Before a federal campaign can accept a contribution or spend a dollar, it needs a dedicated bank account at a federally insured institution, registered with the Federal Election Commission in the committee’s name. The campaign bank account requirements are straightforward on their face: qualifying depository, correct account name, treasurer in place, and disclosure on FEC Form 1 within 10 days. The details are where committees get tripped up.
Which Banks and Credit Unions Qualify
Federal rules require every political committee to designate at least one financial institution as its campaign depository. The qualifying types are state-chartered banks, federally chartered depository institutions such as national banks, and any depository whose accounts are insured by the FDIC or the National Credit Union Administration.1eCFR. 11 CFR 103.2 – Depositories What matters is federal deposit insurance, not the charter type.
Credit unions cause the most confusion. NCUA-insured credit unions qualify because the insurance is backed by the full faith and credit of the United States, and you can confirm status through the NCUA’s Credit Union Locator.2National Credit Union Administration. Share Insurance Coverage Some state-chartered credit unions carry only private insurance. Those do not meet the requirement.
The depository does not have to sit in the same state as the election. A candidate running in Ohio can use a federally insured bank in Virginia. Most stick with a local branch for convenience, but the geography is not regulated.1eCFR. 11 CFR 103.2 – Depositories
Get an EIN First
Banks will not open the account without a taxpayer identification number, and the number must belong to the committee, not the candidate. Committees obtain an Employer Identification Number online through the IRS or by submitting IRS Form SS-4, which classifies the entity as a political organization.3Federal Election Commission. Getting a Tax ID and Bank Account The online route usually produces the number the same day.
The account must be opened under the committee’s exact legal name, and federal law requires that name to include the candidate’s name.4Office of the Law Revision Counsel. 52 USC 30102 – Organization of Political Committees “Smith for Congress” works. “Citizens for Better Government,” with no candidate name, does not.
Putting In the First Money
Most candidates seed the account with personal funds. How that money is characterized matters. Personal funds contributed outright count as a candidate contribution, with no dollar limit but full reporting. If the candidate wants the money back later, it needs to be structured as a loan from the candidate to the committee.5Federal Election Commission. Using the Personal Funds of the Candidate Any campaign expense the candidate pays out of pocket before the account exists, such as a filing fee or website invoice, is reported as an in-kind contribution from the candidate.
When the source is a joint account with a spouse, the candidate’s share is presumed to be half unless a different ownership split is documented.6Federal Election Commission. Using the Personal Funds of the Candidate
Registering the Account With the FEC
Once the account is open, the committee files a Statement of Organization, FEC Form 1. A principal campaign committee must file within 10 days after the candidate designates it on the Statement of Candidacy (Form 2). Other political committees face the same 10-day window, triggered when they cross $1,000 in contributions or expenditures during a calendar year.7Federal Election Commission. Instructions for Statement of Organization (FEC Form 1)
Line 9 of Form 1 is where you list every bank, repository, or depository holding committee funds, including the institution’s name and mailing address. The form also names the treasurer and gives the committee’s contact details. Any later change, including a new bank, must be reported on an amended Form 1 within 10 days.8Federal Election Commission. Filing Amendments
You Need a Treasurer Before You Touch the Account
Every political committee must have a treasurer, and the statute is blunt about a vacancy: no contribution can be accepted and no expenditure can be made while the position is empty.4Office of the Law Revision Counsel. 52 USC 30102 – Organization of Political Committees A campaign without a treasurer is legally frozen, which makes replacing one the most time-sensitive personnel decision the committee will make.
The treasurer keeps records of all contributions, including the name and address of anyone giving more than $50, and full identification for anyone whose contributions exceed $200 in a calendar year. Every disbursement is logged with date, amount, payee, and purpose. Receipts, invoices, or canceled checks are required for any disbursement above $200, and all records must be preserved for three years after the related report is filed.4Office of the Law Revision Counsel. 52 USC 30102 – Organization of Political Committees
No expenditure can move without the treasurer’s authorization or that of a designated agent. The statute recognizes a “best efforts” standard: if the treasurer can show a genuine effort to obtain and maintain required information, the records are considered compliant even when some details are missing.
