Political action committees (PACs) are a critical tool that business entities and associations rely on to assist in their political activities. With respect to federal PACs, those that contribute to federal candidates, the reporting specifications and regulations are governed by the Federal Election Commission (FEC).
During most calendar years – depending on the election activity – federal PACs can elect to file monthly reports due on the 20th for the month immediately preceding, or quarterly or semi-annual reports. However, in major federal election years – like 2020 – the reporting requirements become much more significant and require additional attention from PAC treasurers and compliance professionals.
Considering the number of special elections, run-off races and various state primaries, there is a potential of approximately 150 filing deadlines that PAC treasurers must meet in a typical year. Because of that, PACs that are active in their contributions to federal candidates may want to consider a changeover to the monthly reporting status. While this guarantees a PAC report every month, it also eliminates the complications associated with filing nearly 150 reports before primaries in races where the PAC has already supported a candidate. A change in reporting can be done at any time as long as the Form 99 is filed with the FEC before the first monthly report is filed.
For PACs electing to remain on a quarterly reporting schedule, the treasurer and other compliance professionals should be aware of all 2020 reporting deadlines. They should consider carefully reviewing any campaign contributions and calendar the required reporting date(s) to avoid missing any and incurring resulting penalties.
As with any required reporting, it is imperative to know the deadlines and to understand the underlying activity to ensure effective compliance with all relevant laws and regulations.
For more information, please contact the Barnes & Thornburg attorney with whom you work or Ron Miller at 202-408-6923 or ronnie.miller@btlaw.com.
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This Barnes & Thornburg LLP publication should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own lawyer on any specific legal questions you may have concerning your situation.
