pac.dog / 101

Module 3 of 9

Contributions, and the legal limits

Per FEC, federal limits (inflation-indexed; 2025-2026 cycle amounts):

• Individual → candidate committee: $3,500 per election (primary, general, runoff each count separately).
• Individual → PAC (multicandidate): $5,000 per calendar year.
• Individual → national party committee: $44,300 per year.
• Individual → super PAC: no limit.
• PAC (multicandidate) → candidate committee: $5,000 per election.
• Corporations and foreign nationals: prohibited from contributing to federal candidates. Corporations can fund super PACs.

States have their own parallel limits — usually lower for state and local offices, with distinct rules per state. pac.dog stores every rule in a single limit_rules table; the limit engine looks up the binding rule per contribution.

By state — rules that differ from federal

Federal elections are uniform across the country — the dollar caps in the table above apply identically in every state. But every state runs its own elections, registers its own voters, and regulates its own state-level candidates and committees on its own schedule. The four tables below codify every difference we mirror, sourced from each state's Secretary of State or election commission with the controlling statute cited. No vendors, no aggregator middlemen.

Voter registration cutoffs

Days before an election by which a voter must be registered to vote in it. The federal "motor voter" law (NVRA, 1993) sets a ceiling — states can't require registration more than 30 days before. Same-day registration states let you register and vote on Election Day itself; the days-before cutoff in those states is the cutoff for regular pre-election registration.

State primary election dates (2026)

Each state's election code sets when the state primary is held — "first Tuesday in March," "third Tuesday in May," etc. Louisiana's jungle primary uses the general date itself, so it has no separate state-primary date. The dates below compute deterministically from each state's rule for the 2026 cycle; the rule itself is the same every cycle.

State PAC filing cadence

The state-level equivalent of FEC Form 3X. Each state defines a pre-election report (filed N days before an election), a post-election report (N days after), and a periodic / quarterly / annual cadence in between. Most states converge on 12-days-before, 30-days-after, semi-annual Jan 31 + Jul 31 — the ones below diverge, and each cite is to the campaign-finance statute, not the election statute.

State contribution limits

Each state caps state-level contributions on its own schedule. Some are flat dollar amounts; some scale with the office; some states (Texas, Virginia, Oregon, Missouri) cap individual → state-candidate contributions at nothing — no ceiling. The schema for these rows is in place (limit_rules), but the per-state codification is not yet shipped. Federal-limits first, then state-by-state on the same shape as the deadline rules above.

State filing / itemization thresholds

Federal: a committee must itemize every contribution above $200 from a single source per cycle (donor name, address, employer, occupation). State thresholds vary widely — from $0 (every contribution itemized) to $500 — and roll into the same per-state codification as the limit rules above.

Compliance gotchas (the rules nobody mentions until they bite)

The dollar caps in the limit table are the famous numbers. These are the operational rules a treasurer actually has to remember. Most are federal under 11 CFR; the state-specific ones are flagged.

When is a contribution "received"?

The contribution's date for limit + reporting math is 11 CFR §110.1(b)(6):

• Check (mailed)— the date the donor wrote it. The committee's receipt date governs deposit deadlines, not limit math.
• Credit card — the date the donor authorized the charge. Even if the gateway settles three days later, the contribution date is the auth date.
• In-person cash — the date the committee took custody. (Cap: $100 per donor per election; over that, refuse + return.)
• Online (ACH/bank transfer) — the date the donor submitted the gift, regardless of when funds settle.

Deposit deadlines (10-day clock)

Per 11 CFR §103.3(a) — every contribution must be deposited within 10 days of receipt. Contributions that may exceed a cap or come from a prohibited source (foreign national, corporate to non-super-PAC, government contractor) get a separate §103.3(b) 10-day window during which the treasurer decides to keep, return, or refund. Beyond that window the funds are presumed accepted and the committee is on the hook.

Best efforts (occupation + employer)

For any contribution aggregating over $200 from a single source per cycle, a treasurer must use 11 CFR §104.7 “best efforts” — at least one written or oral request for the donor's employer and occupation. The standard solicitation already prints the request alongside the donate field; the rule kicks in for follow-up if the donor leaves either blank.

