Your FEC Statement of Organization, also known as FEC Form 1, is a document that must accurately represent your PAC at all times. Oftentimes changes within the connected organization result in the PAC needing to update the FEC Form 1.
As soon as you learn changes are occurring, the FEC requires you to file an amended Form 1 within 10 days of the changes taking place.
Why would I need to update my FEC Form 1, you ask? The most common reason we see at PASS is the appointment of a new PAC Treasurer. A PAC Treasurer is the one position required by the FEC and that position must never be vacant. Other reasons include a change in banks, the committee or the business address has changed, or there is a change to the Custodian of Records.
Another time you will need to update your FEC Form 1 is when your organization merges with another company and either changes the company name or the other company also has a PAC. Once the merger is complete, assuming the two PACs still exist, the two PACs are now affiliated and both PACs will have to amend their FEC Form 1 to show an affiliation with the other PAC. Both PACs will also share limits, but that’s a topic for another blog.
Should you need to amend your FEC Form 1, simply provide your PASS Compliance Manager with the updated information and they will prepare the amended form and send it for your review. If the change is the appointment of a new Treasurer or Custodian of Records, that individual must acquire a new password to electronically file the amended Form 1 and subsequent reports. A committee’s Treasurer or Assistant Treasurer can request or change an electronic password online at www.fec.gov/elecfl/passwords.shtml. (from FEC page 11 of Campaign Guide for Political Party Committees (August 2013)).
If you have any organizational changes or want to discuss upcoming mergers/acquisition changes within your organization, please contact your Compliance Manger and they will make the process seamless.