CAMPAIGN FINANCE AND BOOKKEEPING MANUAL

CAMPAIGN
FINANCE
AND
BOOKKEEPING
MANUAL
April 2004

Wisconsin State Elections Board
17 West Main Street, Suite 310
P.O. Box 2973
Madison, WI 53701-2973
Phone:
Fax:
E-mail:
Website:

608-266-8005
608-267-0500




INTRODUCTION
Wisconsin campaign finance law requires candidates for public office to register their intent to
run for office, to disclose their campaign receipts and disbursements, and to abide by certain
contribution limits and prohibitions. To help candidates and their treasurers comply with the
law, the State Elections Board has prepared this campaign finance manual. This manual contains
instructions for completing the registration statement and campaign finance reports, summarizes
the major provisions of the law, and describes a bookkeeping system for campaign committees.
The bookkeeping system presents a simple method to record and save the financial information
necessary for completing the campaign finance reports. It is not required. Any system that a

treasurer uses to keep good records of receipts and disbursements can form the basis for
completing campaign finance reports.
Wisconsin was one of the first states to establish a comprehensive campaign finance reporting
law. The passage of this law in 1974 put Wisconsin at the forefront of open government. The
law recognizes that our democratic system of government can be maintained only if voters are
informed. Registration and financial reports are required of all candidates for state, county, city,
town, village and school district offices and are available for public inspection.
Candidates for local offices can direct questions about campaign finance law or reporting
requirements to their local filing officers. Candidates for state offices can direct questions to the
Campaign Audit staff of the State Elections Board at 608-266-8005.

DISCLAIMER:
This manual is meant as a guide for keeping records and reporting campaign finance activity. It
does not cover every aspect of campaign finance law. Please refer to Chapter 11 of the
Wisconsin State Statutes for campaign finance law specifics. You can view and print this
chapter from the State Elections Board website at .

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CONTENTS
Page
I. REGISTRATION REQUIREMENTS

1

Who is Required to Register
Completing a Registration Statement
Amending a Registration Statement
Penalty for Not Filing a Registration Statement

II. EXEMPTION FROM FILING CAMPAIGN FINANCE REPORTS

3

Eligibility
Financial Records During Exemption
Revoking Exemption
III. CAMPAIGN FINANCE REPORTS

4

Types of Reports
Information Required
Short Form
Special Report of Late Contributions
Computer Generated Campaign Finance Reports
IV. MAJOR PROVISIONS OF WISCONSIN CAMPAIGN FINANCE LAW

8

Contribution Limits
Definition of Campaign Period for the Purpose of Calculating
Contribution Limits
Individual Contribution Limits
Committee Contribution Limits
Cumulative Committee Contribution Limits
Exclusions from Contribution Limits
In-Kind Contributions
Prohibited Contributions
Returned Contributions

Contributions Transferred through Conduits
Loan Guarantees
Joint Fundraisers
V. ATTRIBUTION STATEMENTS ON POLITICAL LITERATURE
(DISCLAIMERS)
Disclaimers
Formats for Disclaimers

ii

12


VI. TERMINATION OF REGISTRATION AND REPORTING
REQUIREMENTS

13

Disposal of Residual Funds
VII. RECOMMENDED BOOKKEEPING SYSTEM

14

SAMPLES OF COMPLETED FORMS
Campaign Registration Statement (EB-1)
Special Report of Late Contribution (EB-3)
Campaign Finance Report (EB-2)

24
26

28

QUICK REFERENCE TOPICS & ADDENDUMS
Non-Candidate Committees
Filing Fees
Independent Expenditures
Reconciling Records
Duplicate Reports
Filing Fee Worksheet
Permissible & Impermissible Expenditures – Party Committees

51

Quick Reference Topics
In-Kind Contributions
Prohibited Contributions
Contributor Information
Date of Contributions
Reconciling Report Issues
Record Retention
Filing Computer Generated Reports
Cash Balance Reconciliation Worksheet
Permissible & Impermissible Expenditures – Candidate Committees
Contribution Limits Local Office
Contribution Limits State Office
Election and Campaign Finance Report Dates

56

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63
65
66


I.

REGISTRATION REQUIREMENTS

Who is Required to Register
Under Wisconsin campaign finance law, a candidate for election to public office must register
with the appropriate filing officer. A candidate for state office:
Governor,
Lieutenant Governor,
Attorney General,
Secretary of State,
State Treasurer,
State Superintendent of Public Instruction,
Justice of the Supreme Court,
Court of Appeals Judge,
Circuit Court Judge,
State Senator,
Representative to the Assembly,
District Attorney;
must register with the State Elections Board in Madison as soon as the individual decides to
become a candidate. Candidates for any local elective office in a county, city, town, village, or
school district, must register with the clerk of the county, city, town, village, or school district as
soon as the individual decides to become a candidate.
A candidate must file a campaign registration statement (EB-1) at the point he/she forms the

intent to become a candidate and before circulating nomination papers, receiving contributions or
spending money on the campaign. Registration statements can be obtained from any filing
officer or from the State Elections Board website (). The minimum
amount of money needed to open an account can be deposited at a financial institution and a post
office box can be rented before registration. These receipts and expenses must be reported on
the first campaign finance report.
After filing the registration statement, a candidate may begin receiving and disbursing campaign
funds. The campaign’s financial activities must be reported to the filing officer on campaign
finance reports (EB-2), unless the committee has claimed an exemption from filing finance
reports. These reports will disclose information on the receipts, expenditures, incurred
obligations and loans of the campaign.
Completing a Registration Statement
Seven items of information are required on a campaign registration statement (EB-1). When any
of this information changes, an amendment to the registration statement must be filed with the
filing officer within ten days of the change. The box at the top of the registration statement is
checked to indicate an amendment to a previously filed campaign registration statement. (An
example of a completed registration statement is shown on pages 24-25).