Anonymous + cash caps

• Anonymous contributions over $50 (11 CFR §110.4(c)(3)) can't be deposited. Donate them to a 501(c)(3) or the U.S. Treasury. $50 or less can be retained but not itemized.
• Cash (currency) contributions over $100 (11 CFR §110.4(c)(1)) are prohibited from any source. Refuse + return.

Payroll deduction (state-specific gotchas)

Federal SSFs (corporate / labor PACs) can solicit payroll deductions from their restricted class under 11 CFR §114.5 with written authorization and a revocable opt-out. State rules layer additional constraints:

• New York — public-employee payroll deductions for political contributions to state candidates / state PACs are prohibited (N.Y. Elec. Law §17-148 + civil service rules). Private-sector payroll PACs are fine; the public-payroll restriction is the trap.
• Indiana, Kansas, Michigan, Tennessee, Wisconsin, Iowa — public-sector payroll deductions for political contributions are prohibited or sharply restricted under each state's civil service / labor statute. Private-sector payroll PACs are generally fine.
• Texas — no state-employer payroll deduction for political contributions to PACs (Tex. Elec. Code §253.034); private payroll PACs operate normally.
• Annual re-authorization— at the federal level and in most states, the donor must re-authorize the payroll deduction annually (or as frequently as required by the SSF's state plan). Treat as a calendar trigger.

Excess-contribution refund window

Any portion of a contribution that exceeds the per-election or per-cycle cap must be refunded within 60 days of receipt under 11 CFR §103.3(b)(3). Alternative: reattribute (to spouse, partner) or redesignate (to a different election the donor is eligible for) within the same window — both require written donor authorization within those 60 days.

Earmarking + bundling

• Earmarking (11 CFR §110.6) — when a donor directs a conduit (an intermediary committee) to forward funds to a specific candidate, the original donor + the conduit + the recipient each appear on the disclosure chain. The contribution counts against the donor's per-recipient cap, not the conduit's.
• Lobbyist bundling — authorized committees, leadership PACs, and party committees must disclose bundled contributions from registered lobbyists or lobbyist/registrant PACs aggregating over the BCRA-indexed threshold ($23,500 in the 2025-26 cycle) on a separate Form 3X Schedule A-1.

In-kind contributions

Goods or services donated to a committee count as contributions at usual and normal charge (11 CFR §100.52(d)). Volunteer time is exempt; if the volunteer is normally paid for the same service (a professional designer doing the website pro-bono), the market value is an in-kind contribution that counts against the donor's cap.

Joint fundraising committee (JFC) allocations

A JFC pools donations from multiple participants (candidates + committees) and splits proceeds by a written allocation formula before solicitation (11 CFR §102.17). The donor's contribution is split per the formula and each split fragment counts against the donor's cap for that recipient — not the full amount against each.

Coordination prohibitions

A super PAC's spending is “independent” only if it doesn't coordinate with the candidate or campaign. Specific triggers — listed at 11 CFR §109.21 — include: the candidate's campaign requesting the communication, the spender hiring a vendor who's also working for the candidate's campaign on the same project within 120 days, and republication of campaign material. Failing the independence test makes the "independent" expenditure an in-kind contribution subject to the (much lower) PAC-to-candidate cap.

What you can't say when soliciting

A solicitation is any communication asking for a contribution. It's the regulated act, not just the form. These rules govern what every "chip in" email, fundraising ad, mail piece, and donate page must — or must not — say:

