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Recording nonconnected PAC disbursements

The committee’s records must show figures for total disbursements by the committee.

Disbursements by check

All disbursements (except those made from a petty cash fund) must be made by check or similar draft drawn on an account maintained at the committee’s designated campaign depository.

Petty cash disbursements

A written record of petty cash disbursements must be kept if a petty cash fund is maintained. Payments from petty cash to one person for any one purchase or transaction may not exceed $100.

Recording disbursements

Each disbursement must be identified by:

  • Date;
  • Amount of the payment;
  • Name and address of the payee; and
  • Purpose of the disbursement (i.e., a brief explanation of why the disbursement was made, such as “dinner expenses” or “postage”).

Disbursements exceeding $200

For each disbursement of more than $200, the committee must keep a receipt, invoice or cancelled check (in addition to the information listed). The committee must itemize disbursements when, in the aggregate, they exceed $200 in a calendar year to the same person.

Disbursements for a federal candidate

A committee must keep the following records on contributions and expenditures made on behalf of candidates, regardless of the amount of the disbursement:

  • Date;
  • Amount;
  • Office sought by the candidate, including the state and Congressional district; and
  • Election for which disbursement was made (to facilitate reporting).

Credit card transactions

For all credit card transactions, a monthly billing statement or customer receipt for each transaction must be retained, as well as the cancelled check used to pay the account.

Credit union checks or share drafts

Carbon copies of share drafts or checks drawn on credit union accounts may be used as records, provided the monthly account statement (showing that the draft or check was paid by the credit union) is also retained.

Transfers-out

To facilitate reporting, records should identify each transfer of funds made to an affiliated committee, regardless of amount, by the date and amount of the transfer and the name and address of the recipient committee.

Disbursements for joint fundraising

The joint fundraising representative must retain, for three years, records on all disbursements made for the joint fundraiser. If a commercial fundraising firm or agent is used, it must forward required records on disbursements to the joint fundraising representative.

Treasurer’s best efforts

Nonconnected committees and their treasurers must make best efforts to obtain, maintain and report the information required by law with respect to itemized receipts and disbursements.

When reporting information is incomplete, the committee and the treasurer will be in compliance with the law if they can demonstrate that they used “best efforts” in trying to obtain and report the required information.

Documenting disbursements

If a treasurer fails to receive a receipt, invoice or cancelled check (required for disbursements exceeding $200), he or she must make at least one written effort per transaction to obtain a duplicate of the needed documentation.