When a filer receives a contribution via an intermediary, typically called a conduit or earmark, there are associated disclosure requirements, specifically when it comes to disclosing the intermediary information. You may see Conduit Memos disclosed in various manners, but the way we disclose Conduit memos has been verified by the FEC.
- For each itemized contribution via Conduit, we disclose a Conduit Memo.
This is according to the Campaign Finance Law 110.6 Earmarked contributions 52 U.S.C. 30116(a)(8)), specifically, Section C2c: The information required under 11 CFR 104.3(a) (3) and (4) for each earmarked contribution which in the aggregate exceeds $200 in any election cycle. - The Amount on the Conduit Memo is the amount of the transfer.
This amount is the whole/parent amount of the individual contribution. Again, this is according to the Campaign Finance Law 110.6 Earmarked contributions 52 U.S.C. 30116(a)(8)), specifically, Section C2b: The total amount of earmarked contributions received from the conduit or intermediary and the date of receipt.
- The Date of the Conduit Memo is the date of the transfer.
This is can be found on the FEC’s site on how to report contributions received through conduits. In the example, Mary Smith gave via conduit Mount Vernon Association PAC. Mount Vernon Association PAC is the conduit and is reported as a memo item supporting Mary Smith’s contribution. The Date of Receipt will be the date the conduit gave the contribution to the committee. This date may be later than the date disclosed with Mary’s information. - The Election of the Conduit Memo is the election of the itemized contribution
A conduit memo can be a mix of different elections. However, this is not supported on the FEC report; a single election must be specified. As we are providing a memo for each itemized donation, it is cleanest have the election of the conduit memo match the associated itemized contribution. This model has been consistently accepted by FEC analysts.
