Getting a tax ID and bank account
Political committees must establish a bank account. This is required for many reasons, including helping keep committee funds separate from personal funds. This account will be used to deposit receipts and make disbursements. The account must be at one of the following:
- National bank
- State bank
- FDIC- or NCUA-insured institution
The name and address of the bank must be listed on the committee's Statement of Organization (Form 1).
Banks require you to have a taxpayer identification number to open an account. Political committees may obtain an “Employer Identification Number” online or by completing IRS Form SS-4. For questions about obtaining a taxpayer identification number, call the Internal Revenue Service, 1-800-829-3676.
All bank accounts must be opened in the name of the committee using the committee’s Employer Identification Number. Bank accounts should never be opened in the name of an individual using an individual’s Social Security Number.
Additional information for specific committees
PACs sponsored by corporations and labor organizations
A separate segregated fund (SSF) must use its own funds to pay taxes on interest income. Federal and state taxes on SSF funds are not considered administrative expenses payable by the connected organization.
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Opening a Bank Account For Your Political Campaign
Raising money and managing expenses is an critical part of the election process. Opening a campaign bank account is a first step in establishing a viable political campaign.
A bank checking account serves several purposes. It allows you to accept political donations and contributions from supporters, and to make campaign purchases. To do all this, you will want to know how to open a bank account for a political campaign.
- Open your political campaign checking account as early as possible. Campaign finance laws in many states require that a campaign bank account be established in order to legally deposit political donations. The earlier you have an account, the sooner you can start raising seed money.
- Prior to opening a campaign bank account, you may need to establish a political campaign committee with your local county Board of Elections. The name you use for your campaign committee is the name you will use to open the bank account. The bank will require committee paperwork along with personal identification.
- Open an interest-free checking account rather than an interest-bearing savings account. Any interest earned on a campaign bank account must be reported in your finance reports. Considering how little banks pay in interest, the small amount of money to be gained is hardly worth the additional effort required by your committee treasurer to report.
- A candidate’s personal funds can be used for campaign purchases before a campaign bank account is established. Those purchases are generally treated as an in-kind donation or as a personal loan. Once the campaign is underway, the treasurer should handle the political funds and keep track of income and expenditures. For larger campaigns, it may be a good idea to hire an accountant.
- You should keep detailed records of every account transaction for financial filing requirements. Keep statements, records and receipts in a safe place. They should be held indefinitely in case questions later arise as to your campaign finances. Whatever you do, do not co-mingle funds between accounts.
So many rules… Local, state and federal…
These guidelines also apply for a political party bank account and political action committee bank accounts. If you accept donations or hold fundraisers, you will need a place to deposit your money. Most traditional banks, savings and loan association or credit unions can handle accounts for political campaigns and fundraising needs. You’ll want to check with them for eligibility first, of course.
- Large banks like Chase and Bank of America can certainly handle government banking needs.
- If you prefer a more personal touch, check with your local regional bank.
- Credit unions may also be able to handle election accounts, if that type of account is permitted by charter and policies.
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EIN numbers for political campaigns
Federal campaigns and committees are required obtain an Employer Identification Number (EIN). This nine-digit number is issued by the IRS for identification purposes. It is similar to EIN numbers assigned to businesses and corporations. This number is required to open a campaign bank account.
- A political organization must have an EIN, even if it does not have any actual employees.
- Don’t apply for an EIN until your organization is legally formed.
- Never open a political bank account in the name of an individual or with an individual’s Social Security Number. Use the organization’s EIN.
If you are starting a political action committee (PAC) and opening a checking account, the PAC must be first approved by the Federal Election Commission (FEC). Under these requirements, you will need an address for the PAC and a designated treasurer to handle the funds. There are additional compliance guidelines for any fund transfers that you make.
One question that tends to come up is whether a candidate needs to establish separate bank accounts for both the primary and general election. This can depend on whether your contribution limits apply per election. For example, if the contribution limits are different then fundraising for the primary election and fundraising for the general election are separate. If this is the case, a candidate may need to establish separate bank accounts for each election.
