again on Schedule B for Line 23 “contributions to other federal candidates and political committees.” The date the resource or facility was used is the date the contribution is made. To reconcile its totals, the SSF must also itemize the payment again, as a negative entry on Line 21(b).
The SSF used Critical Reason’s meeting room on 3/30/2018. It reports this in-kind contribution given to Rene Descartes on Line 23. The SSF included a note connecting this entry to the offsetting entry on Line 21(b).
When the SSF uses the resource or facility, it itemizes a negative entry on Line 21(b) to offset the entry on Line 23 and reconcile its totals.
Reporting with FECFile
To enter the advanced payment, go to the Summary Page tab, right click on “Line 21(b) Other federal operating expenditures” and select “new.”
To enter using the connected organization’s resources or facilities go to the Summary Page tab, right click on “Line 23 Contributions to other federal candidates and political committees” and select “new.” To create the offsetting entry, right click on “Line 21(b) Other federal operating expenditures” and select “new.” Enter the amount on Line 21(b) as a negative entry.