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Item 1. Candidate and Candidate Committee Information
This section must be completed by all candidates and candidate committees. It contains the
information identifying the candidate and committee, party affiliation (if any), office sought
(including branch and district number), date of the primary and date of the election. Political
action committees, political party committees, recall committees and political groups
(referendum) do not complete this section.
There are two types of candidate campaign committees: personal campaign committee and
support committee. A personal campaign committee is organized by the candidate to promote
the candidate’s declared candidacy for a specific office. A support committee is one organized

on behalf of the possible candidacy of a person, with that person’s consent. A candidate with a
personal campaign committee cannot authorize a support committee. A person who authorizes a
support committee must adopt the support committee as his or her personal campaign committee
when the person becomes a candidate. Note: You must register as a personal campaign
committee to appear on the ballot.
Item 2. Political Committee Information (Non Candidates Only)
This section must be completed by political committees other than candidate committees. The
political committee must provide the name, address and telephone number of the committee,
along with the name of the sponsoring organization, if any, and any acronym used by the
committee. The type of committee is indicated by checking the applicable boxes (A – G).
Candidate committees do not fill in this section.
Item 3. Campaign Treasurer
The treasurer for the candidate or political committee must be listed in Item 3. The candidate
can serve as the campaign treasurer. It is important that the treasurer’s name, complete address
and telephone numbers be provided on the registration statement and be kept current. All
notices and forms for campaign finance reports will be sent to this person at the address
given in this section. Failure to keep this information current may result in the committee being
penalized for failure to file necessary reports.
Item 4. Principal Officers of the Committee and Other Custodians of Books and Accounts
If the committee has officers besides the treasurer, they should be listed in Item 4. A nonpartisan
candidate for county or municipal office, or an independent candidate, may authorize certain
committee members or officers to fill a vacancy in nomination due to the candidate’s death.
These individuals should be indicated in Item 4 with an asterisk (*).
Item 5. Depository Information
All registrants must have a single campaign depository account in which all contributions are
deposited and from which all disbursements are made. Candidates claiming exemption from
filing finance reports may use a personal checking account, i.e., they may commingle campaign
money with personal funds. A separate account must be opened if the candidate (committee)
exceeds the exemption limits. All account information must be provided on the EB-1 whether
the account is a personal or separate campaign account. If the registrant maintains additional

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accounts for investment purposes, including savings account, certificates of deposit, money
market, or a safe deposit box, they should be listed on a separate sheet of paper and attached to
the registration statement. Candidates running for more than one elected office are only allowed
one primary campaign depository account. All contributions and all disbursements for all offices
must be run through the one account.
To open the campaign account, it may be necessary to complete a request for Employer
Identification Number (EIN) using form SS4. This form should be available from your financial
institution or from an IRS office or website.
Item 6. Certification
The candidate and committee treasurer must sign the original registration statement of a personal
campaign committee or a support committee certifying that the information is true, correct, and
complete, and that the committee is the only committee authorized to act on the candidate’s
behalf. Amendments to the registration may be signed by either the candidate or treasurer. If
there is a change in treasurer, the new treasurer should sign.
Item 7. Exemption From Filing Campaign Finance Reports
Registrants who are eligible for an exemption from filing campaign finance reports should
complete this section. The exemption requirements are explained in Section II of this manual.
Amending a Registration Statement
When any of the information reported on the registration statement changes the statement must
be amended by filing a new EB-1. The candidate or treasurer must file the new EB-1 within 10
days of the change, checking the “yes” box at the top of the form to indicate that it is an
amendment.
Penalty For Not Filing a Registration Statement
Failure to file the original registration statement by the deadline for filing nomination papers
prevents a candidate’s name from appearing on the ballot. If a required statement or amendment
is not filed on time, the registrant may be subject to a fine.

II.

EXEMPTION FROM FILING CAMPAIGN FINANCE REPORTS

Eligibility
Committees may be eligible for an exemption from filing campaign finance reports if campaign
finance activity is low enough to meet all of the following criteria:
1. The committee anticipates that it will not accept contributions, make disbursements, or incur
loans and other obligations in an aggregate amount exceeding $1,000 in a calendar year;
AND
2. The committee anticipates that it will not accept any contribution or cumulative contributions
from a single source (other than the candidate) exceeding $100 in a calendar year; AND
3. The candidate or treasurer must sign and date the request for exemption on the campaign
registration statement.

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Committees on exemption may receive up to $1,000 in a calendar year, and may spend up to
$1,000 in the same calendar year. The candidate’s contributions do count toward the total
receipts of $1,000 or less in a calendar year. The $100 limit on contributions from a single
source does not apply to contributions from a candidate’s personal funds for his or her own
campaign.
Financial Records During Exemption
When a committee is exempt, it is not required to file any campaign finance reports (EB-2).
However, the candidate or treasurer is required to keep financial records adequate to meet the
requirements of campaign finance law. Records must be kept of all contributions to the
committee and of all expenditures.
A candidate who is exempt from filing campaign finance reports may use a personal account as
the campaign depository. Account information must be provided on the EB-1. A separate

campaign depository account is not required for candidates claiming exemption.
Revoking Exemption
If a decision is made at a later date to exceed the $1,000 limit on contributions or disbursements,
or to raise more than $100 from a single source during a calendar year, the committee must
amend its campaign registration statement immediately, by checking the box: “This registrant is
no longer eligible to claim exemption.”
The committee is then required to file campaign finance reports beginning with the next regular
report. The first report must cover all financial activity from January 1 of the current year,
through the cutoff date of the required report. The committee may also need to list all committee
contributions received in the current campaign period to monitor aggregate committee limits.
III.

CAMPAIGN FINANCE REPORTS (EB-2)

Campaign finance reports must be filed by all registrants that are not exempt from filing reports.
Committees must continue to file periodic reports until termination of their registration. These
reports must be filed with the appropriate filing officer when due. The campaign finance report
(EB-2) is a multi-page form provided to candidates for state office by the State Elections Board
and to candidates for local office by the local filing officer. (An example of a completed
campaign finance report is shown on pages 28-50).
Types of Reports
Candidates must file a pre-primary and a pre-election report due 8 days before the primary or
election. Candidates for local office whose names do not appear on the primary ballot are not
required to file a pre-primary report. However, candidates for state nonpartisan office whose
names do not appear on a primary ballot are required to file a pre-primary report. Candidates
that lose in the primary or election, must continue to file reports until they are eligible for, and
request, termination of their committee. Candidates must also file continuing reports in January
and July of each year until they terminate their registration.
The filing officer will send report forms and a notice of the filing requirements to the treasurer
before each filing deadline. The notice of filing requirement identifies the type of report to be

