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Additional recordkeeping by publicly funded presidential candidates

Beyond the regular recordkeeping requirements that apply to all federal candidates, presidential candidates that seek public funding must also agree to comply with additional requirements for recordkeeping.

Note that it is unlawful for any person knowingly and willfully:

  • To furnish any false, fictitious, or fraudulent evidence, books or information to the Commission, or to include in any evidence, books or information so furnished any misrepresentation of a material fact, or to falsify or conceal any evidence, books or information relevant to a certification by the Commission or any examination and audit by the Commission under the public financing statutes; or
  • To fail to furnish to the Commission any records, books or information requested by the Commission under the public financing statutes.

Generally, presidential candidates seeking public funding must agree to provide required documentation relating to disbursements and receipts, including any books, records (including bank records for all accounts), all documentation required for matching fund submissions and qualified campaign expenses, and other information that the Commission may request.

Recordkeeping for "qualified campaign expenses"

A publicly funded presidential candidate bears the burden of demonstrating that his or her disbursements were made for qualified campaign expenses. The documentation requirements enable the Commission to verify, during the post-election audit process, that public funds were spent in connection with the candidate's campaign. In most cases, complying with these requirements will adequately demonstrate that a candidate’s disbursements are qualified campaign expenses. However, a candidate may be required to provide further documentation should the audit process or an FEC investigation prompt questions about campaign transactions.

For disbursements in excess of $200 to a payee, the candidate or committee must present a canceled check negotiated by the payee and either:

  • A receipted bill from the payee that states the purpose of the disbursement; or
  • If such a receipt is not available, a bill, invoice, or voucher that states the purpose of the disbursement; or
  • If a receipt, bill, invoice or voucher is not available, a voucher or memorandum written at the time of purchase from the candidate or the candidate's committee that states the purpose of the disbursement.

Where the documentation specified in the regulations at 11 CFR 9003.5 (general election funding) or 11 CFR 9033.11 (primary matching funds) is not available, the candidate or committee may present collateral evidence to document the qualified campaign expense. Such collateral evidence may include, but is not limited to:

  • Evidence demonstrating that the expenditure is part of an identifiable program or project which is otherwise sufficiently documented, such as a disbursement which is one of a number of documented disbursements relating to a campaign mailing or to the operation of a campaign office; or
  • Evidence that the disbursement is covered by a pre-established written campaign committee policy, such as a daily travel expense policy.

If the purpose of the disbursement is not stated in the accompanying documentation, it must be indicated on the canceled check negotiated by the payee.

For all other disbursements, the candidate shall present:

  • A record disclosing the full name and mailing address of the payee, the amount, date and purpose of the disbursement, if made from a petty cash fund; or
  • A canceled check negotiated by the payee that states the full name and mailing address of the payee, and the amount, date and purpose of the disbursement.

Committees must also provide documentation relating to funds received and disbursements made on the candidate's behalf by other political committees and organizations associated with the candidate.

Collectability of accounts receivable

If a committee determines that an account receivable of $500 or more, including any credit, refund, return or rebate, is not collectible, it shall demonstrate through documentation that the determination was commercially reasonable. Documentation includes records showing the original amount of the account receivable, copies of correspondence and memoranda of communications with the debtor showing attempts to collect the amount due, and an explanation of how the lesser amount or full write-off was determined.

Production of computerized information

If the candidate or the candidate's committee maintains or uses computerized information containing any of these categories of data, then upon request, the committee must provide the computerized information, along with documentation explaining the computer system's software capabilities and personnel needed to explain the operation of the computer system's software:

  • Information required by law to be maintained regarding the committee's receipts or disbursements;
  • Records of allocations of expenditures to particular state expenditure limits and to the overall expenditure limit;
  • Disbursements for exempt fundraising and exempt compliance costs, including the allocation of salaries and overhead expenditures;
  • Records of allocations of expenditures for the purchase of broadcast media;
  • Records used to prepare statements of net outstanding campaign obligations;
  • Records used to reconcile bank statements;
  • Disbursements made and reimbursements received for the cost of transportation, ground services and facilities made available to media personnel, including records relating to how costs charged to media personnel were determined;
  • Records relating to the acquisition, use and disposition of capital assets or other assets; and
  • Any other information that may be used during the Commission's audit to review the committee's receipts, disbursements, loans, debts, obligations, bank reconciliations or statements of net outstanding campaign obligations.

Recording capital and other assets

Capital assets

The candidate or candidate’s committee shall maintain a list of all capital assets (any property used in the operation of the campaign whose purchase price exceeded $2,000 when acquired by the campaign). The list shall include a brief description of each capital asset, the purchase price, the date it was acquired, the method of disposition and the amount received in disposition. Property that must be valued as capital assets includes, but is not limited to, office equipment, furniture, vehicles and fixtures acquired for use in the operation of the candidate's campaign, but does not include property defined as "other assets." Capital assets include items such as computer systems and telecommunications systems, if the equipment is used together and if the total cost of all components that are used together exceeds $2,000.

Other assets

The candidate or committee shall maintain a list of other assets acquired for use in fundraising or as collateral for campaign loans, if the aggregate value of such assets exceeds $5,000. The list shall include a brief description of each such asset, the fair market value of each asset, the method of disposition and the amount received in disposition. The fair market value of other assets shall be determined to be the fair market value of each item on the candidate's date of ineligibility (primary election) or on the last day of the expenditure report period or the day on which the individual ceased to be a candidate, whichever is earlier (general election) or on the date the item is acquired if acquired after either of these dates.

