Instructions

We follow political money from the public record: who gave to a candidate, PAC or party committee, what that committee spent, who paid for independent expenditures, and when all of it happened relative to the official acts the money might be thought to touch. Everything here is readable without compulsion: FEC filings, state disclosure databases, roll-call records and hearing calendars. The discipline that makes the work publishable is the timing test (§5) and the language rules (§6).

Division of labour. corporate-intelligence-investigator keeps political-donation profiling inside a company dossier (its “timeline discipline” note). This skill owns the FEC-schedule method and the timing discipline; a company dossier that needs either points here.

Use a different skill when:

• the money is lobbying spending or lobbyists’ LD-203 contribution reports — lobbying-fara-disclosure-analyst;
• the question is federal contracts, grants or exclusions — federal-spending-contracts-investigator;
• the question is a member’s own financial disclosures, gifts or ethics rules — congressional-ethics-and-disclosure;
• the task is a member’s whole dais row for one hearing — member-intel-profile, whose §5 FEC

donor field uses this skill’s method;

• the task is who owns the LLC that gave — corporate-intelligence-investigator.

1. Scope

Field	Example	Why
Recipient(s)	a member’s principal campaign committee and leadership PAC	Money reaches a member by more than one committee
Official acts	roll-call votes, hearings, markups, letters	The “linked vote/hearing” column in §8
Window	the election cycle, plus a fixed span either side of each act	Set it before looking at the data (§5)
Donor class	a PAC, an industry’s employees, one family	Decides whether §3 and the inclusion gate run
Comparison set	every member of the same committee, both parties	Partisan symmetry (Safety)

2. Federal filings: Schedules A, B and E

Committees file with the FEC; every filing and its itemized schedules are public on fec.gov.

Schedule	What it lists	Fields we use
A itemized receipts	Each contributor whose contributions aggregate over $200 in the calendar year (PACs, parties) or election cycle (candidate committees)	Name, address, occupation, employer, date of receipt, amount, aggregate
B itemized disbursements	The committee’s payments	Payee, date, amount, purpose; transfers to other committees
E independent expenditures	Spending that expressly advocates for or against a candidate, not coordinated with them	Payee, date, amount, the candidate supported or opposed, support/oppose

Committee types we read.

• Leadership PAC: a political committee directly or indirectly established, financed,

maintained or controlled by a federal candidate or officeholder, that is not their authorized committee or affiliated with it (11 C.F.R. §100.5(e)(6)). A member’s leadership PAC is a second recipient: search it with the principal campaign committee, and read its Schedule B for the members it funds.

• Joint fundraising committee (JFC): committees raise money together through a joint

fundraising representative that collects, pays costs, and splits net proceeds by an allocation formula stated in the solicitation (11 C.F.R. §102.17). Each participant reports its share as a transfer-in and itemizes the original donors as memo entries on Schedule A, dated the day the representative received the money. Read the memo entries, not the transfer, to see who gave; never count a JFC receipt and its memo entries twice.

• Independent expenditures: political committees report them on Schedule E; other persons

whose independent expenditures aggregate over $250 for an election file their own report. Spending close to an election is also reported on 24- and 48-hour schedules (52 U.S.C. §30104(g)).

Data. api.fec (scripts/lib/osint_api/fec.py, FecClient, host api.open.fec.gov) is entity search only today: candidates (--category people) or committees (--category company), returning IDs, names and first-file dates, with links to www.fec.gov: scripts/ca_research.py api api.fec "" --category company --agent . Transaction-level queries take --extra schedule=a, b or e. If one returns nothing, use the committee ID and read the schedules on fec.gov’s own pages or bulk files, recording each row’s filing URL (the image or the FEC transaction page).

Reading rules.

• A contribution is dated on receipt by the committee, not when written. Quarter-end and

pre-election deadlines bunch receipts; that bunching is a calendar effect, not a signal.

• Refunds and redesignations appear as later negative or memo entries. Net them before any

total.

• Employer and occupation are the donor’s own words. Group donors by industry only as a

labelled estimate, and never place a donor in an industry their filing does not state. Use the latest amended report and say so.

3. Dark-money vehicles: what is and is not disclosed

Vehicle	What the public record shows	What it does not show
501(c)(4) social-welfare group making independent expenditures	Its own independent-expenditure reports; contributors who gave for the purpose of furthering an independent expenditure	Its general donors, which are not filed with the FEC
Super PAC (independent-expenditure-only committee)	Schedule A donors like any PAC, including a 501(c)(4) or LLC as donor	Who funded that 501(c)(4) or LLC
LLC giving to a committee	The LLC as contributor on Schedule A when over $200	Its members, unless a filing or a state registry names them

The disclosure rule for non-committees comes from 52 U.S.C. §30104(c): contributions over $200 made for the purpose of furthering an independent expenditure. In CREW v. FEC, 316 F. Supp. 3d 349 (D.D.C. 2018), the court vacated the narrower FEC regulation (11 C.F.R. §109.10(e)(1)(vi)), and the FEC issued guidance on what such filers must now report. Cite the guidance in force on the filing date.