• Disclaimer required (11 CFR §110.11) — every solicitation must say who paid for it. Three variants: authorized("Paid for by [Candidate] for Congress"), authorized by the candidate but paid for by someone else("Paid for by X and authorized by [Candidate] for Congress"), and not authorized("Paid for by Y and not authorized by any candidate or candidate's committee"). The disclaimer must be readable, contained in a box (print), or spoken with the same audibility as the main content (broadcast).
• "Stand by your ad"— for federal- candidate radio + TV authorized communications, the candidate themselves must say "I'm [Name] and I approve this message" ( 52 USC §30120(d)).
• Solicit only the eligible— can't solicit contributions from a federal contractor, a foreign national, a federal employee while on duty or in a federal building (11 CFR §114.5, Hatch Act5 USC §7323), or a minor under 16in their own name. The donate page's eligibility checkboxes exist for these.
• SSF restricted-class rule (11 CFR §114.5(g)) — a corporate or labor SSF can only solicit its restricted class(executive/administrative employees + stockholders + their families for corporations; members + their families for unions). Solicitations sent broader than that — including to the company's general workforce or external mailing lists — are a per-solicitation violation.
• No coercion (11 CFR §114.5(a)) — SSFs can't coerce employee contributions. The solicitation must affirmatively state that the contribution is voluntary, that refusal won't affect employment, and the recommended-but-not-required amount. Implicit pressure (manager standing over you while you fill out the form) is the violation worth knowing.
• No quid pro quo language— can't suggest a contribution will get the donor preferential government action, access, or an official appointment. Bright-line federal bribery territory under 18 USC §201 and the "official act" line drawn in McDonnell v. United States (2016).
• Foreign-national certification (11 CFR §110.20) — online donate forms typically include an attestation: "I am a U.S. citizen or lawfully admitted permanent resident". Required when the committee can't verify domestically (e.g. credit cards from foreign-issued cards trigger the check).
• Federal-contractor + Hatch-Act notice— text like "Federal contractors and federal employees are prohibited from contributing" is the operational disclaimer most committees add to cover both populations in one line.
• Personal-funds attribution (11 CFR §110.10) — a candidate is free to spend their own money on their campaign without limit, but the spend must be reported as a loan or contribution from the candidate, not solicited as an outside contribution.
• Best-efforts language (11 CFR §104.7(b)(1)) — the solicitation must include a clear request for the donor's name, mailing address, employer, and occupation. This is the text everyone copy-pastes: "Federal law requires us to use our best efforts to collect and report the name, mailing address, occupation, and name of employer of individuals whose contributions exceed $200 in a calendar year."
• Joint fundraising disclosure (11 CFR §102.17(c)(2)) — JFC solicitations must list every participating committee AND the formula by which contributions get split. Surprising the donor with a different allocation than the solicitation stated is the violation.
• No using another candidate's name without authorization (11 CFR §102.14) — committee names + solicitation copy can't use a federal candidate's name in a way that suggests endorsement unless the candidate has authorized it. PACs frequently get this wrong: a PAC named "Senator X Strong Republicans" implies Senator X's authorization without it.
• Electioneering communication thresholds (11 CFR §104.20) — broadcast / cable / satellite communications referring to a clearly identified federal candidate within 60 days of a general or 30 days of a primary, aggregating $10k+ in a calendar year, trigger Form 9 disclosure within 24 hours of distribution AND require a heavier disclaimer.
• Independent-expenditure disclaimers — IE communications must additionally state the spender is notcoordinating with any candidate. The spending committee's name + the "not authorized by any candidate or candidate's committee" tag together satisfy this.
• Don't imply the IRS is sending it— using government seals, agency names, or anything that suggests an official-government source in a fundraising ask is per se deceptive under FTC Act §5 AND specifically called out in campaign-finance contexts under various state "misleading communication" statutes (e.g. NY Elec. Law §14-126(4) and CA Gov. Code §84305).

Other state-specific quirks worth flagging

• California (FPPC Form 497)— "late" contributions of $1,000 or more received in the 90 days before an election must be reported within 24 hours.
• Florida (Fla. Stat. §106.0703) — contributions of $10,000+ within the 5 days before any primary or general election trigger a 24-hour report to the state.
• Connecticut— Citizens' Election Program candidates face additional caps and qualifying-grant rules beyond the standard limit table.
• Texas judicial candidates — separate cap regime under Tex. Elec. Code §253.155 distinct from the legislative/statewide table on /limits.
• Hawaii — 4-year cycles for governor + lt. governor; per-cycle limits, not per-election.
• Maine + Connecticut clean-election programs — participating candidates accept stricter caps in exchange for public matching; non-participants face the standard caps.

Personal use of campaign funds

The most frequently violated rule in the entire system. Campaign funds can only be used for bona fide campaign or officeholder expenses (11 CFR §113.1(g)). The bright-line test: would this expense exist irrespective ofthe campaign or officeholder duties? If yes — it's personal use and the candidate must reimburse the committee. Per-se personal-use categories listed in §113.1(g)(1):

• Home mortgage, rent, utilities at the candidate's personal residence
• Clothing (other than "de minimis" campaign-logo wear)
• Tuition payments
• Dues, fees, or gratuities at a country club / health club / gym
• Vacations
• Admission to entertainment events (not connected to the campaign)
• Health-club / fitness expenses
• Salary payments to family members in excess of bona-fide-services value

Vehicles, mobile phones, and meals are case-by-case. The pattern that gets investigated: a candidate's campaign committee buys a $90k SUV, the candidate drives it personally on weekends → §113.1(g)(1)(i)(B) prohibits unless the personal use is "de minimis".

