Using treasury funds
A connected organization may use its treasury funds, including funds derived from commercial activities or dues payments, to pay the costs of establishing, administering and soliciting contributions to the SSF. Treasury money can be used, for example, to pay for office space, phones, salaries, utilities, supplies, bank charges and fundraising activities. There are no dollar limits on these disbursements, and they are not reported to the FEC. The connected organization may either pay these costs directly or establish a separate administrative account to be used solely for the SSF’s administrative and fundraising expenses. The funds contained in the administrative account may never be commingled with the SSF’s own funds, which are derived solely from lawful contributions. Trade associations sponsoring SSFs can solicit their members for donations to their administrative accounts under certain circumstances.
Using the SSF’s own funds
Although the law permits the connected organization to pay start-up, administrative and fundraising expenses for an SSF, the committee may use its own funds to pay those costs. All disbursements by the SSF for these purposes are reportable as operating expenditures on Line 21(b) of Form 3X. Note that the connected organization may reimburse the SSF for those operating expenditures, provided that the reimbursement is made within 30 days of the SSF’s disbursement. These reimbursements are reported as “offsets to operating expenditures.”