Many members of the House and Senate already have announced their plans to retire after their current term is over. The expectation is that the list will grow before November's election. However, there are a handful of senators and representatives who have decided to resign from their seats before the next election, prompting a special election to fill the vacancies.
Special reporting requirements for Political Action Committees (“PACs”) take effect when a special election is scheduled to fill a vacant seat. These reporting requirements mainly impact PACs that file with the Federal Election Commission (FEC) on a quarterly basis, although many PACs do and have transitioned to a monthly filing schedule during this election year. In December, this blog discussed the advantages of transitioning from quarterly to monthly filing during election years.
If a PAC files reports monthly and participates in a special election, that activity will be captured quickly in the next reporting period. But if a PAC files quarterly and engages in a special election, it is possible that the PAC could miss a special reporting deadline.
The current list of special elections and their dates include:
Florida 13th Congressional District
Florida 19th Congressional District
North Carolina 12th Congressional District
Please note that currently there are two special elections whose dates have not yet been scheduled:
Montana Senate (seat vacated by Sen. Max Baucus)
New Jersey 1st (seat vacated by Rep. Rob Andrews)
It is important that PAC managers and treasurers pay particular attention to these special election reporting dates, especially if their PAC is a quarterly filer.
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