A campaign is like a long party. At the end of the night, bottles need to be cleaned up, chips need to be slept off the floor and furniture put back. While many staff and consultants have already hit the road and won’t look back at the mess they made (even if it was a winning mess – it’s still usually a mess), a smart campaign needs to do a number of things to maximize compliance with their regulatory body.
Even though staff is burned out from a grueling campaign, they must attend to several action items in the post-Election Day period. And the sooner the better.
Before staff and consultants jump onto their next race, it’s important that someone on the last campaign gather everyone’s contact information. As campaigns are short-lived, the institutional knowledge of the entity is probably not centralized. Questions will emerge in the weeks to come and those managing the entity through termination will want to quickly locate the person with the answer – even if it’s as simple as, whose jacket is this?
Campaigns often utilize recurring services. It may be a month-to-month lease. It may be a digital donation merchant. Either way, it’s important to find the governing contract and submit a written notice that services will be ending pursuant to the contract’s termination clause. The worst thing a campaign can do is incur charges for services that aren’t needed.
That is a waste of precious, and at this point in the campaign, likely very limited dollars. Everyone likes to drink the beer out of your keg – but no one will want to reimburse you for the deposit if you lose the empty one afterwards or don’t know where to return it. Along the same lines, campaign staff should lose access to their campaign credit cards and cellphones. It’s also prudent to maintain a compliance reserve fund for future reporting, legal, and accounting costs.
Next, staff should contact all vendors and announce a “last call” for invoices. Most vendors are good about invoicing, but some drag their feet. A campaign needs to assess the extent of its liabilities as soon as possible. It needs to see if it has enough cash to pay its bills. If it doesn’t have enough cash, it will need to raise debt retirement money from donors. Or if the candidate has the means, the candidate can make a contribution to bridge the difference. Either way, most campaigns cannot terminate with its regulatory body until it has no debt and a zero cash balance. You may need to pass the hat.
Until a campaign terminates, it will need to continue to file reports with its regulatory body. The treasurer and his staff will need to respond to correspondence from the regulatory body—whether it’s the Federal Election Commission (FEC) or its state equivalent. There’s still activity. Bills are due.
The campaign might receive vendor refunds for previous overpayments. You might receive security deposits. Revenue may be generated for a campaign that rents out its list of donors to other campaigns. A campaign may also liquidate its assets to help generate revenue. Bank accounts will need to be reconciled. And believe it or not, a campaign will still receive mail for quite some time.
The days after an election are eerily calm. They’re a good time for reflection about the campaign’s strengths and weaknesses. Another way to think about it: After a party, you might reconsider a future guest list. It also is a good time for organization.
The campaign should organize all of their documents so that items can be easily retrieved if necessary years down the road. This includes, among other things, copies of invoices, contribution information, human resources files, and contracts. You should store the campaign’s files in a safe, secure, and accessible environment.
The time it takes to wind down a political entity depends on the size and duration of a campaign. A congressional committee that doesn’t make it past a primary is easy to close within a year.
A gubernatorial campaign might take a few years. A presidential campaign could take five or more years to successfully terminate. Since campaigns are by their nature, short-term entities, principal decisionmakers of a campaign don't always think about the post-election responsibilities.
The wind down often takes longer than the campaign. Going forward, it’s wise to think about the wind-down effort during the early stages of the campaign to ensure a smooth landing for what is often a tumultuous ride. It ensures that there are fewer empties to pick up the morning after.
Brad Crate is the founder and president of Red Curve Solutions, a GOP compliance firm.