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filed and the period of time covered by the report. (A table of reporting periods and filing
deadlines is found on page 66). Failure to receive a notice does not excuse the committee from
filing the report on time.
PACs (political action committees) and political party committees are sent filing notices for
continuing reports and for fall pre-primary and pre-election reports. Regular filing notices are
not sent to these committees for spring elections or special elections. Instead, a notice of the
report deadlines is sent. If the committee is planning to make a contribution to a candidate in the
spring or special election, the treasurer is asked to request report forms.
Committees registered with the State Elections Board that accept contributions over $20,000 in a
campaign period (candidates) or a biennium (non-candidates) are required to file their finance
reports electronically in addition to the paper copy. A biennium is a 2-year period running from
January 1 of an odd-numbered year through December 31 of the next even-numbered year.
Information Required
The information listed on the campaign finance report discloses the financial activity of the
registrant. The law requires disclosure of income, disbursements, and incurred obligations. In
addition, disclosure is required for loan guarantees and for estimated in-kind contributions. This
information is required to be placed on separate schedules of the campaign finance report form.
Committee treasurers must exercise diligence in acquiring and furnishing the contributor
information required on the receipts schedules. Under current state law, treasurers and
candidates are required to make a “good faith effort” to obtain all information required on the
reports. For all contributors giving over $20, you must disclose the individuals name and
address. If the individual’s year-to-date total exceeds $100, you must also provide the
occupation, name and address of the principal place of employment.
At the time this manual was being revised, the Elections Board was in the process of drafting a
rule which would require the return or donation of contributions with incomplete contributor
information. Under the proposed rule, committees would be required to furnish the information

within a specified number of days from the due date of the report, or be required to return the
contribution or donate it to a charity. Elections Board staff will keep state registrants informed
of changes in the requirements for reporting contributor information as they occur.
Each of the report schedules has detailed instructions for completing it on the back. These
instructions should be reviewed each time a campaign finance report is prepared. A committee is
only required to file schedules that show activity. You do not need to include blank schedules
when filing reports.
All contributions received by the committee must be reported in Schedule 1 (Receipts) of the
campaign finance report. Contributions and loans from individuals are listed in Schedule 1A
(Contributions Including Loans From Individuals). Contributions from other committees, such
as political action committees, political party committees, and other candidate committees, are
reported in Schedule 1B (Contributions from Committees). All other income such as loans from
financial institutions, contributions returned from other registrants, refunds, returns of deposits or
interest on investments are reported in Schedule 1C (Other Income and Commercial Loans).

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The date which must be provided for all contributions is the date the committee received the
contribution, that is, the date it acquired possession and control of the contribution, not the date
of deposit or date on the check (unless all dates are the same).
All money spent by the committee is reported in Schedule 2 (Disbursements) of the campaign
finance report. General operating expenditures are listed in Schedule 2A (Gross Expenditures).
Contributions to other political committees are listed in Schedule 2B (Contributions to
Committees).
Additional information required to be disclosed is reported in Schedule 3 (Additional Disclosure)
of the campaign finance report. All obligations of the committee such as unpaid bills are listed
in Schedule 3A (Incurred Obligations Excluding Loans). Loans and the individuals who
guarantee loans for the committee are listed in Schedule 3B (Loans). Estimated values of in-kind
contributions are reported by the recipient in Schedule 3C (Estimated Value of In-Kind

Contribution Received from Individuals and Committees) and by contributors in Schedule 3D
(Estimated Value of In-Kind Contributions Given to Candidates or Committees). Contributions
that your committee is returning to contributors are listed in Schedule 3E (Contributions
Returned to Contributor). Contributions donated to charity or the Common School Fund are
reported in Schedule 3F (Contributions Donated to Charity or Common School Fund).
A registration statement (EB-1) is included in every EB-2 finance report forms booklet to be
used only if there is a change in committee information. If there are no changes in committee
information, please keep the EB-1 form for future updates if needed.
Schedule 4 (Termination Request) of the campaign finance report is used for requests to
terminate registration. A final campaign finance report must be filed with a termination request.
Short Form
If a registrant receives no contributions, makes no disbursements and incurs no obligations
during a reporting period, the registrant may file a post card report form, EB-2a. This post card
form should be used only when there has been no financial activity and the cash balance remains
unchanged during the reporting period. If there is any financial activity, a registrant is required
to use the regular campaign finance report form, EB-2.
Special Report of Late Contribution
Candidates for state offices must report contributions of $500 or more received in the 14-day
period before the primary or election within 24 hours of receipt. A special report of late
contribution (EB-3) must be filed (1) for any contribution of $500 or more, or (2) for
contributions from a single source totaling $500 or more received after the closing date of the
pre-primary or pre-election report and before the primary or election is held. Contributions of
$500 or more from the candidate to his or her own campaign are included in this reporting
requirement. The report must be filed within 24 hours of receiving the contributions. Also, the
contribution must be reported on the next full campaign finance report. (An example of
completed special report of late contributions is on page 26).

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Computer Generated Campaign Finance Reports
The use of personal computers to store campaign information and to generate the various
schedules needed for campaign finance reports is becoming more popular. This section is
intended to help those who want to computerize part or all of their campaign finance reporting
responsibility to choose a computer software package that will meet the statutory disclosure
requirements of campaign finance law. The Elections Board does not recommend any specific
commercial software package for campaign finance reports.
Committees registered with the State Elections Board that accept $20,000 or more of
contributions in a campaign period (candidates) or in a biennium (non-candidate committees) are
required to file finance reports electronically in addition to a hard copy. The campaign period
for a candidate is the same as the length of the term (Assembly – 2 yrs., Senate – 4 yrs.). For
non-candidate committees, a biennium begins January 1 of the odd-numbered years and
continues through December 31 of the even-numbered years.
Committees may download an Excel spreadsheet from the Elections Board website or use private
vendor software to meet the requirement to file electronically.
As you consider various software packages that are compatible with the personal computer you
wish to use, it is very important to keep in mind the following points:
1. A computer software package needs to be versatile enough to produce a report that includes
all of the information required on a campaign finance report. You may be using your
software package for other campaign related purposes, however, please include on the report
only the specific information that is required (do not include contributor phone or social
security numbers). This allows a person who wishes to look at reports a consistent
presentation of the disclosure information supplied by all committees and lowers the chance
of your report being misunderstood.
2. The software package chosen should have the ability to sort information for campaign
finance reports by the date income is received and the date expenditures are made. This
software feature makes it easier to generate a report for the dates within any campaign
finance reporting period.
3. Another important decision when choosing a computer software package is whether to
purchase a package that allows you to keep track of both the required calendar year-to-date

amounts and the campaign period-to-date amounts. A campaign period total feature helps
you track the various statutory contribution limits that are in effect for a campaign period. If
you choose a software package that can not perform this function, remember to set up
another system that allows you to keep track of the various campaign contribution limits.
Once the computer software package that best meets your campaign needs has been chosen, set
up a format for reporting your campaign finance information. Send a sample copy of your
format to your filing officer for approval. If your filing officer is the State Elections Board,
we review your format to make sure it meets all of the statutory disclosure requirements.

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IV.

