Citizens may contribute no more than US$30,400 annually to a national party committee.

References: Federal Election Commission website for contribution limits for 2009-2010 [ LINK ]

In law, with the passage of the Bipartisan Campaign Reform Act in 2002, parties can no longer raise "soft money" from corporations, labor unions and wealthy individuals, and the limited amount of hard money that they can raise comes from individuals and political action committees, not from corporate donations.

References: TITLE 2. THE CONGRESS, Chapter 14 Federal Election Campaigns Subchapter 1Disclosure of Federal Campaign Funds, § 441b

Bi-partisan Campaign Reform Act of 2002 [ LINK ]

Interview with Sheila Krumholz and Jihan Andoni, Center for Responsive Politics, Nov. 13, 2009

Peer Review Comments: The Citizens United v. FEC Supreme Court decision in January 2010, which happened after the study period of this dataset, will almost certainly overturn this law.

References: TITLE 2. THE CONGRESS, Chapter 14, Federal Election Campaigns , Subchapter 1, Disclosure of Federal Campaign Funds

References: The FEC and state election offices require financial disclosure of campaign contributions.

References: The campaign finance law permits the Commission to conduct an audit of any political committee. The Commission generally conducts such audits when a committee appears not to have met the threshold requirements for substantial compliance. [2 U.S.C. §438(b)] The audit determines whether the committee complied with the limitations, prohibitions and disclosure requirements of the Federal Election Campaign Act. In addition, the Commission is required by law to audit presidential campaigns and convention committees that accept public funds. See [ LINK ]

References: The Federal Election Commission [ LINK ]

References: Contribution limits are published on the Federal Election Commission website: [ LINK ]

Peer Review Comments: Contributions to nominally independent interest groups created to support a candidate (by destroying their opposition) are not limited by the FEC. It's a significant loophole that funds a great deal of campaign advertising.

References: TITLE 2. THE CONGRESS, Chapter 14 Federal Election Campaigns Subchapter 1, Disclosure of Federal Campaign Funds, § 441b

Bipartisan Campaign Reform Act of 2002 [ LINK ]

Interview with Sheila Krumholz and Jihan Andoni, Center for Responsive Politics, Nov. 13, 2009

Peer Review Comments: The Citizens United v. FEC ruling will likely soon change this by allowing corporate and union "soft" money back into the process.

References: FEC website describes how citizens can access these documents -- [ LINK ]

References: The campaign finance law permits the Commission to conduct an audit of any political committee. The Commission generally conducts such audits when a committee appears not to have met the threshold requirements for substantial compliance. [2 U.S.C. §438(b)] The audit determines whether the committee complied with the limitations, prohibitions and disclosure requirements of the Federal Election Campaign Act. In addition, the Commission is required by law to audit presidential campaigns and convention committees that accept public funds. See [ LINK ]

References: The Federal Election Committee [ LINK ]

One potential loophole, according to the Center for Responsive Politics, is the role of minors. "BCRA (the Bipartisan Campaign Reform Act) did not cap contributions at any particular age, so minors may still give contributions. What's evident in the data is that there's a great likelihood that many if not most of those donations are proxy donations for their parents. So when a five-year-old or a seven-year-old is giving US$1,000 or US$2,400 in a single contribution, it's safe to say they're not giving willfully or knowingly of their own funds. They may be giving of their own funds, but the money has been provided by their parents and they may not necessarily be aware that a contribution has been made in their name. Which, if it were proven, would be illegal. So there is still this loophole provided for in the system. FCC would have to prove that, and if proven, slap penalties (fines, some imprisonment). But very few cases where the FCC has ruled against contribution from minor. FCC however has approved 14-year-olds and there's no base age from which individuals can begin to give political contributions. It's amorphous. It's whenever a complaint is made, then they'll investigate."

References: Center for Responsive Politics, Political Parties Overview, Open Secrets, 2009 [ LINK ]

Interview with Sheila Krumholz and Jihan Andoni, Center for Responsive Politics, Nov. 13, 2009

Peer Review Comments: The ban on soft money has limited disclosed donations to political parties, but has also pushed corporate money into organizations that are clearly political, but less transparent (to the public -- we can assume that candidates and party bosses understand exactly where the money originates).

