Establishing federal and nonfederal bank accounts
All political committees must register an official committee depository. A committee engaging in both federal and nonfederal election activity has two options:
- Set up one federal account (accepting only contributions subject to the limits and prohibitions of the Federal Election Campaign Act) to support both federal and nonfederal candidates and report all activity to the FEC; or
- Set up two accounts—one for federal elections and another for state and local elections.
The second option permits the committee to maintain a separate nonfederal account that has no federal registration or reporting obligations. When conducting an activity that relates to both federal and nonfederal elections however, the committee could also allocate the costs between the two accounts . Also, please note that any activity (including reporting requirements) by nonfederal accounts is governed by relevant state law. A nonfederal account generally has no reporting obligations with the FEC.
Although the law permits the connected organization to pay administrative and fundraising costs for an SSF, the connected organization may establish a separate administrative account to be used solely for the SSF’s administrative and fundraising expenses. Administrative expenses include, for example, rent, utilities, office supplies and salaries not attributable to a candidate. 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 account under certain circumstances.