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Making disbursements as an SSF or connected organization

A separate segregated fund (SSF) may expend its funds for any lawful purpose consistent with the Federal Election Campaign Act (the Act) and Commission regulations.

An expenditure is a purchase, payment, distribution, loan, advance, deposit or gift of money or anything of value to influence a federal election. "Disbursement" is a broader term that covers both expenditures and other kinds of payments (those not made to influence a federal election). All disbursements must be reported by the SSF.

Disbursements must be made by check or similar draft drawn on an account maintained at the committee’s designated depository.

However, the SSF may maintain a petty cash fund for small 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.

Managing the SSF

A corporation (including an incorporated trade association or membership organization) or labor organization that sponsors an SSF is called the connected organization. The connected organization may use its general treasury funds to pay the establishment, administration, and fundraising costs for the SSF.

The connected organization may also exercise control over its SSF. Corporations and labor organizations often adopt bylaws to govern their SSFs, though bylaws are not required under the law and do not have to be filed with the FEC except when requested.

As the name implies, money contributed to an SSF is held in a separate bank account from the general corporate or labor organization treasury.

Contributions made by the SSF or the connected organization

Corporations and labor organizations may make unlimited contributions to Super PACs and to the non-contribution accounts of Hybrid PACs. Corporations and labor organizations, however, may not make contributions to candidates or to any other type of political committee.

SSFs may make contributions to influence federal elections, subject to the Act’s limitations and reporting requirements.

Communications and advertising

SSFs and their connected organizations may make independent expenditures, subject to the Act's reporting requirements.

If a communication is coordinated with a candidate or party, it is generally considered to be an in-kind contribution, subject to the Act’s limitations, prohibitions and reporting requirements.

Using connected organization resources and facilities

Under certain circumstances, corporations (including incorporated membership and trade associations) and labor organizations may allow candidates, political committees (including the SSF) and individuals to use their resources and facilities in connection with both supporting and fundraising for federal candidates, political party committees and other federal political committees, without making a prohibited contribution.