MAJOR PROVISIONS OF WISCONSIN CAMPAIGN FINANCE LAW

Contribution Limits
The contribution limits established by state statute determine the maximum amount of
contributions (cash, loans, and in-kind contributions combined) that an individual or committee
can give or receive over a campaign period. These limits depend on the office sought by the
candidate and the identity of the contributor. (The limits are set out in the table on pages 63-65).
A candidate or committee may not accept contributions that exceed the applicable limit.
Definition of Campaign for Calculating Contribution Limits
For purposes of calculating contribution limits, a candidate’s campaign begins on the date a new
candidate is required to file a registration statement, i.e., the date he or she decides to become a
candidate. The campaign begins for a continuing candidate on either July 1 (candidates
participating in the April election) or January 1 (candidates participating in the November
election). If a continuing candidate has incurred obligations, the next campaign period begins on
the date the candidate receives sufficient contributions to retire those obligations.
The campaign period includes both the primary and election. The usual campaign period for an

Assembly candidate is two years (January 1 odd-numbered year through December 31 of the
even-numbered year).
In the case of a candidate at the September primary or November general election, the campaign
ends on either December 31 following the election or the date the candidate receives sufficient
contributions to retire any obligations incurred in connection with that election, whichever is
later. In the case of a candidate at the spring primary or election, the campaign ends on June 30
following the election or the date the candidate receives sufficient contributions to retire any
obligations incurred in connection with that election, whichever is later. The campaign of a
candidate at a special primary or election ends on the last day of the month following the month
in which the primary or election is held or the date the candidate receives sufficient contributions
to retire any incurred obligations, whichever is later. Example: Special Election on April 20 –
campaign ends on May 31.
A candidate with debt from a previous election may have more than one open campaign period.
A candidate for a future election, that has debt from a past election, may start raising money for
the future election prior to receiving sufficient funds to retire the debt. If a candidate has
multiple campaign periods open and has carried contributions from one campaign back to offset
debt from a prior campaign period, they must clearly identify which contributions are being used
to retire past debt and also retire that amount of debt. Contributions used for retiring debt, are
subject to the contribution limits of the campaign in which the debt was incurred.
Individual Contribution Limits
The individual contribution limits for candidates for statewide office and local office vary. The
specific amounts are listed in the first column of the table on pages 63-65. Candidates for state
senate may not receive more than $1,000 from a single individual over the campaign period.
Candidates for representative to the assembly may not receive more than $500 from a single
individual over the campaign period. In addition to the limits listed in the table on pages 63-65,

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an individual may not contribute more than $10,000 in a calendar year to any combination

of Wisconsin candidates or political committees.
Committee Contribution Limits
The committee contribution limits for candidates for statewide office and local office vary. The
specific amounts are listed in the table on pages 63-65. Candidates for state senator may not
receive more than $1,000 from a single political committee unless the committee is a political
party or a legislative campaign committee. Candidates for representative to the assembly may
not receive more than $500 from a single committee unless the committee is a political party or a
legislative campaign committee.
Cumulative Committee Contribution Limits
There are two different cumulative committee contribution limits. One applies to all political
committees excluding political party committees. The second applies to all political committees
including political party committees. These are commonly referred to as the 45% and 65% limits
because they are found by calculating 45% or 65% of the statutory spending limits for a
particular office. Section 11.31 Wis. Stats., lists the spending limits for elective office. These
spending limits are only for calculating aggregate committee contribution limits, unless the
candidate files an application for a grant from the Wisconsin Election Campaign Fund (WECF).
The limit on the cumulative amount of contributions that can be received from all political
committees excluding political party committees or legislative campaign committees is
calculated by taking 45% of the total spending limit for the candidate’s office. The specific
amounts are listed in the table on pages 64-65. Contributions from other candidate’s personal
campaign committees, political action committees, and grants from the Wisconsin Election
Campaign Fund (WECF) count against this contribution limit.
The limit on the cumulative amount of contributions that a candidate may receive from all
committees including political party committees is calculated by taking 65% of the total
spending limit. The specific amounts are listed in the table on pages 64-65. Contributions from
all political committees, including political party committees and legislative campaign
committees, and grants from the Wisconsin Election Campaign Fund (WECF) count against this
contribution limit.
Exclusions From Contribution Limits
Contributions used to pay legal fees and other expenses incurred in connection with a recount or

petitions to recall an officer are not subject to contribution limits. In order to qualify for this
exclusion, recall expenses must occur before the recall primary or election is ordered, or in
contesting or defending the order. Contributions used to pay recount or recall expenses must be
reported on the regular campaign finance reports. Both the contributor and the candidate should
indicate which contributions are being used for this purpose.
In-Kind Contributions
An in-kind contribution is any goods, service or property offered to the campaign committee
free, or at less than the usual cost, or payment of a registrant’s obligations for such goods,
services or property. For example, if a campaign worker purchases stamps that are used for a

9


mailing and is not reimbursed for the cost of the stamps, the value of the stamps is an in-kind
contribution to the campaign committee from that campaign worker. When an individual is paid
to work on behalf of a candidate by a political committee or some other individual, the payment
for those services is an in-kind contribution to the campaign committee. If a political committee
or individual offers to provide food and beverages for a fundraiser at less than the ordinary
market price, the difference between the ordinary market price and the cost to the campaign is an
in-kind contribution from the political committee or individual.
The candidate or campaign treasurer must agree to accept an in-kind contribution before it is
given. When the contribution is from an individual and its value is small, a verbal agreement to
accept it usually is sufficient. However, when another political committee gives the contribution,
the campaign committee should obtain a written description of the contribution, its actual value
and the date the contribution will be given from the political committee. Also, the campaign
committee should agree to accept the contribution in writing. If the contributor does not know
the actual value of the contribution when the candidate’s consent is needed, a good faith and
reasonable estimate of the fair market value should be provided. (For more information see
ElBd.1.20 Wis. Administrative Code).
An in-kind contribution received by the campaign committee is reported by the committee as

both a receipt and expenditure. This procedure allows the campaign to disclose the receipt of the
contribution on its campaign finance report along with cash contributions received and track year
to date and campaign period totals. Then, in order to keep the committee’s cash balance
accurate, the amount of the in-kind is reported as an expenditure. The two entries offset each
other and, consequently, do not affect the cash balance.
If an estimate of the value of an in-kind contribution is the only value available at the time the
campaign committee must file a report, the committee must report the estimated value of the
contribution in Schedule 3C (Estimated Value of In-Kind Contributions Received…). When the
actual value of the estimated in-kind contribution is known, the actual amount is reported as a
contribution and an expenditure on the campaign finance report.
In-kind contributions are subject to the same itemization thresholds and the same contribution
limits as cash contributions. Cash contributions and in-kind contributions from a single
contributor are added together for the purposes of determining compliance with contribution
limits and the year-to-date amount for a specific contributor. When a political communication is
provided as an in-kind contribution, the disclaimer must identify the committee receiving the
contribution (see page 13 for examples).
Prohibited Contributions
Certain contributions are prohibited by Wisconsin law.
following types of contributions:

A committee may not accept the

1. Anonymous contributions of more than $10;
2. Contributions in cash of more than $50;
3. Contributions given in the name of someone other than the contributor (these are laundered
contributions);
4. Contributions from cooperatives or corporations;
5. Contributions in excess of the limits set by law.

