Spring cleaning your Political Action Committee
With a busy federal and state election cycle on the horizon, now is an ideal time to thoroughly review your Political Action Committee (PAC). These checklist items should be a part of your regular PAC maintenance. Keeping track of PAC activities and internal controls can help a PAC remain in good standing with regulators. But if you haven’t asked yourself these questions in a while, now is the time.
Statement of Organization/Designation of Treasurer
- Are your treasurer and deputy treasurer listed correctly?
- Is all contact information still accurate?
- Is your disclosure of affiliated PACs up to date?
- If you are required to keep a copy of your federal Statement of Organization on file with state regulators, is your filing current? (Ohio requires this of any federal PAC that makes contributions to state and local candidates.)
- 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.
- Have you reviewed bank statements for unauthorized transactions?
- Do you know the location of PAC credit/debit cards?
- Do you have a policy of requiring that checks over a certain amount are signed by two people? If not, consider adopting one. If so, is the policy being followed?
- Is your PAC board up to date on PAC activity?
- Have you calendared all filing deadlines and made note of current contribution limits?
- Please see our updated calendar filing deadline chart. Note that the post-primary filing date has changed with the primary election change in House Bill 197.
- Are all contributions promptly deposited into the PAC account?
- Have you reviewed and updated solicitation materials?
- Has your PAC treasurer or designee taken a training course or reviewed guidance materials to remain up-to-date on recent developments and requirements?
- Are your PAC bylaws or other governing documents up to date? Are they being followed?
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.
This is for informational purposes only. It is not intended to be legal advice and does not create or imply an attorney-client relationship.Download PDF