PAC Audits – Legal and Operational

04 Dec, 2012

PAC & Campaign Finance

PAC Audits – Legal and Operational

Why does your PAC need a legal audit?
Any responsible company knows it must audit its PAC in order to protect itself and its officers from corporate and personal liability.  Many of the laws in this highly regulated area are criminal and in recent years the government has focused on compliance within corporations and associations.

  • Learn by example- Companies that have experienced scandal are now full proponents of audits
  • Transparency through a legal audit will help you to grow your PAC
    • Good buy-in for members/potential members – you can tell them with a straight face that you are adhering to all laws/regulations.  The results from your audit show your compliance.
    • Good buy-in for senior management- it is a sign that you’re running solidly
  • Don’t just do a tax-style audit as they miss some of the legal issues with PACs
    • Many vendors/consultants/lawyers are trained to handle comprehensive legal audits that look at FEC and applicable state laws

Why does your PAC need an Operational or Self- Audit (not tax/FEC specific)?
This type of audit may not be needed for legal purposes but it is just as important.  Evaluating the policies and procedures of your PAC will help you to become more effective and efficient.  It will also give your PAC more credibility both internally and externally and help you gain buy-in from all the necessary players.


  • Having a PAC Board is good for buy-in
    • It should be representative of your organization
    • Senior management representation isn’t enough
    • Include representatives from every department or division
    • Explore having a single board that helps fundraise and make disbursement decisions or one board and a contributions committee
    • Rotate terms of service to help bring in new faces
    • Serving on the board should be seen as an honor and benefit of membership
  • Bylaws are just as important- make them:
    • Simple
    • Changeable
    • Easily accessible to everyone
    • Basic- they should only cover basic tenets of the structure and decision making in order to keep the process fluid
  • Candidate Contribution Criteria are key
    • Use as a buy-in to members/prospects – “this is how we determine where your money goes”
    • Creates an easy, amicable way to say NO to a candidate
    • Keep your criteria fluid and loose
  • Mission Statements show the PAC’s path

Know Your Audience

  • Survey your eligibles
    • What do they know?
    • What are their misconceptions?
    • What will motivate them?
  • Focus groups to determine sentiment around PAC
  • Use your Board as eyes and ears among the staff
  • Give opportunities for feedback everywhere
  • It’s not about you, but your members


  •  You MUST educate everyone about the process before you solicit
    • Explain why you have a PAC and how it work
  • Do you have educational goals for your PAC not tied to fundraising?
  • Is it easy for eligibles to find/access info about your PAC?
  • Is your website easy to navigate?
  • Create an FAQ sheet on your website or as a handout to answer questions before they’re asked
  • Transparency is the key to success

Solicitation Plan

  • Have clear, achievable goals
  • Determine what type of solicitation works within your culture
  • Democratization helps with buy-in
  • Make the plan available to everyone
  • Include some information/eduction-based events to draw people in
  • Options other than financial goals:
    • Increase membership numbers
    •  Have goals by region/department
    • Look at retention/attrition rates
    • Keep track of PAC website hits
    • Grow your number of PAC volunteers


  • They must be trained on legal issues, fundraising, and have copies of sample materials
  • Have well liked, respected people who are good at public speaking
  • Do they have a game plan?
  • Have a resource they can turn to with questions (binder, website, training packet, etc.)
  • Create a team they can turn to with other peer solicitors
  • Are they reporting back to you with progress/issues?
  • Reward everyone who helps you
    • Special rewards/recognition for top performers

Solicitation Letter

  • Brief – one page or less
  • Short paragraphs
  • To the point
  • Highlight key words or messages
  • Include benefits of membership
  • Avoid technical speak unless targeting an audience that often uses this style of verbiage
  • Tailor the message to your audience
  • Answer “What’s in it for me?”
  • Make an ask
  • The signature on it is important- person should be senior, trusted, liked, and respected

PAC Presentations

  • Less is more with PowerPoint
    • Should supplement the presentation
    • Never read off of slides
    • FEW words per slide
    • Use pictures, graphs, chart
  • Messages should all be positive
  • Mention PAC at every possible meeting – get on every
  • Senior management should open every PAC meeting to show their support
  • External competition motivates people
    • Charts comparing us v. competitor v. top PACs


  • Q&A posts
  • Quizzes, games, etc.
  • Member spotlight
  • Education should be throughout your campaign
  • Branding your program is key – brand everywhere
  • Make communications interactive
  • Pictures
    • From PAC events
    • Members with politicians
  • Push benefits where possible
  • Use members as guest writers/reporters
  • Include your web address on everything
  • Quizzes, games, etc.
  • Member spotlight

Member Benefits

  • Thank everyone – a thank you note goes a long way
  • Recognition
    • They want their boss to know
    • CEO can attend PAC events
  • Participation
    • Serve on PAC Board
    • Recommend candidates
    • Volunteer at events
    • Guest write for newslette
  • Incentive Clubs
  • PAC Match
  • Special communications


  • Review the process after every solicitation
  • Ask members for their input
  • Benchmark
  • Think outside the box

Kristin Brackemyre
Senior Director, Public Affairs Practice
202.787.5969 | email