On rare occasions, a PAC may make an inkind contribution in the form of Independent Expenditure. For example, Labor Union #1234 made calls to voters on behalf of the related PAC, People for a Better Town. These calls were to oppose Jane Doe for Dog Catcher. The calls were considered an Independent Expenditure (IE), and the donated staff time is considered an inkind contribution.
However, there are a few factors to consider:
- On the FEC Report, inkind contributions are typically reported as cash-impact on both Schedule A and Schedule B. This insures no overall impact to the committee’s cash on hand
- In this instance, the IE needs to be reported as a memo, as the filer did not spend any money. That means the corresponding inkind contribution must also be reported as a memo so that cash on hand is correct
To ensure proper reporting, there is some specific data entry:
- Create the inkind contribution from the related organization, ensuring to add tag: For Independent Expenditure
- Create an Non-Monetary Expense to the same related organization. At the top of the expense, be sure to check the IsMemo box
- On the Non-Monetary Expense, add Support/Oppose Memos to the Candidates or Ballot Measures that the IE was made for. Ensure the S/O Memos have either tag: IE to Support or IE to Oppose
Doing this will ensure:
- The inkind contribution pulls to Schedule A as a Memo
- The inkind contribution WILL NOT pull to Schedule B
- The IE is properly reported on Schedule E with no cash impact
Please remember, this scenario is quite rare; you should only enter transactions in this way if your related organization, legal counsel or FEC analyst instructed you to do so.