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A registrant should not accept contributions over $25 from organizations that have not registered.
If the committee is notified that a contribution was received from an unregistered organization,
the committee must return the contribution, and not accept any additional contributions from that
organization unless the organization registers with the appropriate filing officer. To determine if
a committee is registered, check with your filing officer.
Registered lobbyists are prohibited from making campaign contributions to state candidates
except between June 1 and the day of the general election in the year of the candidate’s election.
Contributions cannot be given during this period if the legislature is in session. For more
information on this restriction, contact the Ethics Board at (608) 266-8123.
Returned Contributions
Any contribution you return to the donor after depositing it in the campaign account must be
reported on Schedule 2A (Disbursements, Gross Expenditures) and Schedule 3E (Contributions
Returned to Contributor). Any contribution returned to the donor uncashed within 15 days of
receipt has not been accepted and does not get reported.
Contributions Transferred through Conduits
A conduit is any individual, committee or group that receives contributions from individuals,
deposits those contributions in a financial institution, and then transfers the contributions to a
candidate or political committee selected by the original contributor. The conduit may not
exercise any discretion over the amount or ultimate recipient of the contributions. A conduit is
required to register with the State Elections Board.
When a conduit transfers contributions, it writes a single check for the total amount of all
individual contributions designated for that committee. It is required to provide a transmittal
letter with the check. This letter must identify the organization as a conduit, and list the
individual contributors, the amount of each individual’s contribution, and the date the individual
authorized their contribution (see ElBd. 1.855 Wis Admin Code).
Contributions transferred through conduits are reported as contributions received from the
individuals listed in the transmittal letter. These contributions are reported under the individual’s
name in Schedule 1A (Contributions Including Loans from Individuals). They are subject to

itemization on the same basis as other individual contributions.
Loan Guarantees
When a campaign committee borrows money from a financial institution and the loan is
guaranteed by individuals, the amount of the guarantee must be considered a contribution from
the guarantor until the loan is repaid. Loan guarantees are reported on Schedule 3B (Additional
Disclosure, Loans: Individual, Committee or Commercial). If more than one person guarantees a
loan, the amount of a loan is assigned to the guarantors in equal shares in the proportion that the
guarantors bear to the total amount guaranteed, unless a different share is specified in the loan
instrument. When a payment is made to the lending institution which reduces the unpaid balance
of the loan, the amount of the guarantee assigned to each guarantor is reduced in equal shares in
the proportion that the number of guarantors bears to the amount repaid, unless a different share
is specified in the loan instrument. The outstanding amount of a guarantee and the total

11


contributions to the campaign by a guarantor may not exceed the individual contribution limit for
the guarantor.
A bank loan to a candidate, the proceeds of which the candidate loans to the committee is a
personal contribution (loan) from the candidate. This type of loan is reported as a contribution
from the candidate to the committee on Schedule 1A not 1C.
Joint Fundraisers
Any personal campaign committee, political party committee or legislative campaign committee
may solicit contributions for and conduct a joint fundraising effort or program in coordination
with one or more named candidates. The committee or committees conducting the joint
fundraiser must prepare a written escrow agreement signed by the committees. The agreement
shall specify the percentage of the proceeds to be distributed to each committee by the joint
fundraising effort or program.
All solicitations or communications related to joint fundraising efforts or programs shall include
information identifying the committees participating and the percentage of the proceeds to be

distributed to each. No disclaimer is required on these communications if the communication
contains the information described above.
All contributions received and disbursements made by the joint fundraiser shall be received and
disbursed through a separate depository account. The separate depository account shall be
identified in the escrow agreement.
The committee(s) conducting the joint fundraising effort or program are required to register by
filing a Supplemental Schedule of Joint Fund Raising Effort or Program (EB-2JF). The joint
fundraiser must prepare a campaign finance report (EB-2) covering contributions received and
disbursements made in connection with the joint fundraiser. A copy of this report must be
provided to each committee that receives any of the proceeds no later than 15 days after the
proceeds are transferred to the candidate or campaign treasurer.
Committees are required to include a copy of this report and the escrow agreement with their
campaign finance report for the period in which the contributions are received and the
disbursements are made. In addition, candidates are required to itemize in the appropriate
schedules of the campaign finance report the percentage of the proceeds and disbursements
applicable to the candidate. These amounts are added to the totals reported in each schedule.
V.

ATTRIBUTION STATEMENTS ON POLITICAL LITERATURE (DISCLAIMERS)

Disclaimers
Every communication which is paid for by political funds must contain a disclaimer or
attribution statement identifying the source of the funds paying for the communication. This
includes every printed advertisement, billboard, handbill, sample ballot, television or radio
advertisement or other communication paid for by political funds. Also, it includes items such as
T-shirts, bumper stickers and yard signs. The disclaimer must use the words “Paid for by”
(abbreviations shall not be used for this language) followed by the name of the committee or
group making the payment or assuming responsibility for the communication and the name of
the treasurer or other authorized agent of the committee. When the communication is being paid

12


for through an in-kind contribution, it must bear the disclaimer of the recipient campaign
committee. Abbreviations may not be used for the name of a candidate or campaign committee.
No disclaimer is required on 1) personal correspondence not reproduced by machine for
distribution, 2) a single personal item which is not reproduced or manufactured by machine or
other equipment, 3) nomination papers even if the papers contain biographical information, 4)
pins, buttons, pens, balloons, nail files and similar small items on which a disclaimer cannot be
conveniently printed, or 5) envelopes which have campaign committee identification printed on
them. Disclaimers must be included on each separate page of a political communication,
including letterhead and enclosures.
Formats for Disclaimers
When a communication is paid for by a candidate without a committee, or paid for by an
individual, the disclaimer should read:
“Paid for by Mary Smith.”
When the communication is paid for by the campaign committee of a candidate or by a political
committee, the disclaimer should read:
“Paid for by Friends of Mary Smith for Mayor, James Jones, Treasurer.”
“Paid for by the Committee for Votes, John Jones, Treasurer.”
When the communication is provided as an in-kind contribution to the campaign committee of a
candidate, the disclaimer should read:
“Paid for by Friends of Mary Smith for Mayor, James Jones, Treasurer.”
or
“Paid for by John Doe as an in-kind contribution to Friends of Mary Smith for
Mayor, James Jones, Treasurer.”
VI.