Retention of records

By candidates seeking and receiving primary matching funds

Candidates and committees that seek primary matching funds must keep all books, records and other information (including computerized and electronic records) required by the primary public financing regulations for a period of three years after the report to which such records and accounts relate is filed, and shall furnish such books, records and information to the Commission on request.

By candidates seeking and receiving general election public funding

Publicly funded general election candidates must retain records with respect to each disbursement and receipt, including bank records, vouchers, worksheets, receipts, bills and accounts, journals, ledgers, fundraising solicitation material, accounting systems documentation, and any related materials documenting campaign receipts and disbursements (including computerized and electronic records), for a period of three years after the report to which such records and accounts relate is filed, and shall present these records to the Commission on request.

Documenting eligibility to receive presidential primary matching funds

Presidential candidates seeking their party's nomination can qualify to receive matching funds by raising over $5,000 in each of 20 states (that is, over $100,000). Only contributions from individuals apply toward this threshold. To receive the matching funds, the candidates must document their receipt of the funds raised from these individual contributors in a "threshold submission."

Documentation needed for threshold submission

The candidate must submit all contributions in accordance with the Commission's Guideline for Presentation in Good Order.

For each state in which a candidate certifies that the requirements for eligibility have been met, the candidate shall submit an alphabetical list of contributors showing the required information. Additionally, full-size photocopies of each written instrument or digital images, legible as to date, amount, payee and signature, must be submitted in support of each contribution that is to be used for establishing eligibility in each state.

Information required for each listed contributor

Each contributor must be listed by full name (last name, first name, middle initial, and suffix (Jr., Sr., III, etc.), if any) with the contributor's residential address. The residential address must include the street number and name (or box number), city, state and ZIP code. Contributions submitted for joint account holders must be recorded separately, even if the contribution is received in the form of one check. However, contributions drawn on accounts maintained by more than one person must contain the signature(s) of each account holder to whom all or a portion of such contribution is attributed. The signature may be on the check or accompanying supporting documentation.

Additional information on the documentation required to accompany such contributions is found in the Commission's Guideline for Presentation in Good Order.

Bank documentation

Documentation must be provided as follows which indicates that the contributions listed were deposited into a designated depository:

  • Bank validated deposit slips are acceptable and should be obtained for recently deposited contributions for which a bank statement may not be available at the time the matching fund request will be submitted.
  • Non-bank validated deposit slips plus photocopies of bank statements showing the deposit are acceptable.

Documentation of contributions made by credit card, debit card, or electronic check

A campaign committee must take steps to ensure that the person making a credit card contribution over the internet actually owns the card or account on which the charge is made. The use of a credit card's security code provides adequate assurance that the person making the contribution is in physical possession of the credit card. Additionally, billing address verification helps to confirm that the person in physical possession of the credit card is also the owner of the credit card by soliciting and verifying personal information about the card's owner. These procedures, in conjunction with the Committee's collection of personal information about the contributor and its requirement that the contributor provide specific affirmations that it was not made by a prohibited source, are sufficient to allay concerns that the contributor is someone other than the credit card owner.

The documentation requirements developed for credit and debit cards also apply to electronic checks. The information required from third party processors documenting the transmission of funds in a credit or debit card situation will also be required where an electronic check transaction is transmitted through a third party processor. Additionally, presidential campaigns seeking matching funds must provide to the Commission each contributor's checking account number and bank transit number for that account.

Additional information on the documentation required to accompany such contributions is found in the Commission's Guideline for Presentation in Good Order.

Contributions received from joint fundraising and/or entertainment events

If not evident on the face of the written instrument, each contribution received as a result of joint fundraising activities and/or entertainment events must be annotated as such. If contributions received from joint fundraising activities are included, a copy of the joint fundraising agreement, signed by representatives of each participating candidate/committee, must accompany the submission. If contributions from entertainment events are included, a copy of the promotional material and a copy of a ticket at each price must accompany the submission. The promotional material and tickets must clearly indicate that such purchase represents a contribution to the candidate/committee.

Contributions that lack documentation for matching

Contributions that are received by a candidate/committee without the additional documentation required for matching should be deposited and withheld from submission by the candidate/committee until the required additional documentation is obtained from the contributor or appropriate source. After the documentation is received, the contribution and documentation should be submitted for matching.

Documentation for additional submissions

All additional submissions for payments filed by the candidate shall be made in accordance with the Federal Election Commission's Guideline for Presentation in Good Order.

The first submission for matching funds following the candidate's threshold submission shall contain all the matchable contributions included in the threshold submission and any additional contributions to be submitted for matching in that submission, with all the information required for the threshold submission. However, it does not need to be segregated by state as required in the threshold submission.

Recordkeeping of funds received and disbursed by GELAC fund

Publicly funded major party general election candidates must pledge not to accept private contributions for the campaign. Private contributions may, however, be accepted for a special account maintained exclusively to pay for legal and accounting expenses related to complying with campaign finance law. This account is called the General Election Legal and Accounting Fund (GELAC fund).

All contributions made to the GELAC fund are subject to the same recordkeeping requirements that apply to all other receipts by federal candidates.

Disbursements made from the GELAC fund must be documented in the same manner as other qualified campaign expenses and disbursements by publicly funded committees.