Recording receipts for a party committee
With respect to receipts, the Federal Election Campaign Act (the Act) requires reporting of all receipts, but requires recordkeeping only for contributions. Nevertheless, a party committee 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.
Forwarding contributions
Time limits
Any person who receives contributions for a party committee must forward the contributions, together with certain 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.
No commingling with personal funds
Contributions and other committee receipts must not be deposited in a personal account or otherwise commingled with personal funds.
Identifying Contributors
Contributions aggregating over $200
Records must additionally identify the occupation and employer of an individual contributor whose contribution exceeds $200 or aggregates over $200 when added to previous contributions made during the calendar year.
Contributions over $50
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.
Small contributions collected at fundraising event
When a committee receives a large number of contributions of $50 or less at a fundraising event, records need identify only the name of the event and the total amount received on each day of the event. These amounts are reported under the category “unitemized contributions from individuals.”
Small contributions collected through tax checkoff
When a committee receives small contribution in the form of state tax checkoff funds, records on individual contributors are not required. The contributions are reported as “unitemized contributions from individuals.” However, the committee must keep a record of the state government source, the date of receipt and the amount received.
Contributions through online banking services
When a committee receives a contribution from a contributor who used an online banking service to issue a physical check bearing the signature of an authorized bank official, the treasurer is not required to send a follow-up letter to the contributor in order to obtain a written signature if all of the necessary contributor information is included on the check. However, where the check does not include all of the necessary contributor information and the treasurer does not have accurate and up-to-date contributor information on file for the individual on whose account the check is drawn, the treasurer must use "best efforts" to obtain such information.
Contributions by text message
Recipient committees are solely responsible for ensuring that contributions sent by text messages are lawful under the Act and Commission regulations. Committees should work with the text messaging application provider to collect the name, address, occupation and employer of individuals making contributions that aggregate over $200 in a calendar year. Committees must return or refund any contribution that comes from a prohibited source.
Reattributed contributions
For each reattributed contribution, a committee must keep a copy of the reattribution as well as documentation verifying that the reattribution was received within 60 days after the committee’s receipt of the original contribution. If these records are not kept, the reattribution is not effective.
No commingling with personal funds
Contributions and other committee receipts must not be deposited in a personal account or otherwise commingled with personal funds.
Date of receipt
A contribution’s date of receipt is the date on which the person receiving the contribution on behalf of the committee obtains possession of it. That is the date used for recordkeeping and reporting.
The date of receipt may be earlier than the date the committee treasurer receives the money, since a person collecting contributions (other than an authorized agent) has 10 days (or 30 days for contributions of $50 or less) in which to forward them to the treasurer.
Contributions charged on credit cards
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. The treasurer should retain a copy of the authorization form in the committee’s records.
Contributions sent by text message
The date of receipt for contributions sent by text message is the date the contributor "opts-in," or confirms that he or she intends to make the contribution and certifies his or her eligibility.
In-kind contributions
The date of receipt for an in-kind contribution is the date the goods or services are provided to the committee, even if the contributor pays the bill for the goods or services after they are provided.
Deposit of receipts
Once the treasurer (or authorized agent) receives a contribution or other receipt, he or she must deposit it within 10 days. Contributions not deposited within 10 days must be returned to their donors.
Possibly illegal contributions
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.
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 may deposit the contribution, within a 10-day window for depositing contributions, and 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 within thirty days of receipt.