March 28, 2014

Compliance Corner: Contribution Attribution and Federal Primary Dates for 2014

Holland & Knight Eyes on Washington Blog
Aimee S. Lubin

With 2014 being a federal election year, and primary elections occurring during a span of just six quick months, it is important to keep an eye on the dates of those primaries when making political contributions to avoid a scenario where a campaign incorrectly attributes a contribution to the wrong election period.

The Federal Election Commission (FEC) encourages PACs to designate contributions in writing for a particular election (for example, a primary or the general). This designation may be written on the actual check or in an accompanying letter.

An undesignated contribution automatically counts against a PAC's limit for the next scheduled election. So, if a PAC wishes to make a contribution for an election other than the next one, the contribution must be designated in writing.  In addition, PAC managers and treasurers should pay particular attention to these primary dates when issuing disbursements, so as not to attribute a check to a primary election that has already passed.

Here's a quick tally of primary election dates across the country this year.

Primary Election Dates 2014

  • March 4: Texas
  • March 18: Illinois
  • May 6: Indiana, North Carolina, Ohio
  • May 13: Nebraska, West Virginia
  • May 20: Arkansas, Georgia, Idaho, Kentucky, Oregon, Pennsylvania
  • June 3: Alabama, California, Iowa, Mississippi, Montana, New Jersey, New Mexico, South Dakota
  • June 10: Maine, North Dakota, Nevada, South Carolina, Virginia
  • June 24: Colorado, Maryland, Oklahoma, New York (tentative), Utah
  • August 5: Kansas, Michigan, Missouri, Washington
  • August 7: Tennessee
  • August 9: Hawaii
  • August 12: Connecticut, Minnesota, Wisconsin
  • August 19: Alaska, Wyoming
  • August 26: Arizona, Florida, Vermont
  • September 9: Delaware, Massachusetts, New Hampshire, Rhode Island

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