Contributing to non-federal / State-level candidates can be tricky. The limits are different in all 50 states. Some states have blackout periods during which you cannot make contributions. Some states are very restrictive about how (or whether) your Political Action Committee (PAC) or organization can contribute to candidates running for state and local office. Contacting the Secretary of State in each state is time consuming. Ask the right question the wrong way and you may not get the answer you need. Ask two different representatives in the Secretary of State’s office and you could get two completely different answers.
Making the non-federal contribution is just one piece of the puzzle. Reporting those contributions can be even more confusing. Trying to figure this all out on your own is a recipe for making a costly mistake and potentially damaging your organization’s reputation by inadvertently contributing when you shouldn’t or failing to report when you should. The chance of making a mistake increases exponentially as your PAC makes campaign contributions in more states. State campaign finance laws present challenges with inconsistent campaign finance contribution limits, reporting requirements and filing deadlines.
First you need to decide how to register in the state. Will your organization make contributions to state-level candidates out of the Federal PAC? Or, do you need a separate state PAC? In some states, your organization can make contributions from Treasury funds directly to campaigns. If your organization would like to start making contributions in the states using your PAC or funding directly from the organization, the campaign finance compliance experts at PASS can help. Our team of compliance experts and our dedicated State Law Specialist will walk you through the rules and reporting requirements for making non-federal contributions.
Once you make the decision to become active in a state, the PASS team will complete and file your registration statements, review your contributions to make sure they meet the state or local rules, and keep track of all of your reporting obligations. When it comes time to report, your PASS Compliance Manager will prepare your reports, send them to you for review, and then electronically file them to make sure your reports are accurate and you never miss a deadline.
When you are ready to begin contributing to candidates running for state and local offices, PASS’ compliance team will review all disbursements to make sure the PAC or entity is properly registered, ensure compliance with giving limits, proper election designation and track reporting requirements.
All disbursements are stored in a database and reviewed regularly to determine any reporting obligations. Not all reports are scheduled. Some are triggered by the timing of your contribution. The campaign finance experts at PASS keep track of both required and triggered reports and review your contributions to determine which reports, if any, must be filed. If a compliance report must be filed, your Compliance Manager will prepare the report and send it to you for review. You review and approve the report and your Compliance Manager will electronically file your report prior to the reporting deadline.