With the April 15th FEC Quarterly Report filing deadline quickly approaching, it’s important for committees that are required to file to implement best practices and avoid potential filing mistakes that could result in administrative action being taken by the FEC.
File Reports On Time
- While some states have postponed campaign spending disclosure deadlines in response to the coronavirus, the FEC does not have statutory authority to extend the deadline. Therefore, April quarterly reports remain due on April 15.
Avoid Common Reporting Errors
- Be sure to designate which election a contribution is applied towards. Contributions not designated are automatically applied to the next election a candidate is running in. This may result in an excessive contribution if a committee is not aware of which election a contribution is being applied towards.
- Be aware of primary election dates to avoid designating contributions to federal candidates for elections that have already occurred. Before a contribution is designated to be made for debt retirement, it should first be confirmed that the candidate committee has debt. Additionally, these contributions should note the year, debt, and election.
- Check the most recent updates on what the FEC considers to be adequate or inadequate purposes of disbursement. “Fees,” “campaign expense,” and “reimbursement” are all examples of an inadequate purposes of disbursement. As a general rule, a person not associated with the committee should be able to easily discern why the disbursement was made by reading the filing.
Ensure that Internal Committee Controls are in Place
- Open bank accounts using the name of the committee and the Employee Identification Number (EIN) instead of using the name of the person opening the account.
- Review and reconcile bank statements each month and to FEC reports prior to filing with the FEC.
- Limit the number of persons with access to committee funds and persons authorized to sign checks.
A complete list of best practices for FEC filing can be found here.