The Complete Guide to FEC Compliance for Campaign Treasurers

FEC compliance is one of the most critical—and most stressful—aspects of running a federal campaign. Get it right, and your campaign runs smoothly. Get it wrong, and you're facing fines, legal headaches, and potential criminal liability.

This guide covers everything campaign treasurers need to know to stay compliant.

Understanding FEC Reporting Requirements

Who Must File

Federal election law mandates that all federal candidates and political committees maintain rigorous financial reporting schedules. This requirement extends beyond just the principal campaign committee to include any authorized political action committees (PACs), Super PACs supporting the candidate, and relevant party committees. While state and local campaigns operate under their own sets of rules with local election authorities, federal compliance is uniform and strict. Every dollar raised and spent must be accounted for according to federal statutes, with no exceptions for size or scope of the campaign.

Reporting Deadlines

The Federal Election Commission operates on a strict calendar that allows for no flexibility. Committees must file quarterly reports on April 15, July 15, October 15, and January 31 of the following year. As the election approaches, the pace accelerates significantly: Pre-Election Reports are due 12 days before any primary or general election, and Post-Election Reports are required 30 days after the general election. Perhaps most critically, in the final 20 days before an election, campaigns must file 48-Hour Reports for any contribution of $1,000 or more. Missing a deadline results in automatic fines and public bad press, so we recommend building these dates into your campaign calendar with significant buffer time.

Contribution Limits and Restrictions

2024 Contribution Limits

For the 2024 cycle, individual donors are limited to contributing $3,300 per candidate for the primary election and another $3,300 for the general election—these are treated as separate limits. Individuals may also contribute up to $41,300 per year to national party committees and a total of $106,500 annually to all federal political committees combined. Political Action Committees (PACs) are subject to different rules, with a limit of $5,000 per candidate per election and $15,000 per year to national party committees. Tracking these aggregate limits across spouses, partnerships, and multiple donations is one of the most complex accounting challenges a treasurer faces.

Prohibited Contributions

Certain contributions are strictly illegal and must be rejected or returned immediately. Campaigns cannot accept funds from foreign nationals, federal government contractors, or corporations (in the case of candidate committees). Additionally, strict rules govern the method of contribution: cash contributions over $100 are prohibited, as are anonymous contributions exceeding $50. If you receive a contribution that potentially violates these rules, the safest course of action is to return it within 30 days and document the reason for the refund to ensure you have a paper trail if questioned later.

Common Compliance Mistakes (And How to Avoid Them)

Mistake 1: Incomplete Donor Information

The FEC requires campaigns to report the name, address, occupation, and employer for any individual who contributes more than $200 in an election cycle. A common failure mode is collecting donations without required fields, forcing staff to chase donors weeks later for employment details. The solution is simple: make occupation and employer fields mandatory on all donation forms, regardless of the amount. It is far easier to collect this data at the point of enthusiasm than to extract it via email months later.

Mistake 2: Exceeding Contribution Limits

With fundraising occurring across multiple channels—online forms, physical events, mailers, and joint fundraising committees—it is dangerously easy to accept more than the legal limit from a single donor. If a donor gives $3,300 online and then writes a check for $1,000 at an event, you have a compliance violation on your hands. We recommend using software like DonorSense that tracks aggregate contributions in real-time across all sources and prevents over-limit donations from being processed.

Mistake 3: Improper Attribution of Joint Fundraising

Joint fundraising agreements allow candidates and parties to raise money together, but they come with complex accounting requirements. Expenses and contributions must be attributed according to specific allocation formulas agreed upon in advance. Treasurers should work closely with experienced compliance counsel when establishing these committees to ensure the allocation methodology is documented clearly and followed precisely for every transaction.

Mistake 4: Missing 48-Hour Notices

The final weeks of a campaign are chaotic, but they are also when large contributions are most likely to arrive. Any contribution of $1,000 or more received within 20 days of an election triggers a mandatory 48-hour disclosure window. Failing to file these notices is one of the most common reasons for FEC fines. Automated monitoring systems can flag these qualifying contributions and even draft the required reports, ensuring they don't get lost in the noise of the final push.

Mistake 5: Inadequate Recordkeeping

The FEC has the authority to audit campaign records for up to three years after an election. If an audit occurs and you cannot produce bank records, donor cards, or expenditure receipts, you face liability regardless of whether any actual violation occurred. The ongoing best practice is to digitize and organize every financial document immediately upon receipt, maintaining a redundant backup system that ensures your records survive even if a laptop is lost or a hard drive fails.

Best Practices for Compliance Management

1. Start with Good Systems

Attempting to retrofit compliance into a donor database that wasn't designed for it is a recipe for disaster. Choose a platform that has compliance logic built into its core, enforcing limits and collecting required data automatically.

2. Train Your Team

Compliance isn't just the treasurer's job. Every staff member who touches money or donor data—from the finance director to the intern checking guests in at a fundraiser—needs to understand the basic rules. A single well-meaning volunteer can inadvertently create significant legal exposure.

3. Review Before Filing

Never file a report without a "human review" phase. Even the best software can miss context that a human eye will catch. Check for mathematical consistency, missing donor information, and proper categorization of disbursements before hitting submit.

4. Build in Buffer Time

Compliance emergencies almost always result from procrastination. If a report is due on the 15th, aim to have it drafted by the 12th and reviewed by the 13th. This buffer allows you to resolve any discrepancies without the panic of a looming midnight deadline.

5. Document Everything

In compliance, if it isn't written down, it didn't happen. Maintain meticulous records of contribution refunds, "best efforts" to collect donor information, and internal decisions regarding questionable contributions. Your documentation is your primary defense.

When to Seek Professional Help

While software can handle the day-to-day mechanics of compliance, there are times when professional expertise is non-negotiable. Complex joint fundraising arrangements, unexpected legal challenges, or questions about specific expenditures often require the counsel of a dedicated compliance attorney. Similarly, if your campaign lacks an experienced in-house treasurer, hiring a professional compliance firm is often cheaper than paying the fines for getting it wrong. The cost of good counsel is an insurance policy against reputation-damaging violations.

Key Takeaways

1. Know your deadlines—build them into your calendar with reminders
2. Collect complete donor information at the point of contribution
3. Use software that tracks limits and flags issues in real-time
4. Document everything, keep records for at least three years
5. When in doubt, consult a professional

Civitas DonorSense includes built-in FEC compliance automation that catches issues before they become problems. See how it works.