An opaque donor is a gap, not a finding. We report that a 501(c)(4) or LLC gave and that its funders are not disclosed. Making a contribution in the name of another is unlawful (52 U.S.C. §30122); whether an LLC was a conduit is for the FEC or a court, not us. Ownership research on the LLC is corporate-intelligence-investigator‘s.

4. State campaign finance (method)

Each state runs its own disclosure system, with its own thresholds, report schedule and database. We do not keep a per-state table; we find the current rule each time.

1. Identify the filing office from the state’s own election code: usually the secretary of

state, an ethics commission or a campaign-finance board.

1. Record the state’s itemization threshold and reporting calendar from that office’s current

guide, with its URL and date.

1. Search the office’s database by candidate and committee; download the filing, not a

summary page.

1. Use multi-state aggregators (FollowTheMoney.org, now part of OpenSecrets — verify) as leads,

then confirm each row in the state filing. Match donors across records only on name plus address or employer.

5. The timing test

This extends the donations-versus-committee-votes use case (UC-2) and the PAC-plus-vote-timing worked example (EX-3): sequence, not causation.

Official acts.

• Roll calls: api.house_votes (host clerk.house.gov) and api.senate_votes (host

www.senate.gov), one roll call per call, no free-text search: scripts/ca_research.py api api.house_votes "" --extra congress= --extra session= --extra roll= --agent .

• Hearings and markups: the committee’s calendar or Congress.gov meeting records; api.congress

takes a meeting subject by chamber and date window (--extra chamber=… --extra from_date_time=…).

• Member context (committee seats, prior votes): member-intel-profile.

Procedure.

1. Pre-register the window (for example, 30 and 90 days either side of each act) before

pulling contributions. Never widen it after seeing the data.

1. List every itemized receipt from the donor class to each recipient across the whole cycle,

not only inside the window.

1. For each act, compute the gap in days (act date minus receipt date; negative means after).
2. Baseline. Compare in-window receipts with the same donor’s pattern across the cycle and

with the calendar effects in §2. A donor who gives every quarter gives before every vote.

1. Symmetry. Run the same window, donor class and acts for every member of the committee,

both parties, and report all of them, including members who received nothing.

1. Alternatives. Write down the innocent explanations the record supports (a scheduled

fundraiser, a quarter-end deadline, a long-standing donor, a vote along party lines).

1. Stated position. Check whether the member’s position predates the money (prior votes,

statements). Money that followed a settled position is evidence of support, not persuasion.

6. Language rules

Write	Never write (absent a charge or a finding)
“Contributions preceded the vote”	“bought the vote”
“The timing coincided with the hearing”	“paid for”, “in exchange for”
“The PAC gave $X in the 30 days before the markup”	“quid pro quo”, “bribe”, “pay-to-play”
“The donor’s funders are not disclosed”	“laundered”, “straw donor”
“We found no contributions from …” (with the window)	“clean”, “untouched by”
“A complaint alleges …” / “The FEC found reason to believe …”	“was found guilty”, “violated” (before a final finding)

7. Complaint filing: the FEC process, and the CLC and CREW models

Anyone who believes a violation of federal campaign-finance law occurred may file a complaint with the FEC (52 U.S.C. §30109(a)(1); 11 C.F.R. §111.4).

Requirement	Detail
Form	In writing, to the FEC’s Office of General Counsel
Complainant	Full name and address of the person filing
Oath	Signed, sworn to and notarized; the notary’s certificate says “signed and sworn to before me” or equivalent
Content	Identifies each respondent and the facts alleged; separates personal knowledge from information and belief; attaches supporting documents
What happens	The FEC assigns a Matter Under Review (MUR) number and notifies each respondent, who may respond
If dismissed or not acted on in 120 days	A party aggrieved may petition the U.S. District Court for the District of Columbia (52 U.S.C. §30109(a)(8))

The models. Campaign Legal Center (CLC) and Citizens for Responsibility and Ethics in Washington (CREW) file sworn administrative complaints built from public filings, publish them with exhibits, and use §30109(a)(8) when the Commission dismisses or does not act; CREW’s complaint against Crossroads GPS reached the FEC on remand after CREW v. FEC (2018). We explain the model; we do not file.

A citizen files in their own name. A complaint is sworn: the filer attests to it. We supply the complaint-readiness checklist (Appendix) and route the reader to counsel. We never draft it as if from an agency, never use FEC or committee wording, and never file for a reader.

8. Outputs

• Contribution-timing table: one row per receipt or independent expenditure in scope:

Date	Donor	Recipient	Amount	Schedule	Linked vote/hearing	Gap (days)	Source

Donor is the filed name, or “individual contributors (aggregate)” where §Safety bars a name. Schedule is A, B, E or the state form. Source is the filing URL; a row without one is cut.

• Symmetry summary: the same counts and totals for every committee member, both parties,

and one paragraph on what the pattern does and does not show.

• Complaint-readiness checklist: Appendix.

