Author: Benjamin Katz

What is a Non-Committee Filer?

Individuals, groups, corporations, and labor organizations that are not registered as political committees are sometimes subject to filing requirements. These are called non-committee filers.

How do I set up my ISP account for a Non-Committee Filer?

1. In the filer’s Organization record, set the Organization Type to Other.
2. Navigate to Reports, and then Compliance. At the bottom of the page, click on Related Pages, then Manage Filers. 
3. Add your organization as a filer and enter the Filer ID. Or, if it’s already indicated as your filer, ensure the Filer ID is there.

The NC Form 2210A/B/C is for Committees not registered in North Carolina (such as a Federal PAC, or Individual) that makes Independent Expenditures (IEs) for Candidates or Ballot Issues in North Carolina.

There are three forms associated with the Form 2210:

Form 2210-A (Cover Page)

The information on this page is populated based on the information associated with the Filer Record.

• If the filer is an individual, the Individual box will check under Entity Type
• If the filer is a business, type Non-Profit, the Nonprofit Organization box will check
• Otherwise, the Other Organization box will check

Custodian of Records information will pull from the entity linked as Recordkeeper/Recordkeeper Of relationship to the Filer Entity Record.

If the Paper Only box is checked, the Date Filed field on the Cover Page will not populate.

Versions:

• Standard: itemizes ALL contributions, expenses and IEs if more than $100 in aggregate in the period
• 48 Hour Report: itemizes contributions of more than $1000 in aggregate in the period and IEs if more than $5000 in aggregate in the period

Form 2210-B (Donations for Independent Expenditures)

Transaction Type: Monetary Contribution

Form 2210-C (Incurred Costs for Independent Expenditures)

Transaction Types: Expense (on the Standard version of the report), Support/Oppose Memo with either tag IE to Support or IE to Oppose associated with either an Expense or Accrued Expense Payment (on all versions of the report)

Please ensure transactions intended to be Independent Expenditures have a Support/Oppose Memo to the appropriate Candidate or Ballot Issue (rather than the Candidate or Ballot Committee)

There are two versions of the report:

• 48 Hour Report: This version must be filed before an election but after the period covered by the last report due before that election.
  This version:
  • itemizes contributions of more than $1000 in aggregate in the period
  • itemizes expenses and/or IEs if more than $5000 in aggregate in the period
• Standard: This version must be filed on the same schedule as political committees until the end of the election.
  This version:
  • itemizes ALL contributions
  • itemizes expenses and/or IEs if more than $100 in aggregate in the period

You must email the downloaded .csb file to: Campaign.Reporting@ncsbe.gov

48 Hour Reports may be filed via fax or email to the relevant non-State Board

48 Hour Reports filing with the State Board of Elections may be sent by fax to:
(919) 715-0135
or email to:
Campaign.Reporting@ncsbe.gov

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:

1. 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
2. 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:

1. Create the inkind contribution from the related organization, ensuring to add tag: For Independent Expenditure
2. Create an Non-Monetary Expense to the same related organization. At the top of the expense, be sure to check the IsMemo box
3. 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.

How do I e-file with California?

In order to E-file campaign finance reports with California, there are a few one-time administrative steps that need to be taken. Let us help you file California campaign finance reports within ISP.

To begin with, your committee must file a Form 410. Form 410 is the Statement of Organization, which is the document by which a committee is formed and recognized by the State of California.

Your Form 410 is filed with the California Secretary of State (and any applicable local jurisdictions in cases where filing is to a City or County) either on paper or by digitally signed PDF sent by email to the following contact information:

All Committees:

• Form 410 with original ink signature(s)

  Secretary of State
  Political Reform Division
  1500 11th Street, Rm 495
  Sacramento, CA 95814

• Form 410 with digital signature(s)

  Secretary of State via email at: digitalfiling@sos.ca.gov
  As a PDF attachment
  Must contain a verified digital signature on the Signature Line.

Please access the Secretary of State’s website for detailed instructions on how to submit the Form 410 with a digital signature.

County & City Committees: You will also need to file a copy of your Form 410 with the local filing officer who will receive the original campaign statements.

Receiving your Efiling credentials

Once you have submitted your Form 410 to the Secretary of State (SOS), you will receive a Welcome Letter.  State Committees who submit their Form 410 with e-signature receive the Welcome Letter, including the e-filing password, along with the Committee ID.

To find your committee ID number before you receive a Welcome Letter, visit the SOS website or enter your committee’s name in the Cal-Access database search bar.

Committees who do not receive a welcome letter may fill out this form and return it to the SOS.  The Secretary of State will return your password via email.

California E-filing ID and Password Issues

If you receive an ID or password error when Efiling, you may need to confirm that you have the correct credentials, or reset them.  Unfortunately, ISP staff do not have access to CA passwords, and California’s website doesn’t have a quick and easy “Forgot Password” feature to retrieve or reset passwords.

If you are having difficulty with your e-filing login information, please contact the Secretary of State directly for support:

* Email passwordrequest@sos.ca.gov
* Call the Cal-Online Help Desk 877-745-3453 or 916-653-7283
* Cal-Online’s Helpful Tips for Getting Started

The Denver Campaign Finance Report is a simple eFiling-only report for Expenditures and
Contributions for Ballot Measures to be used with the SearchLight
portal.

A PDF will not generate when this report is run.

To file your report, you must generate and download your efile to upload to your filing account.

If you’re transferring money from one of your committees to another, it’s important to enter the data correctly for compliance reporting.

For this example, let’s say you’re transferring money from John for City Council 2024 to John for City Council 2028. In the 2024 account, you’d enter an expense to the 2028 committee. In the 2028 account, you’d enter a monetary contribution from the 2024 committee. This contribution needs to have splits to the individual donors that make up the transfer. The splits count toward the amount that the contributors may give to the committee receiving the transfer.

To import those splits, use the Transfer of Contributions Quick Import format. This format allows you to select the entity you’re transferring from and import all the splits at once.

As long as the two committees are linked in the Relationships section, the Reporting Code TSF will pull on the CA 460.

Note – this scenario is not applicable for internal transfers between bank accounts underneath the same filer. For more info on internal transfers, click here.

There are two ways a transaction can be locked: if it’s included in a bank reconciliation or if it’s included in a compliance report. Both of these will require you to unlock the transaction to edit it.

Attempting to add a transaction that is before the end date of the most recent periodic compliance report will generate a warning. This is on a per-filer basis. Attempting to add a transaction that is before the end date of the most recent reconciliation will generate a warning. This is on a per-financial account basis.

Our AI-Assisted Quick Import format is the most simple of our format options. You attach your file and let AI do its magic. However, that magic requires that the AI be able to easily identify the different columns in your file. In order to use this format, you may have to edit your file a bit to make sure AI knows exactly what it should import. Here are some examples of changes you may need to make:

• If you’re importing both individuals and organizations, have a column that clearly identifies Entity Type.
• If you’re importing transactions, have a column for each of the required fields when adding a transaction: Transaction Type, Date, Amount, Financial Account, Election, and Budget Category.