Types of contributions
A contribution is defined as anything of value given for the purpose of influencing a federal election. Contributions are subject to the limits and prohibitions of the Federal Election Campaign Act (the Act). The most common types of contributions are:
- Gifts of money;
- Gifts of goods and services (in-kind contributions);
- Loans (other than bank loans meeting certain conditions); and
- Guarantees or endorsements of bank loans.
Gifts of money
Cash contributions are limited to $100 per contributor. Contributions of more than $100 must be made by check or other written instrument.
Sales or lease proceeds
Sale of fundraising items and tickets
The full purchase price of a fundraising item or ticket to a fundraising event is considered a contribution. For example, when a person buys a $50 ticket to a fundraising dinner, the amount of the contribution is $50, regardless of how much the meal costs the committee. A person who buys several tickets to a fundraiser makes a contribution in the amount of the total purchase unless the contribution is intended as a joint contribution
Sale of committee assets
When a committee sells or leases an asset (such as a mailing list), the full amount received from the purchaser is generally considered a contribution to the committee unless:
- The committee had purchased or developed the asset for the committee’s own use rather than as a fundraising item;
- The asset has an ascertainable market value;
- Rental of the asset comprises only a small percentage of the committee’s overall use; and
- The purchaser pays the usual and normal charge. (Any payment in excess of that amount is considered a contribution.)
For more information on leasing a party mailing list, see AO 2002-14.
Under certain conditions, the Commission has also concluded that a contribution does not result from a sale that is an isolated disposal or sale of unwanted and depreciated committee assets (such as office furniture).
In-kind contributions include:
- Goods and services offered free of charge;
- Goods and services offered at less than the usual and normal charge (unless the discount is offered in the ordinary course of business);
- Payments, by a third party, of committee bills; and
- Advances of personal funds.
The dollar value of an in-kind contribution is subject to limits. The value is determined as follows:
- Goods (such as equipment, supplies, facilities and mailing lists) are valued at their normal purchase or rental price at the time of the contribution.
- Services (such as advertising, printing and consulting) are valued at the prevailing commercial rate at the time the services are rendered.
- Discounts are valued at the difference between the usual and normal charge and the amount paid by the committee.
Reporting in-kind contributions
Itemize in-kind contributions of any amount from political committees. Itemize an in-kind contribution from any other source if it exceeds $200 per calendar year either by itself or when aggregated with other receipts from the same source. See "Value" for information on how to determine the dollar value of an in-kind contribution.
In addition, add the value of the in-kind contribution to the operating expenditures total on Line 21b (in order to avoid inflating the cash-on-hand amount).
If the in-kind contribution must be itemized on Schedule A, then it must also be itemized on a Schedule B for operating expenditures.
A joint contribution is made by a single check (or other written instrument) that bears two signatures. A check with one signature may also be a joint contribution if an accompanying form or letter, signed by both contributors, instructs the committee to treat it as a joint contribution. (A check drawn on a joint bank account but signed by only one person does not qualify as a joint contribution absent an accompanying form or letter signed by the second person. Attribute the full amount of such a check only to the person who signed it. Alternatively, the committee may reattribute the contribution using the procedures described.)
For the purposes of itemization, report a joint contribution as though the joint contributors had given separately.