Most notable of these are the "527" nonprofits. While these groups are nominally independent of the parties and candidates, in practice they are nearly always run by partisan operatives in support of one party or candidate.

For example, American Solutions for Winning the Future is a leading 527 that opposes climate-change legislation. It is led by Newt Gingrich, former Republican Speaker of the House, and directly supports the Republican position on climate legislation. The group raised $22 million in the 2008 cycle, and its largest donors are energy companies. Corporate donations above $100,000 are routine. [ LINK ]

However, in a supplementary interview, the CRP also warned that "corporations and corporate donors clearly represent a new, potentially serious threat to the campaign contribution limits. If they are now allowed to make unlimited independent expenditures directly from their corporate treasury, that opens up access to huge new pool of players and funds that could have a determinative impact on elections. If a corporation, say a pharmaceutical corporation that wants to unseat a particularly unfriendly member of congress (unfriendly to their interests), they could on their own or banding together with other pharmaceutical industry corporations, drop millions of dollars overnight in the eleventh hour of a campaign and that candidate will likely not be able to respond quickly enough or gather the funds necessary to be able to respond effectively. So it opens up this specter of very different kind of campaign. This has been banned until now. The Citizens United case [Citizens United, a nonprofit corporate group, produced a politically conservative documentary on Hillary Clinton, which under BCRA regulations, fell under "electioneering communication" that unfairly influences federal elections through "big money" from corporations] has pushed the envelope to attack the limits on corporate spending and issue advertising during the 30-60 window, which is now banned post-BCRA. So you cannot mention the name of a candidate in broadcast advertising 30 days before primary, 60 days before an election, without using funds that are disclosed to the federal election commission and limited under the campaign contribution limits. So Citizens United wanted to raise funds anonymously and to be able to raise funds from corporations and use them in this way. So there are a whole host of issues that are on the table that the Supreme Court could turn back. But the greatest concern to the reform community and for candidates is the idea that they might overturn a series of core precedents and Congressional laws including the Tillman Act back in 1907 [which prohibits corporate contributions to federal political candidates], so that's why many people say this really is potentially overturning a hundred years of precedent. But it more recently or more specifically potentially overturn the Austin ruling, which said that corporations may not spend in this way [i.e., states and by extension the federal government are allowed to ban corporations from spending money on political campaigns even if it's not directed at a particular candidate]. And then they're taking on the whole issue of whether corporations are individuals. Right now, the law says they are treated as individuals so they have the right to freedom of speech, but they also said in Austin that there was a compelling interest for the state to ban direct corporate spending in order to protect the system from undue influence or the appearance of corruption. I think there're a lot of moving parts to this debate, but the most shocking development would be if they throw wide the doors on independent expenditures. And it's a concern because corporations have proved themselves willing and able to drop millions of dollars in soft money to the parties. Since that avenue is now closed to them post-BCRA they're looking for all available vehicles to influence policy and legislation, and this would be one way for them to do so; to unseat those in Congress who are unfriendly to their legislative agenda."

Unregulated corporate donations through the backdoor can follow a number of routes. One path is via donations to presidential inaugurations. Presidential inaugurations can receive unlimited corporate donations - for George W. Bush's second inauguration, the corporate donation cap was set at US$250,000 to "avoid the appearance of brazen corporate influence ([ LINK ]). However, the Obama administration set a US$50,000 donation limit and banned corporations - among others - from donating). See [ LINK ].

