The Bernie Sanders campaign’s most recent Federal Election Commission filing ran over 85,000 pages. A few weeks earlier, the Sanders campaign had received a 43 page letter from the FEC asking to make sure certain donors have not contributed over the legal limit. This week they received a 95 page letter with a similar inquiry. When people worry about excessive contributions, they often conjure up images of large dollar donors trying to stack campaigns with tens of thousands of dollars. In fact, for campaigns the size of Sanders’s, small donors pose an even more difficult compliance problem to track, remedy, and refund. In many respects, large donors are easier to track because they give one or a few large donations. The names are usually identifiable — donors that are politically active with their money. They have contributed before. They know the contribution limits well and often have multiple people double-checking everything — themselves, fundraisers, campaign finance staff and then the treasurer or compliance firm.
Bernie Sanders has done a tremendous job raising money from small dollar donors. The New York Times cites the campaign’s number of 1.3 million donors. That explains why the campaign’s (Bernie 2016) Year End FEC report is almost 100,000 pages long. By contrast, Hillary Clinton’s Year End Report was about 35,000 pages long.
When a candidate like Bernie Sanders is bombarded with such a high volume of contributions, the campaign’s treasury department is tested in ways that it may not have anticipated with potentially inadequate staff or an inadequate system.
The first piece to any treasury operation is a sound, technology based system of capturing contribution information. The system needs to be able to handle a high volume of contributions, being received at a rapid pace.
Equally important is a highly skilled staff that prides itself on attention to detail. The measure of systems data and accuracy depends solely upon the accuracy of the data that is entered. Details matter. The spelling of unusual names. Middle initials. Employer occupation information. Capturing this information is sometimes easier said than done, since oftentimes donor forms are plagued with illegible and inscrutable handwriting. While perfection is usually impossible to obtain, a dedicated staff of problem solving data enthusiasts that lean as far as possible in the direction of perfection will minimize data errors.
Campaigns of this size need a pro-active written process that seeks to aggressively clean and maintain data. The staff should clean the data early, often, and on a rolling basis as the contributions are accepted. Excess contributions will not be caught quickly enough and there won’t be enough time for spousal reattributions if this is delayed.
If the data is good and the system is good, compliance becomes much easier. If the data is sound, you can determine who is who. If you know who is who (i.e. Adam Smith is a different person than Adam B. Smith), a campaign can assess if any donor is over federal limits. If a donor is not over the federal limits, you can rest easy as long as the contribution is reported properly to the FEC. Generally speaking, if the donor is over a limit, you must refund or reattribute to a consenting spouse within 60 days.
It is hard to tell how good a treasury operation is from the outside. But the FEC is adept at testing through its requests for additional information. Time will tell if Bernie’s treasury operation is on par with his current popularity with Democratic voters.