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Advances of personal funds for nonconnected PAC expenses

When an individual uses his or her personal funds (or personal credit) to pay for a committee expense, that payment is generally an in-kind contribution from that individual.

For example, an in-kind contribution results if a committee staff member or volunteer pays for postage, office supplies or campaign materials with his or her personal funds. Non-travel advances that are later reimbursed are considered contributions so long as they are outstanding.

However, an advance is not considered a contribution if the payment is for campaign travel expenses and is reimbursed within 30 days of the date the expense is incurred or, in the case of credit card purchases, within 60 days of the closing date of the billing statement on which the charges first appear.

Special reporting rules apply when individuals pay for committee expenses and later receive reimbursement from the committee.

Special rule for reporting reimbursements

If the total amount reimbursed to the individual is $500 or less, the committee must report the individual as the payee. If the total amount exceeds $500 and payments to any one vendor used for the expenses total over $200, additional information is required. In this instance the committee must:

  • Report the individual as payee; and
  • Report the payments aggregating over $200 to any one vendor as memo entries on Schedule B.

Advances made and reimbursed within same reporting period

Advances that are made and reimbursed within the same reporting period are considered contributions and must be reported as follows:

  • Report the original advance only if, at the end of the reporting period, the amount of previous contributions from the person making the advance plus the amount of the advance minus the amount of the reimbursement is greater than $200 (i.e., previous contributions + the advance - the reimbursement > $200) In that case, report the advance as a memo entry contribution on Schedule A; and
  • Report the reimbursement as an operating expenditure and, if reimbursements to that person exceed $200 in the calendar year, itemize it on Schedule B (with a cross-reference to the memo entry on Schedule A for the advance—if the advance was itemized).

Advances made and reimbursed in different reporting periods

Advances that are reimbursed in a later reporting period must be reported as follows:

  • Report the original advance only if, at the end of the reporting period, the amount of previous contributions from the person making the advance plus the amount of the advance minus the amount of the reimbursement is greater than $200 (i.e., previous contributions + the advance - the reimbursement > $200). In that case, report the advance as a memo entry contribution on Schedule A;
  • Report the amount of the advance outstanding at the end of the reporting period as a debt on Schedule D if it exceeds $500 or has been outstanding for more than 60 days; and
  • Report the reimbursement as an operating expenditure and, if reimbursements to that person exceed $200 in the calendar year, itemize it on Schedule B (with a cross-reference to the memo entry on Schedule A for the advance—if the advance was itemized).

Special rule for reporting reimbursements

If the total amount reimbursed to the individual is $500 or less, the committee must report the individual as the payee. If the total amount exceeds $500 and payments to any one vendor used for the expenses total over $200, additional information is required. In this instance the committee must:

  • Report the individual as payee; and
  • Report the payments aggregating over $200 to any one vendor as memo entries on Schedule B.