Paying for Transition Costs

Campaigns of retiring officeholders should review Advisory Opinion 2010-26, in which the Commission ruled that a retiring Congressman may use campaign funds to pay temporary storage costs associated with the move back to his home because those costs are an ordinary and necessary expense incurred in connection with his duties as a holder of Federal office and not an illegal "personal use" of campaign funds. The costs are reportable as "other disbursements" on Line 21 of FEC Form 3, with the specific payee(s) and purpose noted. Likewise, in Advisory Opinion 1980-138, the Commission concluded that a Senator-elect could use campaign funds to pay the expense of moving himself and his family to Washington, D.C. for similar reasons, and with the costs similarly reported.