Campaign banking information and requirements do vary. As always, be sure to follow your local election laws to the letter. Campaign accounts for state and local office are governed by state law.
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How to Open a Checking Account for a Political Committee
Congress reformed the rules for political fundraising and campaign financing back in 1971, and it has made further changes in the half century since then. If you're involved in fundraising or financing for a candidate, you need to know the rules and follow them. The penalties for breaking the law can run as high as a five-year prison stretch.
TL;DR (Too Long; Didn't Read)
First, file with the IRS to get an employer identification number for your political committee. When you go to the bank, use the EIN the way you do your Social Security number on your own accounts. Open the account in the name of the committee, never your own name.
Types of Committees
When it comes to campaign finance, one important committee is the political action committee. Political action committee money has become increasingly prevalent in elections, as PACs can raise money to donate to campaigns and parties. PACs typically represent business or labor organizations or groups organized around a cause, but some politicians form PACs to help other candidates in their party.
Candidates' campaigns also have political committees to handle the campaign finances. These committees work with the campaign finance director and campaign treasurer to meet the campaign's financial goals.
Rules for campaign finance vary in different states and between state and federal races. Whatever type of committee you're interested in forming, however, will need a separate bank account. Depositing political action committee money in your own account is illegal.
EIN Number for a Political Campaign
When you're opening an account for a PAC or other political committee, you're representing an organization, not an individual. Just as you'd give the bank your Social Security number, you'll need an employee identification number for political campaign bank accounts.
To apply for an EIN, you submit IRS Form SS-4. You'll need to provide the name of the committee, the mailing address, the person in charge and other data. Once the IRS reviews the application, it will issue an EIN number for the political campaign committee or PAC, which you'll include on the bank account paperwork.
Opening the Account
Once you've selected the best bank account for a political campaign or for a PAC, open it as soon as possible. You want the account up and running so you can start depositing donations. If you're working for a candidate, the candidate can usually make small purchases and get reimbursed once the account is established.
If you open an interest-bearing account, you'll have to report the interest earned along with political action committee money. That's a lot of paperwork for very little money, so an interest-free account usually makes more sense.
Keep Up the Paperwork
The SS-4 that gets you the EIN for the political campaign account is only the beginning of the paperwork you'll have to track. You must deposit every donation your PAC or campaign receives and record the name and address of most donors plus other information. You'll also need to report transfers to other accounts, any campaign or political action committee money you spend and on what you spent it.
You'll have to make regular reports providing all the campaign finance information. Depending on the office for which you're running and where you're running, local, state and federal officials may all require some paperwork.
Other Ways to Receive Donations
With this being the internet age, there are many more ways to receive donations than checks. You can solicit donations on the campaign or PAC website, for example, set up a button for PayPal political donations or go with one of the online money services that specializes in campaign funding.
Online and PayPal political donations still have to comply with all campaign finance laws. You'll need an online account for the campaign, not yourself, and you'll need to obtain relevant information about the donors.
Fraser Sherman has written about every aspect of business: how to start one, how to keep one in the black, the best business structure, the details of financial statements. He's also run a couple of small businesses of his own. He lives in Durham NC with his awesome wife and two wonderful dogs. His website is frasersherman.com
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Political Activities and Public Policy Engagement
Bank of America Corporate Political Contributions Policy Statement
This statement sets forth basic principles concerning the company's stance on political contributions and activities. Together with our other policies and procedures, included in our Code of Conduct and Political Action Committee (PAC) governance documents, it guides our company's and employees’ approach to political involvement. By following this statement and our other policies and procedures, by adhering to applicable laws and regulations, and by applying sound judgment to political activities, we can further demonstrate our commitment to becoming the world's most admired company.