Sources

Primary:

• FEC, Campaign Guide for Congressional Candidates and Committees —

https://www.fec.gov/resources/cms-content/documents/policy-guidance/candgui.pdf — and Form 3X instructions — https://www.fec.gov/resources/cms-content/documents/policy-guidance/fecfrm3xi.pdf — confirmed via ca_research.py 2026-10-31: the $200 itemization threshold (calendar year for PACs and parties, election cycle for candidate committees) and the itemized fields.

• 11 C.F.R. §100.5(e)(6), leadership PAC — https://www.fec.gov/regulations/100-5/CURRENT —

confirmed 2026-10-31.

• 11 C.F.R. §102.17, joint fundraising; FEC, Joint Fundraising —

https://www.fec.gov/updates/joint-fundraising-2011 — confirmed 2026-10-31: transfer-in plus memo Schedule A entries dated on the representative’s receipt; allocation formula in the solicitation.

• 52 U.S.C. §30104(c), (g); FEC guidance after CREW v. FEC, 316 F. Supp. 3d 349 (D.D.C. 2018) —

https://www.fec.gov/updates/fec-provides-guidance-following-us-district-court-decision-crew-v-fec-316-f-supp-3d-349-ddc-2018 — confirmed 2026-10-31: the $250 non-committee threshold and the vacated §109.10(e)(1)(vi).

• 52 U.S.C. §30109(a)(1), (a)(8); 11 C.F.R. §111.4; FEC, *Guidebook for Complainants and

Respondents* — https://www.fec.gov/em/respondent_guide.pdf — confirmed 2026-10-31: written, signed, sworn and notarized; MUR and respondent notice; the 120-day petition.

• 52 U.S.C. §30111(a)(4) (use of contributor information) and §30122 (contributions in the

name of another) — https://www.law.cornell.edu/uscode/text/52/30111 and https://www.law.cornell.edu/uscode/text/52/30122 — statute text, common doctrine.

• Practitioner, leads only: CLC (https://campaignlegal.org) and CREW

(https://www.citizensforethics.org) complaint archives; the OpenSecrets–FollowTheMoney merger is [U].

Cross-references

• corporate-intelligence-investigator — company dossiers keep donation profiling; LLC

ownership research.

• member-intel-profile — the dais row’s FEC donor field uses §2 and §5.
• hearing-prep-and-analysis — hearing dates and transcripts for the linked-act column.
• network-analysis-specialist — graphs donors, committees and JFC participants.
• patriot-private-citizen-inclusion-gate — required before naming any non-official donor.
• claims-integrity-audit and malice-evaluator — gate publication of any timing claim.
• lobbying-fara-disclosure-analyst — lobbying, LD-203 and FARA money.
• federal-spending-contracts-investigator — federal contracts and grants.
• congressional-ethics-and-disclosure — members’ financial disclosures and ethics rules.

Safety

• Not legal advice. Whether conduct violates federal or state campaign-finance law is for

the FEC, the state agency, the courts and counsel. Route readers to qualified counsel, especially before they swear to a complaint.

• A donation pattern is not a quid pro quo. Timing is reported as sequence (§6); “bought”,

“paid for” and “quid pro quo” appear only when quoting a charge or finding.

• Allegation vs. finding vs. charge. A complaint is an allegation; a “reason to believe”

vote is not a finding of violation; a conciliation agreement is not a conviction.

• No impersonation of government authority. Complaints go out in the citizen’s own name;

never FEC or committee wording, letterhead or the language of compulsion.

• Partisan symmetry. Run the timing test on both parties’ members of the committee and

publish all results (§5 step 5). A one-party table is not an output of this skill.

• Small donors are private persons. Below the itemization threshold there are no names,

and we never infer any. Itemized individuals who are not officials, candidates or public figures are named only after patriot-private-citizen-inclusion-gate passes; otherwise report them in aggregate.

• Contributor data is not for solicitation or commercial use (52 U.S.C. §30111(a)(4)). We

never compile donor contact lists from FEC records.

• Estimates labelled. Industry groupings, inferred totals and anything resting on an

unconfirmed date are labelled.

Appendix: complaint-readiness checklist

For a reader deciding whether to file. Every box is a question for the reader and their counsel, not a step we take for them.

• [ ] Respondent(s) identified by committee ID, candidate ID or legal name.
• [ ] Each alleged fact tied to a document: the filing URL, transaction or image page, or a

dated public record.

• [ ] Facts within personal knowledge separated from those on information and belief, with

the source of the belief stated.

• [ ] The statute or regulation the reader believes was violated, read in full.
• [ ] Innocent explanations from §5 step 6 considered and addressed.
• [ ] Timing claims stated only as sequence (§6).
• [ ] Private persons not named unless the inclusion gate passed.
• [ ] Complainant’s full name and address; complaint signed, sworn and notarized.
• [ ] Filed in the reader’s own name; no agency or committee wording.
• [ ] Counsel consulted; the reader knows a sworn complaint carries legal exposure.
• [ ] A copy kept, with the MUR number recorded once assigned, and the 120-day date noted for

§30109(a)(8).