TERMINATION OF REGISTRATION AND REPORTING REQUIREMENTS

Any candidate, committee or group may terminate its registration if it meets the following
requirements:
1. Determines that all financial activity will stop, and that it will no longer receive
contributions, make disbursements, or incur obligations; and
2. Files a termination campaign finance report showing that all incurred obligations have been
paid or satisfied, and that the cash balance has been reduced to zero; and,
3. Completes a request for termination in Schedule 4 (Termination Request).
A committee that is exempt from filing campaign finance reports need not file a termination
report.
A candidate may not terminate his or her registration before a primary or election in which he or
she is a candidate. If a candidate loses a primary, he or she may terminate before the election.

13


Disposal of Residual Funds
A candidate or committee may dispose of remaining funds when terminating by:
1. Returning money to contributors in amounts that are not more than the contributor’s original
contribution (note: the candidate or treasurer may choose which contributors to refund. You
are not required to prorate and return a portion to all contributors); or
2. Donating money to any tax-exempt charitable organization, the Common School Fund,
Wisconsin Election Campaign Fund, or any other government entity; or
3. Transferring money to another registrant within the permitted contribution limit; or
4. Using any combination of the above.
Contributions to charities are permitted only when terminating a political committee or when
disposing of illegal corporate contributions. Note that the charitable donations should be the
final disbursements made. Prior to making these disbursements, make sure the committee does
not have any pending fees or settlement offers.
VII.

RECOMMENDED BOOKKEEPING SYSTEM

The Elections Board staff has developed a bookkeeping system for keeping campaign finance
records. The system is not mandatory, but it will assist candidates and treasurers to comply with
the reporting requirements of the law. Accurate campaign finance reports can be prepared with
less effort if detailed records are kept throughout the campaign. This system can make your
work simple, efficient, and accurate. It also can help the committee comply with the campaign
finance contribution limits for individuals, parties, and committees.
Our recommended bookkeeping system consists of a daily receipts log, a contributor card file,
and a daily expenditures log. All the information recorded in the logs and on the cards is used
when completing the schedules of a campaign finance report. Other record keeping devices the
treasurer may find helpful are shown as well.
This system assumes that the treasurer is compiling the information and storing it manually. The
basic format can be adapted for use with a personal computer. The use of personal computers to
store campaign finance information and to generate reports is discussed in the section dealing
with computer generated reports on pages 7, and 58.
Recommended Ledgers
Daily Receipts Log
The first step in setting up the recommended bookkeeping system is to prepare a daily receipts
log. A receipt is defined as a gift, subscription, loan, advance, deposit of money, or anything of
value received for political purposes. Most receipts will be contributions in the form of cash or
check. Each receipt should be listed with the date, name, full address of the contributor or source
of income, and the amount received. The amount column should be divided showing receipts
that do not require itemization on the campaign finance reports ($20 or less) and those that must
be itemized (over $20). The log should have columns for the year-to-date total, for writing the
schedule where the receipt must be reported, and for showing the bank deposits.

14

DAILY RECEIPTS LOG
Date
2004

Amount
$20 or Over
Less
$20

Name and Complete Address

Comm. For Better Candidates
108 N. Capitol St., Madison 53702
01/05
DEPOSIT
Jim Johnson
03/15
1502 Main St., Mt. Horeb 54312
Smith Printing – Refund
03/17
1102 W. Wis. Ave., WI Dells, 53965
03/19
DEPOSIT
Peoples Bank (Interest)
06/30
123 Elm St., Deforest 53532
July 2004 finance report cutoff
01/03

500.00

07/02
07/03
08/09
08/08
08/11
08/11
08/15
08/15

EB-2
Schedule

500.00

1B

Bank
Deposit

500.00
20.00

20.00
34.20

1A
1C
54.20

15.67

Date
2004

YTD
Total

Amount
$20 or Over
Less
$20

Name and Complete Address
Republican Party of WI
PO Box 35, Madison, WI 53701
DEPOSIT
Peoples Bank (Loan)
123 Elm St., Deforest 53532
DEPOSIT
Mary Duncan, (via conduit)
7890 14th Ave., Kenosha 53405
Tom Jones (via conduit)
1215 S. Hampton, Oxford 53952
John Doe (Loan)
815 E. Ash St., Lancaster 53813
DEPOSIT

200.00

1C

15.67

YTD
Total

EB-2
Schedule

Bank
Deposit

200.00

1B
200.00

300.00

1C / 3B
300.00

20.00

20.00

1A

100.00

100.00

1A

200.00

200.00

1A / 3B
320.00

The year-to-date cumulative amount for each contributor should be listed in a separate column in
the daily receipts log. When the cumulative amount for an individual exceeds $100 for the
calendar year, the occupation and the name and address of the principal place of employment of
the contributor must be reported on the campaign finance report. This additional information
should be shown on the contributor card discussed in the following section.
When the first bank deposit is made, the total deposit is entered in the daily receipts log. The
amount of each bank deposit should be shown alongside the receipts as they appear in the daily
log to facilitate checking for errors.
When the financial report for the reporting period is prepared, the information for itemized
contributions over $20 can be taken directly from the daily log. Since the cumulative amounts
are noted in the log, there is no need to refer to the contributor cards unless the cumulative
amount exceeds $100. If the contributor’s cumulative amount exceeds $100, the treasurer should
refer to the contributor card file to obtain the information about the contributor’s occupation and
the name and address of his or her principal place of employment. This information should be
entered in Schedule 1A (Receipts, Contributions Including Loans from Individuals) of the
campaign finance report.

