In the waning days of the quarter, candidates have one thing on their minds as they franticly dial through call sheets and rush to events: Raise as much money as possible. FEC reports, and their state equivalents are the public’s window into the health and strength of a campaign. Reporters, supporters, and opponents pore over reports like a parson studies the Bible.
Unfortunately, raising the money is only part of the struggle. At midnight on the day of the fundraising deadline, the relay race doesn’t abruptly halt. The baton is passed from the candidate and the fundraising operation to the treasury operation or whoever is designated to file the disclosure reports.
Here’s a concise checklist that candidates and their campaigns can use in the pre-filing period to impose some order on the chaos. While this checklist is primarily intended for federal campaigns, similar principles are helpful for state campaigns.
1. Make sure all information is accounted for.
This seems obvious, but there are many moving parts a campaign must deal with in order to file a complete and accurate FEC report. You must account for all receipts and expenses. Receipts include all contributions, including contributions from joint fundraising committees and conduits.
It also includes in-kinds, advances by staff and candidates, and loans from the candidate. In gathering this information, the campaign should communicate with all fundraisers, both in-house finance staff and outside fundraising professionals. Clear and frequent communication is important. You must pay attention to FEC regulations on when a contribution is received. A campaign cannot include contributions that were received after the end of the reporting period in order to pad its fundraising numbers.
2. Calculate any debts for debt schedule.
The FEC has very specific rules about reporting debt. A campaign should consult with a reputable election law attorney for specifics. In short, among other requirements, a campaign needs to include on a debt schedule any debt exceeding $500 incurred during a reporting period with the exception of “regularly recurring administrative expenses such as rent, utilities, and salaries.”
3. Perform a comprehensive bank account reconciliation.
If you hire a professional compliance firm, their dedicated staff will perform bank account reconciliations on a more frequent basis. But it’s very important that a campaign’s bank accounts match a campaign’s internal database. You’ll need to address discrepancies found during a bank account reconciliation and correct them before a report is filed. A good bank account reconciliation will uncover transactions that are missed due to data error or technical error. There’s no substitute for human intelligence and analysis.
4. Prepare a press release to preview numbers.
Many campaigns, especially if they’ve had a good fundraising quarter, will want to disclose their fundraising totals to the press in advance of filing their report. It’s a chance to show the public how strong a candidate is and how much support they’ve garnered over the course of the campaign.
But the press blitz shouldn’t occur until the above steps have been completed. There’s nothing worse than having an incomplete number trotted out to the press that’s not supported by the FEC report that’s filed. Be careful with aggressive rounding. Numbers are not subjective.
5. Have multiple people review drafts of the report.
Now, a draft FEC report is no bestselling novel, but it still requires multiple people from different parts of the campaign, including campaign counsel, to read it with a careful eye. You should report activity on the correct schedules and lines. Purpose descriptions should meet FEC guidelines. Where appropriate, add memo text to clarify certain things for the FEC and the public.
Different people who review will find different errors that’ll require corrections prior to filing. The more people who review the report, the better your report will be. You can root out lots of typos, data errors, and assorted human errors.
6. Plan to file the report with enough time to spare.
This requires that a lot of work is done efficiently. Like a term paper in high school, FEC reports aren’t something to compile at the 11th hour. Complete most of the difficult work right after the reporting period closes. That way, if there are big problems, the campaign will have ample time to fix whatever needs attention.
This will also allow plenty of time to review. On filing day, the campaign should not wait until late in the night to file. They should file earlier so that if there are any technical problems, they can be addressed or a call can be placed to the FEC for technical assistance. You want buffer time in the case of unforeseen problems. Lots of things can happen to a campaign on filing day. The campaign’s Internet could go down. Power could go out in the neighborhood. A smart campaign won’t leave things to chance.
Brad Crate is the founder and president of Red Curve Solutions, a GOP compliance firm.