As a global financial services company, Bank of America must be - and is - committed to participation in the political process in a manner that is consistent with solid corporate governance practices and in compliance with legal requirements. It is in this spirit that we encourage our employees to be active in our democratic society and provide them opportunities to do so through the PAC program, when legally permissible, and other voluntary activities benefiting their communities.
Bank of America Political Action Committee Program
Bank of America maintains a PAC program to allow the company's employees to be engaged in the political process. Where permitted by applicable law, Bank of America underwrites the costs of administering the PAC program, but is prohibited from directly contributing to the PACs. The PAC program is funded only through employees' voluntary personal contributions. These contributions are reported to relevant federal, state, and local campaign finance agencies as required by law, and are available here:
To fulfill their mandate for leadership, integrity, and effectiveness, Bank of America's PAC program administrators adhere to established governance and compliance procedures that ensure consistent funding decisions and compliance with all campaign finance laws and regulations applicable to the financial services industry.
Contributions from the PAC program support candidates, parties, or committees whose views on specific issues are consistent with Bank of America's interests. The PAC takes into consideration whether the candidates represent the communities we serve and whether they support policies and initiatives that are important to the company. These include, but are not limited to, policies that impact our business and industry, our employees, and the communities we serve. PAC program contributions are made without regard to the private political preferences of the company's Executive Management Team or any other company executive.
Trade Association Memberships
Bank of America often shares interests with groups that advocate and shape public policy positions on issues that are important to the financial services industry and the global business community. We believe that we are better when we are connected to others as we work to bring about consensus and advocate for issues of importance to us and the communities we serve. However, our membership in and payments to specific trade associations or other organizations do not mean that we endorse every position or issue that these organizations may support. We often voice our differing view on significant issues to such organizations directly or in other ways and continually evaluate the overall benefit of our continued memberships. Our principal memberships in financial industry and certain other trade associations that receive more than $25,000 from us annually are listed below.
- American Bankers Association (and affiliate state bankers associations)
- American Financial Services Association
- Bank Policy Institute
- Business Roundtable
- Consumer Bankers Association
- Electronic Payments Coalition
- Financial Services Forum
- Futures Industry Association
- Institute of International Finance
- International Swaps and Derivatives Association
- Loan Syndication and Trading Association
- Mortgage Bankers Association
- National Business Coalition on E-Commerce & Privacy
- National Association of Affordable Housing Lenders
- New England Council
- Partnership for New York City
- Real Estate Roundtable
- Risk Management Association
- Securities Industry and Financial Markets Association
- Structured Finance Association
- U.S. Chamber of Commerce (and affiliate state chambers of commerce)
When Bank of America makes payments to these organizations, including membership fees and dues, we restrict the organization from using the funds for any election-related activity at the federal, state, or local level, including contributions and expenditures (independent or otherwise) in support of, or opposition to, any candidate for any office, ballot initiative campaign, political party committee, or PAC.
Public Policy Engagement
We do regularly communicate with government policymakers, public officials and regulators at the federal, state and local levels in order to protect and advance the long-term goals and interests of our company, customers, stockholders, and economy. We also monitor legislative activities, analyze policy and regulatory trends, comment on policy and regulatory proposals and support and promote advancement of public policies. We do not engage in grassroots lobbying, which means we do not directly communicate with the general public advocating that it take action with respect to specific legislation. In 2020, 2019, and 2018, Bank of America Corporation spent $1,990,000, $1,930,000, and $2,790,000, respectively, on federal lobbying expenses which includes employee time spent on lobbying, and associated travel and overhead expenses, as well as payments to external consultants and lobbyists and trade association dues used for lobbying. These federal lobbying expenses are publicly disclosed on quarterly reports filed with the Clerk of the U.S. House of Representatives and Secretary of the U.S. Senate pursuant to the Lobbying Disclosure Act of 1995, as amended, and can be found here.
