Calculating cycle-to-date numbers for “Schedule A”
contribution entries.
Question: Why are my “Schedule A” cycle-to-date totals not
reflecting refunds made on my FEC report?
We drew from the specific published instructions for Form 3 Schedule A, the Federal Election Commission Campaign Guide, and the underlying FEC regulations
100.12, 104.3, and 104.8. Throughout the
documentation, transactions are classified as receipts and disbursements. A receipt is defined as a transaction where
value (monetary or otherwise) is received by the committee and a disbursement
is defined as a transaction where value (monetary or otherwise) is disbursed or
transmitted by the committee. The
contribution and the contribution refund are reported and treated as two
separate transactions, one as a receipt and the other as a disbursement, on two
separate schedules. Regulation 104.3 classifies contribution refunds as
disbursements. The refunds are reported
as disbursements on Schedule B, and importantly are not reported on Schedule A
as a negative receipt.
From page 89 of the Congressional campaign guide, the
aggregate number reported is the "Aggregate election-cycle-to-date total
of all receipts (within the same category) from the same source." Since the refund is categorized as a
disbursement and not a negative receipt, according to this instruction, it
would not be considered in the aggregate number. We could find no reference in
the documentation which qualify this explicit and precise instruction such that
refunds would be subtracted from the aggregate contribution total.
Please feel free to share this with the FEC if you have further questions.
Thanks,
James Gibson
Trail Blazer Campaign Services, Inc
Last reviewed: 7/09/2012