15

Contributions of $20 or less should be totaled for each report period. When a contributor’s
cumulative contributions exceed $20, the amounts must be itemized. They should not be
reported in the unitemized contribution total.
When a contribution from another registrant is received, the same procedure for entering the
information in the daily log is followed. It is helpful to write 1B by the receipt to indicate that it
is reported in Schedule 1B (Receipts, Contributions from Committees) of the campaign finance
report.
When other income, in the form of loans from financial institutions, contribution returned from
other registrants, refunds, interest earned, returned deposits, or commercial transactions, such as
the sale of campaign assets, is received the income is listed on the daily log indicating the date
and source of the income. Write 1C next to the entry in the daily log. This will help the
treasurer identify income that is reported in Schedule 1C (Receipts, Other Income and
Commercial Loans) of the campaign finance report.
Contributor Card File
The contributor card file contains index cards on which contributions made to the campaign are
recorded. One index card should be made for each individual and for each registrant making a
contribution. There should be a separate file for individual contributors and for committee
contributors (registrants). The card for an individual contributor should contain the contributor’s
name, address, occupation, the name and address of the contributor’s principal place of
employment, and the contribution limit applicable to that individual. The contributor card for a
committee has a similar format but without the information on occupation. These should be filed
alphabetically in the appropriate file box. In this way, the treasurer can record one or more
contributions received from the same person or committee on different dates. With all this
information on the same card, the treasurer can easily verify a person’s or a committee’s
contributions during the campaign period.
Our suggested form for a receipt card is:
Name:
Address:

Contribution Limit:
Date
Amount

Occupation:
Name and Address of Principal Place
of Employment:

Total

Description

16


The top part of the card records the information about each contribution that may be needed for
completing the finance reports. Depending on the total amount of the contribution, the treasurer
may not be required to report all the information on each card. But this information will be
available if it is needed at a later date. The lower half of the card identifies the contribution by
the date and the amount.
Here is an example of how to enter a series of contributions from a single contributor:
Assembly candidate, David Smith, receives five contributions from John Jones in the same year:
1.
2.
3.
4.
5.

A loan of $100;

A cash donation of $20;
A donation of campaign signs valued at $75;
A total of $40 for four tickets to a fundraiser;
A donation of food for a fundraiser valued at $25.

His campaign contribution limit is $500. These transactions would be recorded as follows:
Occupation: Salesman
Jones Sales Co.
Highway 51
Deforest, WI 53532

John Jones
1 Main Street
Waunakee, WI 53597
Contribution Limit: $500
Date

Amount

Total

Description

1/13
2/15
3/20
3/28
4/4

$100

20
75
40
25

$100
120
195
235
260

Loan
Cash
In-kind, campaign signs
Check
In-kind, food for fundraiser

Daily Expenditures Log
Every disbursement made by the campaign committee must be by negotiable instrument. The
name of the candidate or committee must appear on the face of the check along with sufficient
words to indicate the political nature of the account. The only exceptions are expenditures from
petty cash. Petty cash funds are discussed on page 19.
DAILY EXPENDITURES LOG
Date
2004
01/03
03/10
03/31
05/06

Business Name and Address
U.S. Postmaster, 1501 Milwaukee
St., Madison 53712
Smith Printing, 1102 W. Wisc. Ave.,
Wisconsin Dells, WI 53965
Peoples Bank, 123 Elm St., Deforest,
WI 53532
WI Telephone, 316 W. Washington
Ave., Madison, WI 53705

Chk.
No.

Purpose

Amount
$20 or Over
Less
$20

502

Stamps

58.00

2A

503

Printing – Brochures

200.00

2A

-------

Service Charges

504

April Telephone

17

19.50

EB-2
Schedule

2A
37.96

2A


Computerland, 195 N. Johns St.,
Waunakee, WI 53708
July 2004 finance report cutoff

Peoples Bank, 123 Elm St.,
07/01
Deforest, WI 53532
John Doe for Assembly
07/27
418 E. Water St., Lodi, WI 53555
Joe’s Supper Club, 237 W. Lake St.,
08/15
Briggsville, WI 53920
Smith for Senate, (I-K) (Postmaster)
08/22
248 Oak St., Rio, WI 53960
Pre-Primary report cutoff
Peoples Bank, 123 Elm St., Deforest,
09/01
WI 53532
09/01 Peoples Bank, “
09/30 Peoples Bank, “
Tom Day, 5193 Riverview Dr.,
10/12
Wisconsin Rapids, WI 54494
06/07

505

Office Supplies

-------

Service charges

506

Contribution

507

Fundraiser
hall/food

508

47.93
19.50

2A
2A

250.00

2B

450.00

2A

Postage

137.50

2B

509

Loan payment

50.00

2A / 3A

509
-------

Interest
Service Charge

510

Return Contribution

–

3.00
19.50

2A
2A
30.00

2A / 3C

The daily expenditures log contains all of the information needed to complete Schedule 2
(Disbursements) of the campaign finance report. Each entry should show the date, the name and
address of the business or person, the check number and the specific purpose of the expenditure.
The amounts of items that must be itemized on reports, expenditures over $20, are listed in one
column. Items not requiring itemization, expenditures of $20 or less, are listed in a different
column. Unitemized expenditures are totaled and reported as a lump sum in Schedule 2A (Gross
Expenditures). An additional column is provided for writing the schedule where the expenditure
is to be reported. Indicating the proper schedule at the time the expenditure is made simplifies
completing the campaign finance reports later.
Special Purpose Ledgers
In-Kind Contributions Ledger
A separate ledger should be kept for in-kind contributions. In-kind contributions also are entered
on the contributor cards. For a full discussion of in-kind contributions see pages 9-10, and 56.
IN-KIND RECEIPT / EXPENDITURES
Note: All in-kind receipts must have an offsetting expenditure report on schedule 2A.
Date

2004

Name and Complete Address

Jane Jackson,
Rt. 5, Lodi 53515
Tim Jones, 234 W. Dewey
01/15
Mazomanie 53560
Dane Co. Rep. Party
06/15
Box 1798, Madison 53701

July 2004 Continuing Finance Report
Republican Party of WI
07/02
Box 31, Madison 53701
01/08

Purpose

Amount
$20 or
Less

Copying Letters

$16.00

YTD
Total

EB-2
Schedule

$16.00

1A / 2A

78.00

78.00

1A / 2A

Radio Ads

500.00

500.00

1B / 2A

Printing

200.00

200.00

1B / 2A

Postage
Letters

18

for

Over
$20


In preparing campaign finance reports, in-kind contributions should be taken from this record

and listed in Schedule 1A (Contributions Including Loans from Individuals) if the in-kind
contribution comes from an individual, or Schedule 1B (Contributions from Committees) if the
in-kind contribution comes from another registrant. Because in-kind contributions substitute for
expenditures that could have been made by the committee, the receipt of every in-kind
contribution must also be reported as an in-kind expenditure in Schedule 2A (Gross
Expenditures).
Petty Cash Ledger
A petty cash fund can be a useful method to make expenditures for various inexpensive items.
The treasurer may want to establish a petty cash ledger for these transactions. Our suggested
format for a ledger, similar to a checkbook ledger, can be done on a sheet of 8 ½” x 11” paper
and does not require a detailed explanation.
Our suggested format is:
Petty Cash Ledger
Date
Name & Address

