Author: Benjamin Katz

At ISPolitical, we build in tools to make it as rare as possible to get a Request for Additional Information (RFAI) from the Federal Election Commissions. However, not all RFAIs can be avoided. If you do get one about missing details on your report, review the notes below for what you should do and how you can avoid getting another RFAI in the future.

See our full list of RFAI help files if you get a letter about another issue.

Contribution to Support Federal Candidate Missing Details

Text from RFAI

On Schedule B, you have disclosed disbursements to federal candidate committees. Commission regulations require that these itemized disbursements include the recipient’s full name, complete address, date, amount, state of election, office sought (House, Senate, or President), and district (if applicable). Please amend your report to include the state of election, office sought, and district. (11 CFR ?104.3 (b)(3))

Background

Federal Election law requires that when making a contribution to support a Federal candidate you include detailed information about both the committee and the candidate. You are missing key information about the candidate.

Solution

In most cases, ISP will automatically pull this information from the Federal Election Commission (FEC.)

However, in rare cases, such as newly declared candidates, you will need to manually enter this. If you don’t already have one, enter in a support/oppose memo for the expense, linked to the support candidate. As needed, update the candidate record with all of the required information. Then file an amendment with the needed information included.

Best Practices

Pulling from ISP’s built in database of all declare FEC candidates and committee makes data entry quick and accurate and avoids problems like this.

Additionally, take advantage of ISP’s error and warning system which will alert you to missing required information so it can be corrected before filing.

Missing Address and Purpose on Schedule B

Text from RFAI

On Schedule B supporting [Line Number] of the Detailed Summary Page, you have itemized disbursements for which you have failed to include the address and/or purpose. Please amend your report to include the missing information. (11 CFR ? 104.3(b)(3))

Background

Federal law requires that you include an address and description explaining the
purpose of every expenditure you make that exceeds the reporting
threshold. You have failed to do so for one or more expenses.

Solution

Add an appropriate reporting description that meets the Federal
Election Commissions (FEC) threshold for sufficiency and file an
amendment.

Best Practices

ISP will automatically alert you if your FEC report is missing any
required reporting description as well as if you reporting description
fails to meet the FEC’s standards. It will also alert you for any missing or incomplete addresses. When generating your report, click on
warnings to quickly update this information and avoid future problems
with the FEC.

Missing Purpose on Schedule B

Text from RFAI

On Schedule B supporting [Line Number] of the Detailed Summary Page, you have itemized disbursements for which you have failed to include the purpose. Please amend your report to include the missing information. (11 CFR ? 104.3(b)(3))

Background

Federal law requires that you include a description explaining the purpose of every expenditure you make that exceeds the reporting threshold. You have failed to do so for one or more expenses.

Solution

Add an appropriate reporting description that meets the Federal Election Commissions (FEC) threshold for sufficiency and file an amendment.

Best Practices

ISP will automatically alert you if your FEC report is missing any required reporting description as well as if you reporting description fails to meet the FEC’s standards. When generating your report, click on warnings to quickly update this information and avoid future problems with the FEC.

Must Disclose Identification of Individual Donors

Text from RFAI

Commission Regulations require that a committee discloses the identification of all individuals who contribute in excess of $200 in a calendar year. (11 CFR ? 104.3(a)(4)(i)) Identification for an individual is defined as the full name (initials for first or last name are not acceptable), complete mailing address, occupation, and name of employer. (11 CFR ? 100.12) Your report discloses contributions from individuals for which the identification is not complete.The following employer name and occupation entries appear on your report and are not considered acceptable: [LIST OF PROBLEM ENTRIES] You must provide the missing information, or if you are unable to do so, you must demonstrate that “best efforts” have been used to obtain the information. To establish “best efforts,” you must provide the Commission with a detailed description of your procedures for requesting the information. Establishing “best efforts” is a three-fold process.First, your original solicitation must include a clear and conspicuous request for the contributor information and must inform the contributor of the requirements of federal law for the reporting of such information. (11 CFR ? 104.7(b)(1)) See 11 CFR ? 104.7(b)(1)(B) for examples of acceptable statements regarding the requirements of federal law.Second, if the information is not provided, you must make one follow-up, stand alone effort to obtain this information, regardless of whether the contribution(s) was solicited or not. This effort must occur no later than 30 days after receipt of the contribution and may be in the form of a written request or an oral request documented in writing. (11 CFR ? 104.7(b)(2)) The requests must:? clearly ask for the missing information, without soliciting a contribution, ? inform the contributor of the requirements of federal law for the reporting of such information, and ? if the request is written, include a pre-addressed post card or return envelope.Third, if you receive contributor information after the contribution(s) has been reported, you should either a) file with your next regularly scheduled report, an amended memo Schedule A listing all the contributions for which additional information was received; or b) file on or before your next regularly scheduled reporting date, amendments to the report(s) originally disclosing the contribution(s). (11 CFR ? 104.7(b)(4))Please amend your report to provide the missing information or a detailed description of your procedures for requesting the information. For more information on demonstrating “best efforts,” please refer to the Campaign Guide.