Corporate donations to party conventions also remains a major campaign financing loophole. For example, in the 2008 Republican National Convention, "nearly 90 percent of the GOP money came from donors who contributed at least US$250,000, with more than 40 percent tapped from just 15 contributors who chipped in over US$1 million." For the Democrats, 72 percent of funds came from contributors who gave up to US$250,000. The majority contributors were from corporations. Because host committees of conventions are seen as non-profit groups, contributors can make unlimited, tax-exempt donations. See [ LINK ]

References: Center for Responsive Politics, Political Parties Overview, Open Secrets, 2009 [ LINK ]

Interview with Sheila Krumholz and Jihan Andoni, Center for Responsive Politics, Nov. 13, 2009

[ LINK ]

[ LINK ]

[ LINK ]

Peer Review Comments: The ban on soft money has limited disclosed donations to political parties, but has also pushed corporate money into organizations that are clearly political, but less transparent (to the public -- we can assume that candidates and party bosses understand exactly where the money originates).

Most notable of these are the "527" nonprofits. While these groups are nominally independent of the parties and candidates, in practice they are nearly always run by partisan operatives in support of one party or candidate.

For example, American Solutions for Winning the Future is a leading 527 that opposes climate-change legislation. It is led by Newt Gingrich, former Republican Speaker of the House, and directly supports the Republican position on climate legislation. The group raised $22 million in the 2008 cycle, and its largest donors are energy companies. Corporate donations above $100,000 are routine. [ LINK ]

Individuals are limited to contributing US$2,300 to presidential candidates for the primary and another US$2,300 for the general election. However, the FEC permits unlimited donations from corporate and union treasuries for the two nominating party conventions, based on the rationale that they are motivated by a desire to promote the convention city and not by political considerations. Common Cause identifies this as a glaring loophole that Congress should close by extending contribution limits to contributions made for party conventions and requiring more timely disclosure of those donations.

Common Cause finds further loopholes in existing campaign finance legislation, regarding the limits on individual contributions. The Bipartisan Campaign Reform Act of 2002 (BCRA) closed a major loophole in campaign finance law by banning unlimited soft money donations to political parties. Before the ban, soft money contributions to both parties reached almost US$500 million during both the 2000 and 2002 election cycles. Yet Common Cause suggests that more work needs to be done in this field: both parties in the 2008 elections sidestepped the restrictions on the amount of money an individual donor can make to a political committee. They set up joint fundraising committees, which allow individual donors to give well in excess of the normal limits because the contributions are divided up among many different committees, such as national and state party committees. Such strategies allowed Senator McCain to appear at fundraisers where individual donors gave as much as US$70,000 to joint fundraising committees.

References: Federal Election Commission website [ LINK ]

Common Cause, Campaign Finance Reform: A New Era Common Cause [ LINK ]

Public Citizen, "White House for Sale" [ LINK ]

In addition to the structural problems related to the bipartisan makeup, the other issue is how they're nominated. The critics say they're party hacks without thinking independently. The more recent criticism is that the FEC is rejecting its regulatory authority and is no longer willing to take up debates and fights. One good sign is that they seem to be focused on rejuvenating their website and making it more accessible and intuitive for average Americans. Like many government agencies, they're concerned about people utilizing their website effectively to meet their mandate, to disclose information, but also to publish it in a way that is logical and intuitive and attractive and engaging for Americans searching for information.

References: Public Citizen Letter to the President, April 30, 2009 [ LINK ]

Interview with Sheila Krumholz and Jihan Andoni, Center for Responsive Politics, Nov. 13, 2009

Peer Review Comments: The commission does not initiate investigations, but instead responds (or doesn't, in most cases) to complaints.

References: Letter to President Obama RE: Deadlock on the Federal Election Commission from Public Citizen, April 30, 2009 [ LINK ]

Peer Review Comments: Consider the case of Rep. Joe Schwarz. The candidate's campaign was found to have broken the law by coordinating with an interest group, and each was fined $2500. In the context of Schwarz's career fundraising total of $2.9 million, the FEC fine is a minor transaction cost. What's more, the entire finding was politically convenient for the Republicans on the FEC. Schwarz was busted by a complaint by the politically heavy Republican interest group Club For Growth, which had already successfully defeated Schwarz in the Republican primary. [ LINK ]

In other cases, without a political motive, the FEC's record is an almost flawless display of inaction. Here are some randomly selected sample reports (ironically entitled "FEC Takes Final Action on Five Cases") from during and after the 2008 election cycle:

