FEC issues interim reporting guidance for national party accounts (2015)
On February 13, 2015, the Federal Election Commission issued interim reporting guidance for national party committee accounts.
On December 16, 2014, President Obama signed into law the Consolidated and Further Continuing Appropriations Act, 2015 (H.R. 83). Provisions of that law enable national party committees to establish accounts to defray certain expenses incurred with respect to:
- Presidential nominating conventions;
- National party headquarters buildings; and
- Election recounts and contests and other legal proceedings.
Until the Commission adopts new regulations, national party committees that establish such accounts should report the activities of those accounts as described below.
Although party committees normally disclose their contributions on Form 3X, Line 11(a), the Commission''s forms currently do not provide a clear way to distinguish between contributions deposited into the committees' separate accounts. Thus, as described below, national party committees should report the contributions deposited into their presidential nominating convention, national party headquarters buildings, or election recounts and contests and other legal proceedings accounts as "other federal receipts," with the appropriate descriptions. Similarly, the committees should report expenditures from these accounts as "other federal operating expenditures" or "other disbursements" (depending upon the account, as explained below), with the appropriate descriptions.
Interim reporting instructions
Report all receipts and disbursements for all accounts pursuant to the Federal Election Campaign Act of 1971, as amended, and Commission regulations. See 52 U.S.C. § 30104 (formerly 2 U.S.C. § 434); 11 CFR Part 104.
Presidential nominating convention account (“Convention Account”)
- Committees should report contributions deposited into the Convention Account on Line 17 of Form 3X titled “Other Federal Receipts.”
- When itemizing on Schedule A, filers should identify those receipts by entering “Convention Account” in the description field.
- Report administrative or operating expenses made from the Convention Account on Line 21(b) of Form 3X titled “Other Federal Operating Expenditures.”
- When itemizing on Schedule B, filers should identify these disbursements by entering “Convention Account” in the Purpose of Disbursement field along with the required purpose of the disbursement (e.g., “Convention Account – Bookkeeping and Compliance”).
National party headquarters buildings account (“Headquarters Account”)
- Committees should report contributions deposited into the Headquarters Account on Line 17 of Form 3X titled “Other Federal Receipts.”
- When itemizing on Schedule A, filers should identify those receipts by entering “Headquarters Account” in the description field.
- Report administrative or operating expenses made from the Headquarters Account, on Line 21(b) of Form 3X titled “Other Federal Operating Expenditures.”
- When itemizing on Schedule B, filers should identify these disbursements by entering “Headquarters Account” in the Purpose of Disbursement field along with the required purpose of the disbursement (e.g., “Headquarters Account – Carpeting”).
Election recounts and contests and other legal proceedings account (“Recount Account”)
- Committees should report contributions deposited into the Recount Account on Line 17 of Form 3X titled “Other Federal Receipts.”
- When itemizing on Schedule A, filers should identify those receipts by entering “Recount Account” in the description field.
- Report administrative or operating expenses made from the Recount Account, on Line 29 of Form 3X titled “Other Disbursements.”
- When itemizing on Schedule B, filers should identify these disbursements by entering “Recount Account” in the Purpose of Disbursement field along with the required purpose of the disbursement (e.g., “Recount Account – Legal Services”).
Political committees with specific questions regarding their reporting obligations may contact the Reports Analysis Division at (800) 424-9530 (at the prompt, press 5). Others may contact the Information Division at (800) 424-9530 (at the prompt, press 6).
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