In certain situations, nonconnected committees that maintain different types of accounts must allocate particular expenses between those accounts. Failure to allocate expenses when required could result in a prohibited contribution to the federal account of the committee.
Allocating operating expenses between federal and nonfederal accounts
Nonconnected committees need not allocate administrative expenses, costs of generic voter drives, and public communications that refer to a political party between their federal and nonfederal accounts. Nor do they need to report these allocations on FEC Form 3X.
Allocating expenses between federal and non-contribution account for Hybrid PACs
Consistent with a court order in Carey v. FEC, Hybrid PACs should allocate administrative expenses between their traditional PAC and non-contribution accounts so that each account pays a percentage that closely corresponds to the percentage of activity for that account.
Report all other disbursements, including those for administrative or operating expenses made from a committee’s non-contribution account, on Line 29 of Form 3X titled “Other Disbursements” (as opposed to Line 21(b) of Form 3X).
When itemizing on Schedule B, electronic filers should identify these disbursements by entering “Non-Contribution Account” as memo text or in the description field along with the required purpose of the disbursement. (Paper filers should simply write “Non-Contribution Account” below the amount.)