1) The Commission found no reason to believe that the Lantern Project violated the Federal Election Campaign Act of 1971. 2) The Commission closed the file and took no further action. 3) The Commission closed the file and took no further action. 4) The Commission closed the file and took no further action. 5) The Commission closed the file. [ LINK ]

Here's another from 2009: 1) The Commission found no reason to believe the respondents violated the Act. 2) The Commission found no reason to believe Haverford Township Democratic Committee violated the Act. 3) In April 2006, the Commission found reason to believe Business Alaska, Inc. violated the Act. 4) The Commission exercised its prosecutorial discretion and dismissed the matter. 5) The Commission exercised its prosecutorial discretion and dismissed the matter. 6) The Commission exercised its prosecutorial discretion and dismissed the matter. [ LINK ]

Another set: 1) In a conciliation agreement, respondents agreed to pay a civil penalty of $99,000. (A settlement! In this case an FEC audit found that a candidate accepted $313,000 in illegal contributions and a variety of other violations. Note the ratio of illegal cash in vs. fines out: the campaign netted $214,000 even after being busted by the FEC auditors.) 2) The Commission found no reason to believe that ... 3) The Commission found no reason to believe that ... 4) The Commission found no reason to believe the law was violated. 5) The Commission found no reason to believe that the respondents violated any provisions of the Act. 6) The Commission found no reason to believe that ... 7) The Commission closed the file. (In this case, an FEC investigation found a failure to make required discloses, but declined to do anything about it!) 8) The Commission found no reason to believe the law was violated. [ LINK ]

More results can be found here: [ LINK ]

Another example of such a report is the Public Issuance of the Audit Report on Dallas County Republican Party, based on an audit of Dallas County Republican Party (DCRP), undertaken by the Audit Division of the Federal Election Commission (the Commission) in accordance with the Federal Election Campaign Act of 1971, as amended (the Act).

References: Federal Election Commission,  Public Issuance of the Audit Report on Dallas County Republican Party, Dec. 1, 2008 [ LINK ]

Federal Election Commission, Public Issuance of the Audit Report on Oregon Republican Party, Dec. 11, 2008 [ LINK ]

Peer Review Comments: The FEC does vet forms and data when submitted. Obvious errors and discrepancies are flagged and fixed. Usually this process is not done as a formal audit. It's typically done as a letter requesting more information or fixes. You'll see those all over the place. They are pretty good at that, all things considered. These are usually bookkeeping problems -- donations that are on the wrong line, information missing, etc.

Audits that find serious violations of the FECA can start investigations by the FEC board (though the partisan board can ignore the audit). Audits that discover more serious wrongdoing (e.g., theft, fraud) are sent to the Justice Department for criminal prosecution.

Source: Interview with Aron Pilhofer, Newsroom Interactive Technologies Editor for the New York Times.

However, according to Common Cause, the incentives to opt into this system have become too weak. In 2004, both of the major parties' nominees opted out of receiving primary matching funds and raised US$500 million before even accepting their nominations. In 2008, big money dominated the elections, with the leading presidential candidates in both parties raising over US$39 million by the end of 2007, 11 months prior to the general election. Common Cause has issued a report with suggestions for campaign finance reform, arguing that the presidential public financing system has fallen out of date and out of favor. Few of the leading presidential candidates in the primaries used the public financing system in the 2008 cycle: during the primary season alone, Obama, Clinton and McCain all opted out of the system, respectively raising more than five times, four times and twice the limit of the current primary public financing system for the primaries. Moreover, candidates relied on large donors (giving US$1,000 or more) for between half and two-thirds of their campaign funds. The timing and levels of funding are critical shortfalls of the existing system, and Common Cause has recently created a six-point "agenda for change" to address this problem.

