Including a Notification Letter with the Form 1 - Statement of Organization:
According to the FEC, Political Committees already registered with the FEC must inform their Reports Analysis Division (RAD) analyst(s) their intent to form a separate Non-Contribution Account. If the Political Committee isn’t yet registered with the FEC, they must include the notification letter with their reported Form 1 – Statement of Organization.
The notification letter must include the following:
“Consistent with the stipulated judgment in Carey v. FEC, this committee intends to establish a separate bank account to deposit and withdraw funds raised in unlimited amounts from individuals, corporations, labor organizations, and/or other political committees. The funds maintained in this separate account will not be used to make contributions, whether direct, in-kind, or via coordinated communications, or coordinated expenditures, to federal candidates or committees.”
Clients can include the notification letter language on the FEC Miscellaneous Text section of their Form 1 or submit a Form 99 referencing their Form 1 with the appropriate language.
Non-Contribution Account (Carey Committee) Receipts:
According to the FEC, all receipts deposited to the Non-Contribution Account must be reported on Line 17 – Other Receipts (Form 3X).
When regular contribution receipts are assigned to a Non-Contribution Account fund code (Fund Type “U”), Crimson will automatically assign those receipts to Line SA17 instead of the normal Schedule A lines of Line SA11(a), SA11(b), and SA11(c) as well as include the Memo Text “Non Contribution Account” for those transactions. In-kinds receipts assigned to a Non Contribution Account Fund Code will still automatically create a corresponding expenditure, but they will be assigned to Line SB24.
For questions regarding your Fund Code setup, please email CrimsonSupport@cmdi.com.
Non-Contribution Account (Carey Committee) Disbursements:
According to the FEC, all Independent Expenditures paid from the Non-Contribution Account must be reported on Line SB24 while all other disbursements paid from the Non-Contribution Account must be reported on Line SB29 – Other Disbursements (Form 3X).
Also, itemized disbursements paid from the Non-Contribution Account should be identified by including the language “Non Contribution Account” in the FEC Memo Text and/or FEC Description fields. Please note, if you choose to report this language in the Description field, you must still include the required purpose of the disbursement too.
Crimson does not automatically assign the FEC line number or include the “Non Contribution Account” language for any disbursements paid from the Non-Contribution Account. Clients must select the correct line numbers as well as enter the FEC Memo Text and/or FEC Description themselves within the disbursement records in Crimson.
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