Bundling, Conduits, and Joint Fundraising: Federal Rules for Political Fundraisers

Terms Worth Knowing

Bundling

Someone gathers checks from several people and delivers them to a committee. Disclosure duties can attach to that person depending on who they are and how much they bring in. Check the FEC's lobbyist bundling disclosure rule (11 CFR 104.22) and the current dollar threshold before you let anyone collect checks on your behalf; the threshold is adjusted for inflation, so read the number off fec.gov rather than a memo from last cycle.

Conduit or intermediary

Passing someone else's money under the wrong name hides the real source and is barred (52 U.S.C. 30122). Earmarked money that legitimately passes through a conduit is a different case: the actual donor still appears on the report, and so does the person who forwarded it.

Joint fundraising

More than one committee shares a raise. You need a written joint fundraising agreement with the allocation formula, solicitations that say who gets what, and books that prove the split happened the way the agreement said it would.

Operations That Save Filings

• Sign the agreement before the event: the math for the split, who pays the vendors, who signs the checks.
• Print the allocation in every solicitation, naming each committee and the share each receives.
• Keep employer and occupation on every intake form so itemized receipts don't come back as best-efforts letters.
• Move money out of the joint account promptly. Idle balances make reports ugly and raise the question of who really controlled the funds.

Why Auditors Care

Wrong splits and quiet bundling show up again and again in enforcement. Treat this as front of house work, not something finance fixes alone afterward. Our 2026 FEC compliance checklist covers the filing side; the FEC's contribution limits page has the hard money caps.

Joint Events Without Mixed Up Books

Splits are only as clean as the intake data. In FundraiserMax the bundler sits on the contact record next to employer and occupation, so the itemized receipt and the bundler credit come off the same row. Record the event under the joint committee's campaign in Events, then close the batch before the filing clock runs out.