Treasurers will have to pay a lot of attention to keeping accurate and up-to-date contribution records.   PDC recommends that campaigns use the free computer software provided by the PDC that allows easier handling of large volumes of data and automatic calculation of cumulative totals for contributors. 

Determining "Date Received"

"Receipt" of a campaign contribution occurs at the earliest of the following:

  • the date that the candidate, treasurer, deputy treasurer, campaign manager, campaign chairperson or similarly situated campaign official obtains possession of the contribution, 
  • the date that the candidate, treasurer, deputy treasurer, campaign manager, campaign chairperson or similarly situated campaign official is informed of the contribution, or becomes aware that the campaign, or in the case of an earmarked contribution, the intermediary or conduit, has possession of the contribution, or
  • the date that the contribution becomes available for use by the candidate or committee.

An exception is online and credit card contributions, which should be considered received on the date the transfer is initiated from the merchant account to the campaign account.

Bank Deposits

Deposit monetary contributions within five business days of when they are received.  Candidates who select the full reporting option will report each deposit to the PDC.

Required Contributor Information

The contributor's name and address, along with the amount given, and the date the candidate received the contribution must be collected for each contribution received.

Sources of Contributions

Candidates and treasurers who file disclosure reports listing their sources of contributions must often make decisions about whom to show as the contributor.  Contributors have the obligation to inform campaigns of the true and actual source of the donation at the time the contribution is made.  However, in the absence of other information concerning a contribution's true source, follow the interpretations given below when keeping records, identifying your contributors on the C-3 report and when complying with the contribution limits.

One-Party Personal Checks:

List the name printed on the top of the check as the contributor.

Joint Personal Account Checks:

Attribute equal parts of the contribution to each of the names of the parties printed on the check, unless a written explanation to the contrary accompanies the contribution.  (In the case of $100 check drawn on the account of John and Mary Smith, attribute $50 to John and $50 to Mary.  John and Mary each may contribute up to the maximum allowed by an individual.)

Checks Drawn on Sole-Proprietor Business Accounts:

For contribution purposes, the owner of the business and the business entity are considered one and the same.  The proprietor's aggregate contribution total must include donations from his/her personal funds as well as from the business.

Partnership Account Checks:

List the partnership as the contributor, unless the contribution is to be paid from one or more of the partners' capital accounts, in which case the contribution is attributed to the partner or partners whose funds are being used.  Written notice of this arrangement is to accompany the check.

Other Entities:

Show the contribution as coming from the name printed on the check when reporting contributions from corporations, unions, membership organizations, associations, political committees and other organizations

Contributions from Minors:

Contributions by unemancipated children, under eighteen years of age, are considered contributions by their parents and are attributed proportionately to each parent.  In the case of a single custodial parent, the total amount of the contribution is attributed to the parent; otherwise, 50% of the contribution is attributed to each parent.

Contributions from emancipated children, under eighteen years of age, are considered contributions from the child if the decision to contribute is made knowingly and voluntarily by the child, the contribution is from a source owned and controlled exclusively by the child, and the contribution does not result from a gift intended to give the child the wherewithal to contribute.

Contributions of Uncertain Origin:

Do not deposit any contribution, or accept any in-kind contribution, if you know or suspect it has been made in a fictitious name, or by one person through an agent, relative, political committee, or any other person so as to conceal the true source or to exceed the contribution limits.  Return such a contribution within ten calendar days to the source, if known, or endorse the check and make it payable to the State Treasurer.  Send the endorsed check to the PDC, along with an explanation, for deposit in the state's general fund.

Contributions from Individuals

Treasurers will also need to obtain occupation and employer information regarding individuals who give more than $100 in the aggregate contributions.  Include both monetary and in-kind contributions when aggregating a donor's contributions.


Special Tracking Required by Candidates Subject to Limits

A candidate who is subject to limits separately tracks primary and general election contributions.  Since it's likely many donors will not specify or designate a contribution for a certain election, the PDC has approved the following course of action:

  • if a contribution is designated in writing by the contributor for a specific election, the contribution will be attributed to the contributor's limit for that designated election;
  • an undesignated contribution made prior to the date of a primary election shall be attributed to the contributor's limit for the primary election;
  • any portion of an undesignated contribution made prior to the date of the primary that exceeds the contributor's primary limit must be attributed to the contributor's limit for the general election; and
  • an undesignated contribution made after the date of the primary must be attributed to the contributor's limit for the general election.

Also, take care not to spend any general election contributions on the primary election campaign.  Also see Spending General Election Contributions.

Affiliation

Corporate Contributions:

If the corporation is affiliated for contribution limit purposes with another entity, all contributions from both the corporation and the other entity are added together to determine when the limit has been reached.  Corporate subsidiaries share a contribution limit with their parent corporations; however, if the parent company does not participate in an election campaign regarding a candidate, then each subsidiary has its own limit [unless the subsidiaries are themselves affiliated pursuant to the factors set out in WAC 390-16-309(3)].  If the parent organization does not stay out of an election campaign regarding a candidate, then the parent and all of its subsidiaries share one contribution limit.  A corporation always shares a limit with its PAC.  See WAC 390-16-309.

Unions and Other Membership Organizations:

Local units of any organization -- including unions, associations, collective bargaining organizations, trade associations and other membership organizations -- share a contribution limit with the state and federal levels of their organizations.  If neither the federal nor state level participates in an election campaign regarding a candidate, each local unit has its own contribution limit [unless the local units are themselves affiliated pursuant to the factors set out in WAC 390-16-309(3)].  If both the state and federal level do not stay out of an election campaign regarding a candidate, then the federal, state and local units all share one contribution limit.  RCW 42.17A.455.  A union, association, or other membership organization always shares a limit with its PAC.

Political Committees:

A PAC established, financed, maintained or controlled by a corporation, union, association or any other type of entity shares a contribution limit with that entity.  For example, a corporation and its PAC share one limit, as do a union and its PAC.  Further, if a PAC receives all of its funds from one source (whether that source is an individual, an entity, a political committee or any group of persons) and this source exercises exclusive control over how the PAC funds are spent, the source shares a contribution limit with the PAC.  [RCW 42.17A.455(1)]

Contributions from bona fide parties and caucus campaign committees

Contributions from party and caucus committees should not be attributed to either the primary or general election.  These committees have an election cycle limit that controls how much they may give when contributing to candidates subject to limits. 

Legislative District and County Party Committees - Limitations

Local party committees may only contribute to candidates if the candidate is elected by voters from the legislative district or county.  In other words, if a county or district committee represents an area that is not entitled to vote for a candidate, that committee may not contribute to the candidate.  Further, the local party committees share a limit of $.50 per registered voter, if the candidate receiving the contribution is subject to limits.  As with other limits, the candidate's treasurer will have to make sure this joint limit is not exceeded, especially since the committees involved will not necessarily communicate with each other before making contributions