Policy statement on reporting "purpose of disbursement"
On December 14, 2006, the Commission approved a Statement of Policy designed to improve the descriptions of the purpose for each itemized disbursement that political committees and others disclose on their FEC reports. The policy was published in the January 9, 2007, Federal Register. 72 FR 887.
FEC regulations require that the "purpose of disbursement" entry for each disbursement be sufficiently specific, when considered with the identity of the recipient, to provide a clear reason for the payment. The regulations also provide examples of acceptable and unacceptable descriptions, but the lists are brief and not exhaustive. 11 CFR 104.3(b)(3) and (4).
The new policy statement includes non-exhaustive lists of acceptable and unacceptable "purpose of disbursement" descriptions intended to provide additional guidance to the regulated community and to foster consistency among filers. As a rule of thumb, the statement suggests that filers consider whether a person unaffiliated with the campaign/committee could discern why a payment was made by reading the description they have provided.
The Commission added one additional term, "Consulting-Political," to the non-exhaustive list of generally insufficient descriptions, based on public comments it received on the proposed policy. To the non-exhaustive list of generally acceptable descriptions, the Commission added "Consulting-Media," "Consulting-Fundraising," "Consulting-Polling," "Consulting-Legal" and "Consulting-Get-Out-The-Vote."
The policy statement is available on the Commission’s website.