Campaigns & Elections: Guarding Against Unauthorized Transactions
Campaigns & Elections Magazine | By Emily Tadlock | July/August, 2013, Issue 319
A simple approval process can save your campaign a major headache
All too often campaigns don’t have the necessary checks and balances in place when it comes to expenditures. If a transaction hasn’t been authorized or isn’t disclosed, then it’s potentially illegal. It could also raise a red flag with the Federal Election Commission should it be uncovered. It should go without saying that these are realities you don’t want to be faced with after Election Day. Here are five steps to protect your campaign:
1. Prohibit in-kind contributions
In-kind contributions are really both an expense and a contribution that take place simultaneously. To make matters worse, in-kind contributions are rarely approved by your treasurer in advance of the gift’s acceptance. A policy of accepting in-kinds greatly increases your risk of inadvertent corporate contributions.
In many cases, treasury and/or compliance teams are not made aware of in-kind transactions, therefore the transactions go undisclosed. Former Nevada Sen. John Ensign’s (R) campaign recently paid a $32,000 fine for failing to disclose a substantial in-kind donation.
2. Require approval for every expenditure
Here’s a simple sample process for an approval structure that can be suited to your campaign operations:
- $5,000 or less: Approval required by division director
- $5,000 to $100,000: Approval required by division director and CFO
- Over $100,000: Approval required by division director, CFO and campaign manager
3. Implement an ongoing self-audit process
It’s best practice to make one of your staff the file manager to act as your in-house audit response liaison. It’s your file manager’s responsibility to serve as a final check on your expense and receipt-documentation requirements. The file manager’s expense review should come before each fling at the very least and more frequently depending on the number of expenses your campaign is incurring.
4. Implement an ongoing compliance review for all fundraising channels
Campaigns must combat the issue of unchecked contribution flow from all sources of funds raised. In all cases, these gifts must comply with the FEC’s contribution rules. A couple of the most obvious channel issues include:
Online Donations: Serious campaigns must employ the use of political online fundraising tools such as WidgetMakr, which are built specifically to comply with federal campaign finance law. Very frequently, those new to political fundraising will use a non-political specific Google/Paypal/Yahoo! donation form and end up having to return the gifts because they didn’t capture the donor data required for FEC disclosure reports.
Bundlers/Volunteer Fundraisers: Contributions collected or “bundled” by your volunteer fundraisers require that your finance team and their volunteers are fully educated on current FEC contribution rules. This is even more important if your fundraisers are also lobbyists. Knowing basic fundraising rules should be required by the CFO or treasurer, as well as any campaign manager.
5. Hire professionals
Considering the risk of not implementing systems to comply with the ever-changing and expanding FEC regulations, it’s most cost effective to engage professionals to manage your campaign finances and ensure that all of your disclosure reports are filed accurately and on time. A professional compliance team will work to ensure 100 percent compliance, or else they wouldn’t be professionals.
As we approach 2014 and beyond, the candidate that’s most efficient with their resources has a huge competitive advantage. Establishing automated compliance and fundraising processes now is one of the best uses of your resources as the 2014 political cycle kicks off.
Emily Tadlock currently works in the political department of CMDI where she has served multiple presidential campaigns, JFCs and senatorial committees. Prior to joining CMDI, Emily served as treasury operations manager for the McCain-Palin campaign and comptroller on the 2008 Giuliani presidential campaign.
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