Tidying up: Spring cleaning for your PAC

Bricker & Eckler LLP

With a busy state and federal election cycle coming up this year, spring is an ideal time to give your Political Action Committee (PAC) a thorough cleaning. These checklist items should be part of your regular PAC maintenance. If you haven’t asked yourself these questions in a while, now is an ideal time. 

Statement of organization/designation of treasurer

  1. Are your treasurer and deputy treasurer listed correctly?
  2. Is all contact information still accurate?
  3. Is your disclosure of affiliated PACs up to date?
  4. If you are required to keep a copy of your federal statement organization on file with state regulators (Ohio requires this of any federal PAC that wishes to make contributions to state and local candidates), is your filing current?

Bank accounts

  1. Have you reconciled the PAC balance and the bank balance? Preferably, this reconciliation should be done by someone other than the person with daily responsibility for PAC operation.
  2. Have you reviewed bank statements for unauthorized transactions?  
  3. Do you know where PAC credit/debit cards are?

Internal controls

  1. Do you have a policy in place that requires checks over a certain amount to be signed by two people? If yes, is the policy being followed? If no, consider adopting one.
  2. Is your PAC board up to date on PAC activity?
  3. Have you calendared all filing deadlines and made note of current contribution limits? Contribution limits and filing deadlines change depending on the election year.
  4. Are all contributions promptly deposited into the PAC account?
  5. Have you reviewed and updated your solicitation materials?
  6. Has your PAC treasurer or designee taken a training course or reviewed guidance materials to remain updated on recent developments and requirements?    

While solidifying the answers to these questions may be less satisfying than decluttering that spare bedroom closet, keeping your systems, processes and information up to date promotes compliance — especially during harried election seasons. Who knows? Crossing these items off the list may even bring some joy to you and your team.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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