Another potential loophole, according to the Center for Responsive Politics, is the role of minors. Sheila Krumholz's caveat on regulations governing individual donations to political parties (indicator 22a) also applies to individual political candidates: "BCRA (the Bipartisan Campaign Reform Act) did not cap contributions at any particular age, so minors may still give contributions. What's evident in the data is that there's a great likelihood that many if not most of those donations are proxy donations for their parents. So when a five-year-old or a seven-year-old is giving US$1,000 or US$2,400 in a single contribution, I think it's safe to say they're not giving willfully or knowingly of their own funds. They may be giving of their own funds, but the money has been provided by their parents and they may not necessarily be aware that a contribution has been made in their name. Which, if it were proven, would be illegal. So there is still this loophole provided for in the system. FCC would have to prove that, and if proven, slap penalties (fines, some imprisonment). But very few cases where the FCC has ruled against contribution from minor. FCC however has approved 14-year-olds and there's no base age from which individuals can begin to give political contributions. It's amorphous. It's whenever a complaint is made, then they'll investigate."

Individuals are limited to contributing US$2,300 to presidential candidates for the primary and another US$2,300 for the general election. However, the FEC permits unlimited donations from corporate and union treasuries for the two nominating party conventions, based on the rationale that they are motivated by a desire to promote the convention city and not by political considerations. Common Cause identifies this as a glaring loophole that Congress should close by extending contribution limits to contributions made for party conventions and requiring more timely disclosure of those donations.

Common Cause finds further loopholes in existing campaign finance legislation, regarding the limits on individual contributions. The Bipartisan Campaign Reform Act of 2002 (BCRA) closed a major loophole in campaign finance law by banning unlimited soft money donations to political parties. Before the ban, soft money contributions to both parties reached almost US$500 million during both the 2000 and 2002 election cycles. Yet Common Cause suggests that more work needs to be done in this field: both parties in the 2008 elections sidestepped the restrictions on the amount of money an individual donor can make to a political committee. They set up joint fundraising committees, which allow individual donors to give well in excess of the normal limits because the contributions are divided up among many different committees, such as national and state party committees. Such strategies allowed Senator McCain to appear at fundraisers where individual donors gave as much as US$70,000 to joint fundraising committees.

References: Common Cause,  Presidential Public Financing, [ LINK ]

Common Cause,  Campaign Finance Reform: A New Era - Common Cause Agenda for Change, Common Cause, January 2009 [ LINK ]

Federal Election Commission website [ LINK ]

Center for Responsive Politics, interview with Sheila Krumholz and Jihan Andoni, Nov. 13, 2009

Furthermore, the CRP's caveat on regulations governing corporate donations to political parties (indicator 22b) also applies to individual political candidates. As Sheila Krumholz of the CRP observed: "corporations and corporate donors clearly represent a new, potentially serious threat to the campaign contribution limits. If they are now allowed to make unlimited independent expenditures directly from their corporate treasury, that opens up access to huge new pool of players and funds that could have a determinative impact on elections. If a corporation, say a pharmaceutical corporation that wants to unseat a particularly unfriendly member of congress (unfriendly to their interests), they could on their own or banding together with other pharmaceutical industry corporations, drop millions of dollars overnight in the eleventh hour of a campaign and that candidate will likely not be able to respond quickly enough or gather the funds necessary to be able to respond effectively. So it opens up this specter of very different kind of campaign. This has been banned until now. The Citizens United case has pushed the envelope to attack the limits on corporate spending and issue advertising during the 30-60 window, which is now banned post-BCRA. So you cannot mention the name of a candidate in broadcast advertising 30 days before primary, 60 days before an election, without using funds that are disclosed to the federal election commission and limited under the campaign contribution limits. So Citizens United wanted to raise funds anonymously and to be able to raise funds from corporations and use them in this way. So there are a whole host of issues that are on the table that the Supreme Court could turn back. But the greatest concern to the reform community and for candidates is the idea that they might overturn a series of core precedents and Congressional laws including the Tillman Act back in 1907, so that's why many people say this really is potentially overturning a hundred years of precedent. But it more recently or more specifically potentially overturn the Austin ruling, which said that corporations may not spend in this way. And then they're taking on the whole issue of whether corporations are individuals. Right now, the law says they are treated as individuals so they have the right to freedom of speech, but they also said in Austin that there was a compelling interest for the state to ban direct corporate spending in order to protect the system from undue influence or the appearance of corruption. I think there are a lot of moving parts to this debate, but the most shocking development would be if they throw wide the doors on independent expenditures. And it's a concern because corporations have proved themselves willing and able to drop millions of dollars in soft money to the parties. Since that avenue is now closed to them post-BCRA they're looking for all available vehicles to influence policy and legislation, and this would be one way for them to do so; to unseat those in Congress who are unfriendly to their legislative agenda."