Background

Federal law requires that you disclose the full name of all donors who have given more than $200 in aggregate. This RFAI means you have one or more donors for whom the Federal Election Commission (FEC) believes you have failed to report their full legal name.

Solution

There are rare cases where an individual will have a legal name that does not appear to be a full name (eg “Cher”). If that is the case for your donor, submit a Form 99 explaining the situation.

Alternatively, if you previously failed to report a full name, but now have it, file an amendment report with this information.

Finally, if you have been unable to gather the full name, file a Form 99 explaining the efforts you have made and that you were unable to gather this information.”

Best Practices

Use ISP communication tracking system to keep track of when you’ve requested this additional information so that you can easily provide dates to the FEC and ensure that you’re fully in compliance.

On Schedule B supporting Line 21(b) of the Detailed Summary Page, you have itemized disbursements for which you have failed to include the address.

Text from RFAI

On Schedule B supporting [Line Number] of the Detailed Summary Page, you have itemized disbursements for which you have failed to include the address. Please amend your report to include the missing information. (11 CFR ? 104.3(b)(3))

Background

Federal law requires that you include an address for every expenditure you make that exceeds the reporting
threshold. You have failed to do so for one or more expenses.

Solution

Add the full address(es) and file an
amendment.

Best Practices

ISP will automatically alert you for any
missing or incomplete addresses. When generating your report, click on
warnings to quickly update this information and avoid future problems
with the FEC.

At ISPolitical, we’re always open to integrating with new vendors. If you’re a vendor looking to integrate with us, please take the following steps.

1. Contact us at support@ispolitical.com.
2. We’ll set you up with a sandbox account for testing.
3. We’ll send you all the API information you need.
4. Once the integration is complete, send us a logo, a brief description for our integrations page, and a longer description for our help file. The longer description should include steps for enabling the integration on your side.

Filing California reports can be tricky, especially when it comes to requirements for filing paper or electronic reports, or both. Depending on your agency, this will vary.

To determine your needs, visit the FPPC’s site and locate the report you need to file.

When it comes to reporting Occupation and Employer information on compliance reports, some states require specific formatting or terminology. These states are:

• Colorado
• Delaware
• Georgia
• Indiana
• Maine
• New Hampshire
• New Jersey
• New Mexico

We at ISP feel having a specific set of Occupations and Employers to choose from is not ideal, as there are many different ways to record an Occupation or Employer. Because of this, we have created back-end logic to help bridge the gap between the data we receive and what the agency requires. For example, titles like Attorney at Law will be converted to just Attorney. 

When donors contribute, they sometimes have the option to increase the amount in order to cover processing fees. This is essentially making an additional contribution in the amount of the fees so the recipient of the donation receives the full intended donation amount. For example, if a donor intends to contribute $100 and the processing fee is $5, they can donate $105. This way the recipient gets the full $100. Otherwise, minus the processing fee, the donation amount would be $95.

The data entry for this can vary depending on the conduit and sometimes require further processing expense entries.

Investment income is similar to interest. In order for the transaction to appear correctly on the report, create it as Other Income. Conversely, if the investment is a loss, create it as an Other Income but be sure to click the Is Reversal box.

If you have investment expenses, such as bank fees, these are entered as standard committee expenses.

