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Travel on behalf of nonconnected PAC

General rule

Generally, committees may pay for travel as an operating expenditure. An in-kind contribution generally results from the source of payment for the travel unless an exemption for individual travel applies or the committee pays for its own travel. Additional rules apply to travel on behalf of leadership PACs on non-commercial aircraft and to reimbursements for advances of personal funds for travel.

Advances of personal funds for travel

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. If an individual uses personal funds to pay the travel expenses of another, an in-kind contribution results.

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.

Reporting reimbursements for advances of personal funds for travel

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

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.

Commercial aircraft transportation

If a committee uses an aircraft that is operated for commercial air service, such as a commercial airline or charter service, or another means of commercial transportation, the committee must pay the usual and normal charge for that service to avoid receiving an in-kind contribution from the service provider.

Commission regulations define the term “campaign traveler” as any individual traveling in connection with an election for federal office on behalf of a candidate or political committee, and candidates who travel on behalf of their own campaigns. The term campaign traveler also includes any member of the news media traveling with a candidate. Candidates are only considered campaign travelers when they are traveling in connection with an election for federal office. This term does not include Members of Congress when they engage in personal travel or any other travel that is not in connection with an election for federal office.

Travel on behalf of leadership PACs of Senate, presidential and vice presidential candidates

For non-commercial travel on behalf of leadership PACs of Senate, presidential and vice presidential candidates, the reimbursement for that travel is the responsibility of the committee on whose behalf the travel occurs. The reimbursement rates are as follows:

  • The lowest unrestricted and non-discounted first-class airfare in the case of travel between cities served by regularly scheduled first-class commercial airline service;
  • The lowest unrestricted and non-discounted coach airfare in the case of travel between a city served by regularly scheduled coach commercial airline service, but not regularly scheduled first-class commercial airline service, and a city served by regularly scheduled coach commercial airline service (with or without first-class commercial airline service); or
  • The normal and usual charter fare or rental charge for a comparable commercial aircraft of sufficient size to accommodate all campaign travelers and security personnel, if applicable, in the case of travel to or from a city not served by regularly scheduled commercial airline service.

To avoid the receipt of an in-kind contribution, the committee must reimburse the service provider no later than seven calendar days after the date the flight began.

Travel on behalf of House candidates and House leadership PACs

House candidates, individuals traveling on behalf of House candidates, their authorized committees, or the leadership PACs of House candidates are generally prohibited from engaging in non-commercial campaign travel on aircraft. This prohibition does not apply when the travel would be considered an expenditure by someone other than the House candidate, the House candidate’s authorized committee or the House candidate’s leadership PAC (for example, if the House candidate were traveling on behalf of a Senate candidate instead of on behalf of his or her own campaign). This prohibition cannot be avoided by payments to the service provider, even if the payments derive from the personal funds of a House candidate.

Travel on behalf of other nonconnected committees

The reimbursement rate structure for campaign travelers who are traveling on behalf of political party committees, separate segregated funds (SSFs), nonconnected committees and certain leadership PACs is the same reimbursement rate structure described under “Travel on behalf of leadership PACs of Senate, presidential and vice-presidential candidates.”

Other non-commercial transportation

For non-commercial travel via other means, such as limousines and all other automobiles, trains and buses, a political committee must pay the service provider the normal and usual fare or rental charge for a comparable commercial conveyance of sufficient size to accommodate all campaign travelers, including members of the news media traveling with a candidate and security personnel, if applicable. Payment for the travel must be made within 30 days from the receipt of the invoice, but no more than 60 days following the date the travel commenced.

Government conveyances

Candidates and representatives of political committees may make campaign travel via governmental conveyances, such as government aircraft, subject to specific reimbursement requirements. Candidates, their authorized committees or House candidate leadership PACs must reimburse the federal, state or local government entity providing the aircraft at either of the two following rates:

  • “Per candidate campaign traveler” reimbursement rate, which is the normal and usual charter fare or rental charge for a comparable aircraft of sufficient size to accommodate all of the campaign travelers. The pro rata share is calculated by dividing the normal and usual charter fare or rental charge by the number of campaign travelers on the flight that are traveling on behalf of candidates, authorized committees or House candidate leadership PACs, including members of the news media, and security personnel. No portion of the normal and usual charter fare or rental charge may be attributed to any other passengers, except for members of the news media and government-provided security personnel, as provided in 11 CFR 100.93(b)(3); or
  • “Private traveler reimbursement rate,” as specified by the governmental entity providing the aircraft, per campaign traveler. 

For campaign travelers who are traveling on government aircraft, but are not traveling with or on behalf of a candidate or candidate’s committee, the reimbursement must be equal either to the lowest unrestricted and non-discounted first-class commercial airline service that is geographically closest to the military airbase or other location actually used, or, for all other travel, the applicable rate from among the rates specified in 11 CFR 100.93(c)(3).

Members of the news media who are traveling with a candidate on government aircraft and security personnel not provided by a government entity must be included in the number of campaign travelers for the purposes for identifying a comparable aircraft of sufficient size to accommodate all campaign travelers.

A political committee must reimburse the governmental entity providing the conveyance within the time frame specified by the governmental entity.