This document contains all information you need for FEC compliance for conduit accounts. Before you proceed, please double check to make sure you know what type of account you are working with by reading this doc.
Please note that this is not legal advice, so you should consult with your counsel and compliance team when filing reports, but this will help get you going in the right direction
Table of Contents
How Donations Work for Conduit Accounts
Conduit accounts receive donations that are earmarked to them by the donor via WinRed PAC. The WinRed PAC is an FEC registered PAC that serves as a passthrough for donations. When a donor gives on a page, the candidates to whom they are giving are listed and WinRed PAC distributes the funds to the recipient committees.
If you are working with a federal-level committee that registers with the FEC, you most likely have a conduit account, meaning donations are conduited to you via WinRed PAC. You can confirm this by checking the funding type of your account.
Recipient Committees Reporting Earmarked Receipts
All contributions received from WinRed for conduit accounts are earmarked contributions through WinRed PAC. An earmarked contribution from WinRed must be reported by both the conduit and the recipient committee.
The recipient of an earmarked contribution has a reporting obligation if the earmarked contributions received from a single conduit exceed $200 per election cycle or calendar year depending on your committee type. In that case, on Schedule A, the authorized committee must:
Identify the conduit by name and address (and occupation and employer if the conduit is an individual)
Report the date of receipt and total amount of earmarked contributions received from that conduit
Itemize the original contributions from each individual whose total contributions to the committee aggregate over $200 per election cycle or calendar year depending on your committee type (including the full name, mailing address, occupation and employer of the contributor, the amount earmarked and the date the conduit received the contribution).
Here is the information for WinRed PAC you will need to report the earmarked contributions. Please note this information relates to the PAC only and is not the entity to report processing fees to.
WinRed is a non-connected PAC
FEC ID C00694323 — https://www.fec.gov/data/committee/C00694323/?tab=about-committee
Address: PO BOX 9891 ARLINGTON, VA 22219
WinRed is a PAC that distributes earmarked contributions to candidates and committees
Recipient Committees Reporting Conduit Processing Fees
WinRed Technical Services LLC deducts a processing fee from each conduit. To report these fees to the FEC please follow these instructions.
The gross contribution from the conduit contributor should be reported on the correct line item schedule A of the report as outlined above.
The corresponding processing fees for each contribution should be reported as a disbursement on schedule B as an operating expense. For candidates and committees filing on Form 3, fees should go on line 17. For PACs and Party Committees filing on form 3X fees should be reported on line 21b.
Here is the reporting information you need to report processing fees. Please note this information is for processing fees only and not for vendor fees.
Name: WinRed Technical Services LLC
Address: 1776 WILSON BLVD, Suite 530 ARLINGTON, VA 22219
All processing fees are disbursed to WinRed Technical Services LLC
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Other Types of Fees
WinRed spells out each type of fee in the payout report and payout details view. It is important to check these fees because they are reported differently.
Vendor Fees: If a vendor and a candidate or committee have a fundraising commission arrangement, you can use WinRed's bill-pay feature to automatically collect payment. Think of it as WinRed providing a bill pay service to your candidate. The candidate is paying the fees to the agency as a disbursement, NOT WinRed. You will see extra columns on your payout report for the agency name and the amount.
Merchandise Fees: If you are using WinRed's on demand merchandise program to easily sell merchandise with no upfront cost, you will also see added columns on your payout reports that show the cost of merchandise. These are not credit card fees, but are for the cost of goods sold and reportable to WinRed Technical Services LLC.
Accessing Payout Information
A complete write up of how to access your donor information can be found here.
As always, if you need any help please contact the WinRed team using the chat icon at the bottom right of your screen!