How do I track independent expenditures?
Independent expenditures are payments for communications that expressly advocate for or against a clearly identified candidate without coordination with that candidate's campaign. These expenses face specific, often stringent reporting requirements at both federal and state levels. Tracking them accurately in EveryAction helps ensure you meet all disclosure obligations while maintaining appropriate separation from candidate campaigns. Proper documentation of these activities protects your organization and provides transparency in your political spending.
Step 1: Verify your independent expenditure settings
Before tracking independent expenditures, check that your system is properly configured for this specialized reporting. Navigate to the Compliance or Disclosure section and look for "Settings," "Configuration," or a similar option. Within the settings, verify that independent expenditure tracking is enabled and configured according to your jurisdiction's requirements. This might include setting up the appropriate reporting codes, expenditure categories, and attribution statements that will be needed for your filings. If these options aren't available or properly configured, work with your administrator or EveryAction support to set them up before proceeding.
Step 2: Create a new independent expenditure record
Once your settings are configured, return to the main Compliance section and look for "Independent Expenditures" or a similarly named option. Click "Add Independent Expenditure" or "New Record" to begin. Unlike regular disbursements, independent expenditure records require additional specialized fields. Start by entering the basic transaction details: date, amount, vendor information, and payment method. Then select the candidate(s) affected by the expenditure, indicating whether the communication supports or opposes each candidate. Be precise with these designations, as they determine how the expenditure appears on disclosure reports and may affect aggregation calculations for reporting thresholds.
Step 3: Document the communication details
Provide specific information about the independent expenditure communication itself. Select the communication type (such as direct mail, digital advertising, television, etc.) from the available options. Enter the dissemination date—when the communication reached the public—which may differ from the payment date and often triggers reporting deadlines. Upload a copy of the communication content if your system supports attachments, or note where this documentation is stored. Some jurisdictions require specific attribution statements on independent expenditure communications; verify that your materials included the required disclaimers and note this compliance in the appropriate field.
Step 4: Allocate costs for multiple candidates or elections
If your independent expenditure communication mentions multiple candidates or relates to multiple elections, you'll need to allocate the costs appropriately. Look for allocation options in the expenditure form, which typically allow you to split the amount across different candidates and/or election contests. Some jurisdictions have specific formulas for this allocation (such as equal distribution or space/time calculations); follow the relevant requirements for your situation. If the communication also includes issue advocacy not directly related to candidates, you may need to allocate only a portion of the total cost as an independent expenditure. Document your allocation methodology clearly in the notes or description field to support your calculations if questioned.
Step 5: Submit timely reports for independent expenditures
Independent expenditures often trigger special reporting deadlines separate from your regular disclosure schedule, particularly when they exceed certain thresholds or occur close to an election. After recording the expenditure, check whether additional reporting is required. Navigate to the Reports section in the Compliance module and look for independent expenditure-specific report options such as 24-hour reports or 48-hour notices. If required, generate and file these reports promptly to avoid penalties. Remember that these special reports typically don't replace the need to include the same expenditures on your regular disclosure reports; they're additional requirements due to the timing or nature of the spending. Set calendar reminders for relevant deadlines based on your independent expenditure activities to ensure timely compliance.
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