Purpose

Amount

Deposit
Balance
(Check #)

For example, candidate David Smith starts his campaign and deposits $50 into his petty cash
fund by writing a check from his campaign account to cash. He notes on the check, “for petty
cash.” He then buys $10 worth of supplies, and spends $20 for stamps. His transactions are
recorded as follows:
Petty Cash Ledger
Date

Name & Address
2004
01/05
Cash In
G&F Supply Co.
01/07
105 Main St., Waunakee
01/09
Postmaster, Waunakee

Purpose

Amount

Deposit
Balance
(Check #)
$50 (#10) $50

Supplies

$10

40

Stamps

20

20

The $50 check for petty cash is not reported in Schedule 2A (Gross Expenditures) of the
campaign report but each expenditure should be reported. The campaign treasurer should be
given a receipt for each expenditure. The receipts should be kept with the other financial
records. The receipts and the checks used to put funds into the petty cash account should balance
each other. The amount in petty cash should be determined by the candidate or treasurer. It is
recommended that disbursements of more than $20 be made by check instead of from the petty
cash fund whenever possible. Any disbursements from petty cash for more than $20 must be
itemized in Schedule 2A.
Contribution Limit Ledger
It is an essential part of the campaign treasurer’s job to ensure that the candidate committee does
not exceed the cumulative contribution limits applicable to the campaign. Use of a contribution
limit ledger similar to the one shown below will help the treasurer fulfill this responsibility.

19


SAMPLE CONTRIBUTION LIMIT LEDGER
Single Committee: $500

Maximum Limits (State Assembly)
Cumulative Committee / Party
Cumulative Committee
(65%) Limit - $11,213
(45%) Limit - $7,763
PAC, Candidate All Committees
Contribution
Comm., WECF including Parties
Amount
Limit $7,763

Limit $11,213

Date

Contributor

2003
02/03
03/05
05/10
06/15
09/30
11/09

Small Businessmans PAC
Johnson for Governor Comm
Dane Co. Republican Party
Dane Co. Republican Party
People’s Choice PAC
Jones for Senate Comm.

2004
01/03
07/02
08/15
09/30
10/01
10/13

Committee for Better Candidates

Republican Party of WI
Republican Assembly Campaign
Committee
Small Businessman’s PAC
Republican Assembly Campaign
Committee
Dane Co. Republican Party

$100.00
50.00
200.00
500.00
100.00
200.00

$100.00
150.00

500.00
200.00

950.00

250.00
450.00

500.00
100.00

$100.00

150.00
350.00
850.00
950.00
1,150.00
1,650.00
1,850.00
2,350.00

1,050.00

2,450.00

2,000.00

4,450.00

1,000.00

5,450.00

The single committee contribution limit, the cumulative committee contribution limit, and the
cumulative committee/party contribution limit applicable to the campaign are written at the top
of the page. The amount of each contribution received from a political committee, other
candidate’s campaign committee or political party committee is entered in the amount column.
This amount is added to the total received from all other committees subject to the same limit.
This allows the treasurer to keep a running cumulative total for the two cumulative contribution
limits.
Completing Campaign Finance Reports
Reporting Receipts

In preparing to report receipts on a campaign finance report, please remember the following:
1. Receipts of $20 or less, including contributions from individuals and other income, such as
interest and refunds, are reported as unitemized receipts in the appropriate section of
Schedule 1A or 1C. However, your records must show all receipts in the daily receipts log
and include all contributions in the total shown on the contributor card.
2. A single contribution or cumulative contributions from the same person totaling more than
$20 must be itemized in Schedule 1A.
3. A single contribution or cumulative contributions from the same person exceeding $100 is an
itemized contribution requiring not only the contributor’s name and address, but also the

20


contributor’s occupation and the name and address of his or her principal place of
employment.
4. Contributions from individuals received through a conduit are reported in Schedule 1A.
They are treated in the same manner as other individual contributions.
5. Each individual contributor’s name, address, and amount of contribution must be listed
separately in Schedule 1A.
6. A contribution given from a joint checking account should be reported as a contribution from
the individual that signed the check. If any part of the amount on the check is intended to be
contributed by the other owner of the account, that amount must be clearly indicated on the
check or in some other writing which accompanies the check. Note: If the amount is
divided, each individual must be itemized separately.
7. Receipts from raffles, auctions, garage sale, and other similar fundraising events are
individual contributions and must be reported in Schedule 1A.
8. Contributions received from a sole proprietorship or partnership are reported as individual
contributions in Schedule 1A (corporations and associations are not allowed to contribute).
9. All contributions from political committees, regardless of the amount, must be itemized in
Schedule 1B with the full name and address of the registrant, the date and amount of the

contribution.
10. In-kind contributions such as political posters, lawn signs, and other items are reported at
their fair market value at the time of contribution. These contributions are reported as both a
receipt and an expenditure. As a receipt, they are reported in Schedule 1A or 1B, with the
appropriate information about the contributor. As an expenditure, the in-kind contribution is
reported on Schedule 2A. This offsetting entry procedure is necessary because an in-kind
contribution is treated as if cash was given, and then used to buy the item contributed.
11. A loan from an individual is considered a contribution. It must be reported in Schedule 1A
as a contribution and in Schedule 3B as a loan. Payments on the loan should be reported as
expenditures in Schedule 2A and the cumulative amount paid in a reporting period recorded
in Schedule 3B. THE LOAN ADDED TO OTHER CONTRIBUTIONS FROM THE
SAME INDIVIDUAL CANNOT EXCEED THE APPLICABLE INDIVIDUAL
CONTRIBUTION LIMIT. Loans from political committees are considered contributions
and reported in Schedule 1B.
12. Contributions returned from other registrants, refunds, interest income and loans from
commercial lenders are reported in Schedule 1C.
Reporting Expenditures
In preparing Schedule 2 of the campaign finance report, the treasurer should remember the
following:
1. All expenditures totaling $20 or less are unitemized expenditures that can be lumped together
and reported as an unitemized total in Schedule 2A.
2. An expenditure that exceeds $20 in amount or value is an itemized expenditure requiring the
name and address of the person or business to whom it was made and the date and amount of
the payment. It is reported in Schedule 2A.
3. The specific political purpose of an expenditure must be reported. Please remember that the
purpose of campaign finance reports is to inform the public. The descriptions should provide
a person, perhaps unfamiliar with the intricacies of campaigning, with information on the
nature of the expenditure and how it relates to the political process. For example, if food has
been purchased for a fundraiser or for a party for workers, give the purpose as “food for
fundraiser” or “food for party for campaign workers.” Do not write “food” only. If T-shirts

21