About the FEC Form 48-IE Report

The FEC 48-IE Report is used to report Independent Expenditures in aggregate of more than $10,000 outside of the 20 days before an election. This will report Independent Expenditures made by the committee, and estimated expenses will pull to this report. 

The FEC 48-IE is only filed by political committees. For Non-Committee filers, use the Form 5.

Please note this report, as well as the FEC Form 24-IE and Schedule E on the FEC Form 3x, only disclose IEs made about Federal candidates or committees.

The aggregation calculation is a little different for IEs than other transactions. IEs aggregate on the office and election, rather than the individual candidate. Determining when contributions should pull to a FEC Form 48-IE can be confusing. Here are a few examples to help demonstrate situations that are most common.

Example 1: Your committee pays for two IEs for Sarah Smith for Congress. One is for $7000 for the Primary and one is for $5000 for the General. Even though this is for the same office and the grand total is over $10,000, neither of these would itemize as the per-election totals do not cross the $10,000 amount ($7000 for Primary and $5000 for General).

Example 2: Your committee made an IE to Support Jesus Gonzalez for Senate in the amount of $6500 for the Primary. You also made an IE to Oppose his opponent in the amount of $5000, also for the Primary. Despite these being for different candidates, these would itemize, as the total amount for office and election is more than $10,000.

Example 3: Your filer made an IE in the amount of $7500 for Minh Nguyen for Congress (AZ-4) for the Primary. You also made an IE in the same amount for Anya Patel for Congress (TX-2) for the Primary. These would not itemize because even though they are for the same election, for a congressional race, and the grand total is over $10,000, they are for a different congressional districts.

Furthermore, if you are expecting an IE to pull to a FEC Form 48-IE and it is not, verify the following data entry:

• The Form 48-IE only reports IEs. Check to make sure there is a Support/Oppose Memo on the expense transaction you’re expecting to report. Also ensure there is either an IE to Support or IE to Oppose tag on the Support/Oppose Memo
• The Form 48-IE only reports Federal IEs and, as stated above, matches on office and election. Ensure the Candidate Info is fully filled out: State, Office Sought, District Number, and Jurisdiction is Federal. Double check the election on the Support/Oppose Memos as well.

There are two versions of the 48-IE:

• (FEC Preferred) Static Aggregate: On the Static Aggregate version, the itemization is on a Static Basis (total as of the end of the report) instead of Running Basis (total as of the time of the transaction). This version is different than the Running Aggregate version in that if the aggregate total of IEs for the same office and election is above the threshold, only the transactions that are above the threshold itemize. With the static aggregate, if you generate the report from the first of the year, all transactions that make up the $10,000 itemization threshold amount will itemize, including those below the threshold amount. While this version is preferred by the FEC, it is not required.
• Running Aggregate: On the Running Aggregate version, the itemization is on a Running Basis (as of the date of each transaction) rather than a Static Basis (as of the end of the period). This version is different than the Static Aggregate version in that if the aggregate total of IEs for the same office and election is above the threshold, all transactions itemize for the same office and election, including those below the threshold amount). With the Running Aggregate, even if you generate the report from the first of the year, only the transactions that meet or exceed the $10,000 itemization threshold amount will itemize.
  Despite the Static Aggregate version being preferred by the FEC, this version is acceptable.

For either version, the FEC Form 48-IE resets after each report is filed. This means the aggregation total for itemization goes back to $0 and you don’t have to file another report until an additional $10,000 is spent on the office and election. Ensure after you file a report, you mark the report as filed so the aggregate properly resets.

When generating the 48-IE report, the start date of the report period is a fixed value.  The start date of the report period in the report generator defaults to 01/01/YEAR (where year is the year in which the report is generating).  This is to ensure compliance with FEC guidelines and ensure that all previously unitemized Independent Expenditures are included in the report and accurately itemized.

If you need to file a report due to an Independent Expenditure in aggregate of more than $1,000 within the 20 days before an election, please use the FEC Form 24-IE Report.

There can be situations where the 48-IE and 24-IE reports overlap. Since the same information is reported on both, most use the 24-IE instead of the 48-IE during the 20 days before an election. Please confirm with your FEC analyst if you are not sure which report to use.