References: Common Cause, National Party Conventions: Lingering Loopholes, Summer 2008 [ LINK ]

Interview with Sheila Krumholz and Jihan Andoni, Center for Responsive Politics, Nov. 13, 2009

The Federal Election Commission (FEC) is the regulatory body established by the Federal Election Campaign Act of 1974 that is responsible for enforcing campaign finance laws. Yet Common Cause argues that rather than provide swift rulings and forcefully police the campaign finance and election landscape, the FEC is a failing agency that is built for gridlock and often held captive by the elected officials that it is meant to police. In sum, Congress has the FEC on a tight leash, preventing it from being an effective watchdog. This is mainly due to:

- Politicization of the FEC: The FEC has direct oversight and regulatory authority over Members of Congress. As a result, Congress and especially party leadership tightly control the nomination process and have historically seated commissioners who are loyal to the party that appoints them.

- Structure of the FEC: the commission has three Democratic appointees and three Republican appointees who vote on official agency actions. A 3-3 tie vote results in no action by the commission, effectively giving each party veto power over any potential FEC enforcement action.

- Limited actual powers relative to other law enforcement agencies: The FEC cannot on its own sanction groups it believes have violated the law. It can only negotiate for a payment of civil penalties by candidates or political groups. If it cannot reach a settlement, then FEC can begin an enforcement action in court by filing a civil lawsuit against the respondent. The commission has the power neither to seek court injunctions to halt illegal activity while it is occurring nor to conduct random audits of campaigns.

Based on these failings, Common Cause recommends that Congress model the FEC after more effective law enforcement agencies headed by a single administrator who is appointed for a fixed term by the President and confirmed by the Senate. The commission must be better insulated from those it regulates; it needs the power to adjudicate and sanction cases independently and to stop illegal activities quickly.

References: Letter to President Obama RE: Deadlock on the Federal Election Commission from Public Citizen, April 30, 2009 [ LINK ]

Common Cause, FEC Reform [ LINK ]

Peer Review Comments: The FEC board rarely pursues candidates unless the crimes are already proved or the candidate is out of favor with their party (i.e., facing a primary challenge).

If the FEC has historically been criticized for being ineffective because of the bipartisan makeup, the other issue is how they are nominated. The critics say they are party hacks without thinking independently. The more recent criticism is that the FEC is rejecting its regulatory authority and is no longer willing to take up debates and fights. One good sign is that they seem to be focused on rejuvenating their website and making it more accessible and intuitive for average Americans. Like many government agencies, they are concerned about people utilizing their website effectively to meet their mandate, to disclose information, but also to publish it in a way that's logical and intuitive and attractive and engaging for Americans searching for information.

References: Letter to President Obama RE: Deadlock on the Federal Election Commission from Public Citizen, April 30, 2009 [ LINK ]

Interview with Sheila Krumholz and Jihan Andoni, Center for Responsive Politics, Nov. 13, 2009

Peer Review Comments: FEC fines, when they do occur, are often a transaction cost subtracted from the millions raised in support of campaigns. The worst-case scenario is having to pay back the illegally raised funds.

References: Federal Election Commission disclosure database [ LINK ]

Peer Review Comments: The FEC does vet forms and data when submitted. Obvious errors and discrepancies are flagged and fixed. Usually this process is not done as a formal audit. It's typically done as a letter requesting more information or fixes. You'll see those all over the place. They are pretty good at that, all things considered. These are usually bookkeeping problems -- donations that are on the wrong line, information missing, etc.

Audits that find serious violations of the FECA can start investigations by the FEC board (though the partisan board can ignore the audit). Audits that discover more serious wrongdoing (e.g., theft, fraud) are sent to the Justice Department for criminal prosecution.