South Carolina Candidate Campaign Disclosure Review

Candidate Campaign Disclosure Review is required to be submitted to the South Carolina Ethics Filing For Candidates and Public Officials.

The report parameter fields are as follows:

• Date Range: Please ensure that your date range lines up with either standard SC reporting dates or dates that are specific to your report. i.e. Initial Report, Pre-Election, etc.
• Previous General Election Date: Please supply the most recent General (November) Election Date. This is typically used for per-cycle aggregate calculations.
• Report Period: The available report periods will appear in the dropdown.
• All Caps: This will generate your entire report in all caps.

We recommend upon completion of generating your report, that you save it as a PDF for your records or to compare to other reports. This must be done at the time of generation, or you will not be able to save it as a PDF without generating it. You can also download the e-filing for your records as well.

NOTES:

• SC bulk import does not support the concept of memos. Typically states want to see where the money originated/ended up, so we itemize splits as cash-impact transactions, and do not itemize the whole/parent transaction. 
• The Bulk Import is quite limited – only 4 transaction types can be imported. There will be an indication below if the transactions on the schedule need to be hand-entered directly into SC’s system.
• When uploading to SC’s system, the time it takes to complete the upload can be variable due to the size of the report. The larger the file the longer it will take.

Cover Page Totals

Below is a breakdown of each Contribution and Expenditure schedule based on the order found on the Cover Pages. 

Cash Contributions

• Transaction Types: Monetary Contribution, Enforceable Pledge Payment (except from the Filer Candidate)
• REVERSED Transaction Types: Monetary Contribution, Enforceable Pledge Payment (except from the Filer Candidate)

In-Kind Contributions

Please be aware transactions from this schedule must be hand-entered directly into SC’s system.

• Transaction Types: Inkind Contribution
• REVERSED Transaction Types: Inkind Contribution

Debt Setoff Funds

This schedule is not supported. Please contact Support for assistance.

Personal Contributions

Please be aware transactions from this schedule must be hand-entered directly into SC’s system.

• Transaction Types: Monetary Contribution (from the Filer Candidate)
• REVERSED Transaction Types: Monetary Contribution (from the Filer Candidate)

Loans

Please be aware transactions from this schedule must be hand-entered directly into SC’s system.

• Transaction Types: Loan Received

Account Credits

Please be aware transactions from this schedule must be hand-entered directly into SC’s system.

• Transaction Types: Refunded Expense, Other Income
• REVERSED Transaction Types: Refunded Expense, Other Income

Expenditures

• Transaction Types: Expense, Accrued Expense Payment
• REVERSED Transaction Types: Expense, Accrued Expense Payment

Returned Contributions

Please be aware transactions from this schedule must be hand-entered directly into SC’s system.

• Transaction Types: Refunded Contribution
• REVERSED Transaction Types: Refunded Contribution

In-Kind Expenditures

This schedule is not supported. Please contact Support for assistance.

Schedules Not Listed on the Cover Page

Loan Repayments

Please be aware transactions from this schedule must be hand-entered directly into SC’s system.

• Transaction Types: Loan Received

Creating a Word Template

• 1. Navigate to the Tools > Word Templates section in ISP.
• 2. Select Create at the bottom of the page to create a custom Word template.
• 3. Insert merge fields ( e.g., Name, Address, Contact information) wherever you want ISP data to appear. 
• 4. Save Word template.

Generating a Word Document

• 1. Open an entity record.
• 2. Select Quick Communications.
• . Choose Generate Word Document and select your saved template.
• 4. Select Merge Mail
• 5. ISP will automatically fill in the merge fields with the entity’s information.
• 6. The completed Word document will download to the desktop.

Take the following steps to enter an accrued expense of a contribution made to a committee via a conduit organization. 

1. If it doesn’t exist already, create a record for the candidate’s committee.
2. Link the candidate to his/her committee via the Relationships section.
3. Enter the accrued expense.
4. Add a split to the conduit organization.
5. Navigate to the conduit organization’s record and click on the transaction.
6. Add a split to the candidate committee and save.
7. Navigate to the candidate committee record and click on the transaction.
8. Add a Support/Oppose Memo to the candidate and save.