Recordkeeping — the 3-year rule

Every receipt, contribution-card, bank statement, vendor invoice, and disbursement record must be retained at least 3 yearsafter the report it's cited on (11 CFR §104.14(b)). For ongoing committees, the rolling-3-year window means most treasurers retain indefinitely. The practical bar: a treasurer getting an FEC audit notice 30 months after a cycle must be able to produce every donor card + bank statement.

Affiliated PAC aggregation

Two or more PACs established, financed, maintained, or controlled by the same corporation, labor org, person, or group are affiliated under 11 CFR §100.5(g) and §110.3. Affiliated PACs share one contribution limit — a donor giving the max to one of them has hit the cap for the entire affiliated group. Bright-line affiliated cases: parent corporation + subsidiary SSF, national + state party committees of the same party, multiple PACs sharing officers or office space. pac.dog's limit engine ties them via affiliated_group_id on limit_rules so the consumption math is automatic.

Terminating a committee

A committee that's wound down (paid all debts, distributed remaining cash) files a Termination Report(a final Form 3 / 3X with the "termination" box checked) per 11 CFR §102.3. Remaining cash options: refund pro-rata to donors, donate to a 501(c)(3), transfer to a party committee (caps apply), or contribute to other candidates (caps apply). Personal use of the wind-down cash is the same per-se prohibition as during active operation.

Audits + the enforcement ladder

• Random + threshold audits— committees with $1M+ in receipts/disbursements get systematically selected for audit by the FEC's Reports Analysis Division. Audits cover the prior 2-year cycle.
• Internal Review Letters (RFAI) — the lightest-touch enforcement; FEC analyst sends a letter asking for a clarification or amendment to a filing. Most issues resolve here.
• Alternative Dispute Resolution (ADR) — for violations that admit a clear factual basis, the committee can negotiate a penalty with the FEC outside a full enforcement proceeding. Faster + smaller penalties than MURs.
• Matter Under Review (MUR) — formal enforcement after a sworn complaint or internal referral. Can take 2-3 years; penalties scale with severity (typical range $5k - $200k for committee-level civil penalties; criminal referral for knowing/willful violations).
• Knowing-and-willful threshold— civil penalties become criminal at the "knowing and willful" mental-state bar (52 USC §30109(d)). Up to 5 years prison + $250k per count for individuals. Aggregate-over-$25k threshold for felony level.

Reporting period cutoff vs filing deadline

Two different dates on every FEC filing: coverage period (e.g. Q1 = Jan 1 - Mar 31) and filing due date (Q1 = April 15). Receipts + disbursements dated within the coverage period show up on thatfiling regardless of when the committee actually deposited or paid them. Late-coverage activity bleeds into the next period's report. The most common reporting error treasurers make is putting an item on the wrong report because they keyed off the deposit date rather than the contribution date.

"Soft money" — federal vs non-federal split

Funds that don't comply with federal source + amount limits are non-federal funds (the artist formerly known as soft money). BCRA banned national party committees from raising or spending non-federal funds; state + local party committees can still raise non-federal funds for state activity but must use a federal account (subject to FECA limits) for any activity that affects a federal election, and the two accounts pay for shared activity per a published allocation ratio under 11 CFR §106.7. Mixing the accounts is the violation. The schema column committees.jurisdiction on pac.dog flags federal-account committees; state-account counterparts are a separate row with the same parent.

Independent-expenditure reporting windows

• 48-hour window (11 CFR §109.10(c)) — IEs that aggregate over $10,000 in a calendar year, outside the 20-day pre-election window, trigger a Form 24 report within 48 hours. Each new $10k threshold (e.g. $10k, $20k, $30k …) re-triggers.
• 24-hour window (11 CFR §109.10(d)) — within 20 days of an election, the threshold drops to $1,000 and the deadline tightens to 24 hours. Most super-PAC enforcement actions cite blown 24-hour windows in the final 3 weeks of a cycle.

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