The 10-Day Deposit Rule
All receipts must be deposited into a designated campaign depository within 10 days of the treasurer’s receipt. The only alternative is returning the contribution to the donor within that same window.9eCFR. 11 CFR 103.3 – Deposit of Receipts and Disbursements Holding a check for two weeks violates the rule even if the money eventually clears.
Online fundraising platforms like ActBlue and WinRed change the timing. Contributions sitting in a payment processor’s merchant account in the ordinary course of business are not yet receipts of the committee, so the 10-day clock does not start until the processor forwards the funds. Once the money arrives, though, it needs to move into the depository promptly.
Petty Cash Cap
Committees can keep a petty cash fund for small expenses, but no single payment from petty cash to any one person for any one purchase or transaction may exceed $100.10Federal Election Commission. Making Disbursements Anything above that threshold has to go through the bank account as a check, draft, or electronic transfer drawn on the designated depository. Cash disbursements still need a written record with date, amount, payee name and address, and a specific purpose. “Miscellaneous” is not a purpose. “Parking” or “office supplies” is.
Secondary Accounts, CDs, and Investments
Committees can designate more than one depository and often park surplus funds in a savings account or certificate of deposit. Money can move out of the primary account for investment, but the rule sets one firm limit: the funds must return to a designated depository before the committee spends them on anything.9eCFR. 11 CFR 103.3 – Deposit of Receipts and Disbursements You cannot pay a vendor directly from an investment account.
The regulations do not spell out an approved investment list. CDs and savings accounts are the usual choice because they are simple and federally insured, and the FEC has approved holding bitcoin for investment purposes through advisory opinions.11Federal Election Commission. Investment Income
Interest and dividends earned on committee funds are not treated as contributions and do not count against any donor’s limit. But if a committee earns interest from a bank, that bank has to be listed on Form 1. A CD opened at a different institution than the primary checking account is itself a designated depository and must be disclosed. Missing that disclosure is one of the more common compliance slips.
What the Account Cannot Pay For
Campaign funds cannot cover anything the candidate would need to pay for regardless of running for office. The FEC calls this the “irrespective test”: if the expense would exist without the candidacy, it is personal use and it is prohibited.12Federal Election Commission. Personal Use of Campaign Funds
Categories always treated as personal use include:
- Mortgage, rent, or utility payments for the candidate’s personal residence or family-owned property
- Groceries and household supplies
- Clothing, beyond low-cost campaign items like T-shirts or hats
- Tuition, unless the courses train campaign staff
- Sporting events, concerts, country club dues, and health club memberships, unless tied to a specific campaign or fundraising event
- Salary payments to a relative, unless that person provides genuine services at fair market value
- Vacations and personal travel unrelated to the campaign or officeholder duties
- Funeral expenses, except in limited circumstances involving a death during campaign activity
Legal fees, meals, and mixed-use travel fall into a case-by-case zone. When a trip mixes personal and campaign activity, the personal share must be reimbursed to the committee within 30 days.13eCFR. 11 CFR Part 113 – Permitted and Prohibited Uses of Campaign Accounts
Switching Banks
If the committee changes depositories, whether because of a move, better terms, or a bank merger, it files an amended Statement of Organization within 10 days. The FEC explicitly lists a change of campaign depository as the kind of update that triggers the amendment. The same deadline applies to other Form 1 changes: new treasurer, new address, new email.8Federal Election Commission. Filing Amendments
What Noncompliance Costs
Civil penalties for general campaign finance violations can reach the greater of $5,000 or the amount involved in the violation. If the FEC finds the violation was knowing and willful, the ceiling rises to the greater of $10,000 or 200 percent of the amount involved.14Office of the Law Revision Counsel. 52 USC 30109 – Enforcement
Criminal penalties apply to knowing and willful violations involving contributions, donations, or expenditures. Violations totaling $25,000 or more in a calendar year carry fines and up to five years in prison; violations between $2,000 and $25,000 carry up to one year. Filing false information with the FEC can also draw prosecution under the federal false statements statute, which carries up to five years on its own.15Office of the Law Revision Counsel. 18 USC 1001 – Statements or Entries Generally
Most committees encounter the FEC’s Administrative Fine Program instead of the higher tiers. That program uses a formula tied to the amount of financial activity, how late a report is, and whether the committee has prior violations. Late or missing reports are where the average campaign runs into trouble, not the criminal statute.