Reporting to FEC and FEC Data Processing

Overview

We needed to understand the corresponding steps of the FEC financial campaign data processing to design a system that provides the individual contribution data faster and more convenient than the FEC web interface and OpenFEC. We will share those steps in this section.

The data is spread over a multitude of sources as FEC's data processing cycle can take up to months. Processed an unprocessed data has to be pulled from different endpoints. Furthermore, to pin down recent individual donors by their exact locations, the raw uploaded filings of each recipient committee have to be downloaded and parsed.

The processing schema of the FEC is illustrated in the Federal Election Commission (FEC) Data platform overview. Depending on the type of committee, different reports are filed with the FEC. The different reports require separate workflows in the FEC Data system to be all shown in the data for a candidate's principal campaign committee.

The different ways that contributions are given to various committees can be complex if we account for earmarked contributions and joint fundraising committees to gather as many disclosed individual contributions as possible. For example, the ways donations are contributed to Donald Trump's campaign are shown in this flow chart:

Important Concepts in FEC Campaign Financing

Committee Types

Filings

Filing Contributions from Individuals in Forms 3P/3X

Authorized Committees
Presidential (also: House and Senate) candidates must designate a campaign committee. This authorized committee takes in contribution and makes expenditures on behalf of the campaign.

Presidential Committees
Presidential Committees file contributions from individuals in form 3P in line 17ai (F3P-17ai, also referred to as 17A).

Political Party Committees and Political Action Committees (PAC)
Political Party Committees and Political Action Committees file contributions from individuals to form 3X in line 11ai (F3X-11ai, also referred to as 11A).

Itemized Receipts (Form 3P/3X Schedule A)
A receipt in any of the following categories must be itemized if it exceeds USD 200 per calendar year, either by itself or when aggregated with other receipts from the same source: Contributions from individuals or groups other than political committees / Offsets to operating expenditures / Other receipts (such as interest and dividends earned on invested funds).

Although a committee only has to itemize contributions in its reports for persons (other than political committees) giving more than USD 200 per year, the committee's records must identify the sources of contributions of more than USD 50.

Remedying an Excessive Contribution
What happens if a contributor "over"-contributes? The itemized contribution data display contributions that exceed the allowed contribution limit. The FEC recommends the following steps:

• Refunding.
• Re-designation: by contributor or by committee (e.g., primary->general election).
• Re-attribution: by contributor or by committee (-> joint contribution by several contributors)
  within 60 days.

Direct Contributions to Committees

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Earmarked Contributions

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Contributions to Joint Fundraising Committees

Overview

Donations to Joint Fundraising Committees (JFCs) are shared among the committee's participants according to an allocated formula.

Although the contribution amount arriving at a candidate's principal campaign committee is clear, the question remains whether the donor's intention is reproduced correctly. For example, a donor with the intention to donate to Donald Trump will visit the website https://donate.donaldjtrump.com, and may miss the note that only 0.75 cents for each dollar go to Donald Trump's principal campaign committee while the rest is allocated to the Republican National Party. It could be argued that the whole dollar should be regarded as contribution to Donald Trump's presidential campaign, at least in a comparison of donations between Republican and Democratic presidential candidates.

Contribution Limits for Joint Fundraising Committees

The interpretation of donations described above, however, does not sufficiently cover all situations as one of the reasons to start a JFC is to increase the legally allowed limit for contribution by individuals. The maximum donation limit to presidential candidate committees (2019-2020: $2,800 per cycle) is different than to a national party committee (2019-2020: $35,500). Please see table below for more details.

In the above example, the Republican National Party is allowed to receive up to a multiple per year than the candidate committee per election. Thus, in certain cases an interpretation of the whole contribution as a contribution to the presidential candidate does not make sense if used for a comparison of numbers to other candidates who do not use JFCs. In these cases, according to the disclaimer of the above mentioned JFC website, "the allocation formula may change if any contribution would exceed applicable contribution limits".

From the 99 form by committee "DONALD J. TRUMP FOR PRESIDENT, INC.", June 17, 2020, we learn that the exceeding amount of a contribution with a 75% share above $2,800 is not automatically assigned to the Republican National Party but can be reassigned or reattributed by the candidate committee as is common practice for all contributions by individuals exceeding limits. As the limit is per election, an individual can donate a total of 2 x $2,800 = $5,600 per election cycle, once for primary elections and once for general elections. In the case of the Trump Victory Committee, the quota is 100% for Trump which means that contributions up to $5,400 are assigned to Trump while every dollar above this limit is assigned to the other participants (RNC and Republican State party committees). Lastly, a donor may also "designate a contribution for a specific participant or participants" of the JFC.

The above remarks expound the difficulties in interpreting the contributions to JFCs regarding the intentions of donors especially when comparing absolute contribution numbers between candidates.

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Note: The user is allowed to make his or her own interpretation, and we add the option to regard either the whole contribution as contribution to the candidate or only the JFC participant's share.

How are the Reporting Limits Enforced?

A candidate committee is required to itemize individual contributions when they exceed $200 in the election period from the same source. If a contribution transferred from a JFC leads to an excessive contribution it is reported independent from its individual amount. Also, "If any prohibited contributions are received for a participating unregistered organization, the joint fundraising representative must report them as a memo entry".

JFC Donation Distribution: Incomplete Reporting

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