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 debts and accrued expenses, 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.
Continuous Reporting of Outstanding Loans
Text from RFAI
Commission Regulations require the continuous reporting of all outstanding loans. This report omits the loan itemized on your previous report. Please amend your report(s) to indicate the current status of the following loan: the [AMOUNT] loan made by [ENTITY] on [DATE]. (11 CFR ?? 104.3(d) and 104.11)
Background
The Federal Election Commission requires that you report loans when they are first incurred and continue to report them on each periodic report (Form 3, 3X or 3P) through the report disclosing that they are fully paid off or forgiven.
You previously reported a loan but neither reported it on this report nor reported it as paid off/forgiven.
Solution
Managing loans in ISPolitical is straightforward. Simply enter the loan when originally received and then when it’s repaid or forgiven, you enter those transactions. Do NOT delete the original loan when it is repaid/forgiven. For more information about entering these transactions, consult our How Do I Add a Loan Repayment or Forgiveness Help file.
For each incorrectly filed compliance report, you will need to file an amendment. We recommend filing from the oldest first.
Best Practices
To avoid problems such as this one going forward, ISPolitical recommends two key things:
1) Use ISPolitical’s built-in bank reconciliation tool. This will ensure that the reports you’re filing match your actual bank activity.
2) Pay attention to the errors and warnings when generating a report in ISPolitical. You’ll be warned about problems like this so that they can be addressed before filing your report.
Inconsistent Debt Balance Compared to Previous Report
Text from RFAI
Your report discloses a debt owed to [ENTITY NAME] with an outstanding beginning balance of [AMOUNT]. The previous report filed by your committee discloses a closing balance of [DIFFERENT AMOUNT] These amounts should be the same. Please correct this discrepancy and file an amendment to your report(s). (52 U.S.C. ? 30104(b)(8) (formerly 2 U.S.C. ? 434(b)(8)) and 11 CFR ? 104.11)
Background
Federal Election Law requires continuous and detailed reporting of debts, including payment and adjustments such as when a debt is forgiven.
One of your debts has had a balance change without disclosing how it changed.
Solution
In nearly all cases, this would be due to entering a payment or balance reduction after you already filed the report for that period.
Use the changed transaction report to identify the change that was made, confirm that is was accurate, and file amendments for the report with the missing transaction and each report after.
Best Practices
To avoid problems such as this one going forward, ISPolitical recommends three key things:
1) Use ISPolitical’s built-in bank reconciliation tool. This will ensure that the reports you’re filing match your actual bank activity.
2) Pay attention to the errors and warnings when generating a report in ISPolitical. You’ll be warned about problems like this so that they can be addressed before filing your report.
3) Mark your reports as filed. ISPolitical when then automatically warn you if you enter a transaction in a period that you’ve already filed for.