Source: Interview with Aron Pilhofer, Newsroom Interactive Technologies Editor for the New York Times.

According to the FEC Enforcement report, in FY2008 (most recent data available) there were 20 cases involving "substantive" issues around filing requirements and 83 "substantive" cases on the content of reports. These numbers seem to include all campaign financing filers, not just political parties.

References: [ LINK ]

Federal Election Commission Campaign Guide for Political Party Committees (June 2009): [ LINK ]

FEC Selected Enforcement Statistics FY 2003- 2008. [ LINK ]

Peer Review Comments: Late filings of mandatory disclosure are not uncommon. Penalties for late filings are rare.

References: [ LINK ]

Peer Review Comments: The FEC has been publishing data online in bulk since 1979. However, completeness and formatting of FEC data are not ideal.

[ LINK ]

References: [ LINK ]

Federal Election Commission website [ LINK ]

Center for Responsive Politics, Political Parties Overview [ LINK ]

Peer Review Comments: See this discussion on the quality of the FEC's online data: [ LINK ]

References: [ LINK ]

Peer Review Comments: According to Derik Willis, an FEC data expert working at the New York Times, "Electronic filing is still an unwieldy mess that has made for two classes of campaign finance data users: those who have the time and ability to figure out the electronic data and those who cannot."

Aron Pilhofer, also of the New York Times, said "The FEC has been collecting full donor addresses since 2002 for all but Senators and the DSCC (last I checked the NRSC files electronically only DSCC is a holdout) and cannot seem to bother itself to get those data out there except through the extraordinarily complex electronic filing system ... there is a mandate for committees to report names as five discreet data fields, yet it continues to shove them into a single field ... they still have employer/occupation (again, separate data fields) shoved into a single field in the FTP data that is too small to accommodate them."

According to the FEC Enforcement report, in FY2008 (most recent data available) there were 20 cases involving "substantive" issues around filing requirements and 83 "substantive" cases on the content of reports. These numbers seem to include all campaign financing filers, not just individual candidates.

References: [ LINK ]

FEC Selected Enforcement Statistics FY 2003- 2008. [ LINK ]

Peer Review Comments: Late filings are not uncommon. Penalties for late filings are rare.

References: [ LINK ]

References: [ LINK ]

According to the Center for Responsive Politics with respect to publicly available records of the bundling of individual donations: "unfortunately, the disclosure of the 'bundling' [i.e., packaging of small donations from individual contributors as one package to avoid new legal restrictions - see SourceWatch: [ LINK ]] particularly in presidential cycles is wholly inadequate. There is none, it's up to the candidate to decide whether to voluntarily release that information. And often they're credited with releasing that information, but it's incomplete. There is no upper tier. So for instance it's more than US$500,000. Well is it US$500,000 or US$5 million? It's completely voluntarily. Fortunately for Americans, they had two reformers who believed in transparency and disclosure, or at least made that part of their platform in the last cycle, but there's no guarantee going forward that they'll have access to that kind of information. To his credit, George Bush also released his bundling information, but both his and Kerry's were incomplete, as was the last cycle."

References: [ LINK ]

Interview with Sheila Krumholz and Jihan Andoni, Center for Responsive Politics, Nov. 13, 2009

Peer Review Comments: According to Derik Willis, an FEC data expert working at the New York Times, "Electronic filing is still an unwieldy mess that has made for two classes of campaign finance data users: those who have the time and ability to figure out the electronic data and those who cannot."

Aron Pilhofer, also of the New York Times, said "The FEC has been collecting full donor addresses since 2002 for all but Senators and the DSCC (last I checked the NRSC files electronically only DSCC is a holdout) and cannot seem to bother itself to get those data out there except through the extraordinarily complex electronic filing system ... there is a mandate for committees to report names as five discreet data fields, yet it continues to shove them into a single field ... they still have employer/occupation (again, separate data fields) shoved into a single field in the FTP data that is too small to accommodate them."

[ LINK ]