Recording nonconnected PAC receipts
With respect to receipts, the Federal Election Campaign Act (the Act) requires reporting of all receipts, but requires recordkeeping only for contributions. Nevertheless, nonconnected PACs must keep records for all types of receipts in order to comply with the reporting requirements of the Act and FEC regulations. The committee must maintain the following information for contributions of any amount and should maintain these records for other receipts:
- Amount received;
- Date of receipt; and
- Name and address of source.
A person who collects contributions on behalf of a nonconnected committee must not commingle them with personal funds. Instead, he or she must forward the contributions, together with the appropriate recordkeeping information about the contributors to the committee treasurer within the following time periods:
- Contributions of $50 or less: Within 30 days after receiving the funds.
- Contributions of more than $50: Within 10 days after receiving the funds.
All contributions, regardless of amount, must be deposited in a committee bank or credit union account within 10 days of the treasurer’s receipt.
Date of receipt
The "date of receipt" of a contribution is the date on which a person receiving the contribution on behalf of the committee obtains possession of it. That date is the date used for recordkeeping and reporting of receipts.
The date of receipt may be earlier than the date the committee treasurer receives the money, since a person collecting contributions has several days in which to forward them to the treasurer.
Credit card receipts
When the committee receives contributions through credit card charges, the date of receipt is the date on which the committee receives the contributor's signed authorization to charge the contribution or on the date the contributor's credit card account is charged. The treasurer should retain a copy of the authorization form in the committee's records.
Deposit of receipts
Once the treasurer receives a contribution, he or she must deposit it within 10 days. Contributions not deposited within 10 days must be returned to their donors.
Contributions from individuals and from groups other than political committees must be recorded as follows:
Contributions aggregating over $200
For each contribution that exceeds $200, either by itself or when aggregated with (added to) previous contributions from the same donor to the committee during the same calendar year, records must identify the following information:
- Date of receipt;
- Donor’s full name and address; and
- Donor’s occupation and employer.
Contributions of more than $50
Records must identify each contribution exceeding $50 by noting the following:
- Date of receipt; and
- Donor’s full name and address. In addition to any other recordkeeping requirements, committees must retain a full-size photocopy or digital image of the check for any contribution over $50.
Contributions of $50 or less
The Commission recommends two possible accounting methods:
- Keep the same records as those required for contributions that exceed $50; or
- In the case of small contributions collected at a fundraising event (such as gate receipts, cash contributions, etc.), keep a record of the name of the event, the date and the total amount of contributions received on each day of the event.
Contributions from political committees
Committee records must identify all contributions from political committees regardless of amount by noting the amount, date of receipt and the name and address of the contributing committee.
Joint fundraising receipts
With regard to gross proceeds, the joint fundraising representative must collect the following contributor information and later forward it to the participating political committees:
- For contributions exceeding $50, the amount, date of receipt and the contributor's name and address.
- For contributions exceeding $200, the amount, date of receipt and the contributor's name, address, occupation and employer.
The date of receipt is the date the joint fundraising representative receives the contribution.
Documenting a contribution’s legality
In order to determine whether a contribution of questionable legality was made by a permissible source and was not excessive, the treasurer must make at least one written or oral request for evidence of the contribution's legality. If the contribution cannot be determined to be legal, the treasurer must refund the contribution to the source within 30 days of receiving it.
A committee must keep a written record noting the basis for concern for each deposited contribution that:
- Requires a written reattribution from the contributor; or
- Requires confirmation that it is not from a prohibited source.
Recording other receipts
The FEC recommends that committees keep records on the following receipts in order to fully comply with reporting requirements:
- Transfers from affiliated committees;
- Bank loans;
- Interest and dividends received on invested committee funds; and
- Repayments on loans made by the committee.
Committee records should contain the full name of the source and the date and amount of each receipt.