Q1 2020Q1 2019Q1 2018Q2 2020Q2 2019Q2 2018Q3 2020Q3 2019Q3 2018Q4 2020Q4 2019Q4 2018
Corporate Political Contributions
Bank of America and its affiliates do not make corporate contributions to candidates for public office or political parties, and do not use corporate funds to make independent political expenditures.
In appropriate circumstances, Bank of America may make contributions to non-candidate organizations such as political convention host committees or inaugural committees, to the extent permitted by applicable law. Bank of America discloses an itemized list of the recipients and amounts of such contributions as required by law. In 2020, Bank of America made contributions to the following groups organized under Section 527 of the Internal Revenue Code:
|Bank of America donations to 527 organizations|
|527 Organization Name||Amount|
|Democratic Governors Association||$50,000|
|Republican Governors Association||$50,000|
|Republican Attorneys General Association||$25,000|
|Democratic Attorneys General Association||$25,000|
|Democratic Legislative Campaign Committee||$25,000|
|Republican Legislative Campaign Committee/Republican State Leadership Committee||$25,000|
It is the policy of Bank of America that any payments made to 527 organizations shall only be used for operational and administrative purposes and not to be used to support or oppose any candidate for U.S. federal, state, or local office, or to support or oppose any ballot initiatives. Additionally, payments to 527 organizations may not be transferred to any federal, state, or local PAC, any other form of political committee, or any other entity for the purpose of making contributions or expenditures, independent or otherwise, to support or oppose any candidates for U.S. federal, state, or local office, or to support or oppose any ballot initiatives.
Additionally, Bank of America may occasionally make contributions to groups organized under Section 501(c)(4) of the Internal Revenue Code, including but not limited to ballot measure committees and other social welfare organizations, but does not do so to support the election of any specific candidate or for the purpose of funding specific expenditures or communications. In 2020, Bank of America made such contributions to the following 501(c)(4) organizations at the direction of the company’s Public Policy Department:
|Bank of America donations to 501(c)(4) organizations|
|501(c)(4) Organization Name||Amount|
In 2020, Bank of America made the following contributions to ballot measure committees at the direction of the company’s Public Policy Department.
|Bank of America donations to ballot measure committees|
|No on Prop 15- Stop Higher Property Taxes and Save Prop 13(CA)||$100,000|
|Portland Business Alliance-Portland Metro 26-218||$10,000|
|El Paso for Education Excellence (TX)||$1,000|
When Bank of America makes any of these contributions, it does so to promote the interests of the company and without regard to the private political preferences of its executives. Consideration is given to entities that support policies and initiatives that are important to the Company. Bank of America forbids the use of its facilities, equipment, or other assets for political purposes without consent and to the extent prohibited by applicable law.
Archive of Corporate Contributions
Employee Political Contributions and Activities
Bank of America welcomes the informed participation of its employees in governmental, regulatory, and elective processes. Bank of America respects the rights of its employees to support issues and candidates of their choosing, and employees may elect to make personal political contributions, either directly or through company-sponsored or other political committees as permitted by applicable local, state, and federal laws, as well as the laws of any applicable jurisdiction outside of the United States. Employee contributions are not reimbursed by Bank of America.
Additionally, Bank of America employees are welcome to participate in political activities on their own time and in accordance with their individual desires and political preferences. When engaging in political activities, apart from Bank of America responsibilities, employees are expected to make it clear that they are acting as an individual and not as a representative of the Company.
Employees who wish to accept an appointment to public office or file as a candidate for election must first obtain approval consistent with Bank of America policy to avoid any conflict of interest.
Compliance and Monitoring
The Bank of America Code of Conduct guides us in all that we do. The Code, which is grounded in our company's values, provides basic guidelines of business practice, as well as professional and personal conduct, that all employees are expected to adopt and uphold.
The Code influences how we do business as we continue to build a stronger, more streamlined and customer-focused company. The Code covers a range of issues from anti-bribery and anti-corruption to our risk framework and workplace safety. Our Code specifically covers how our employees may engage in the political process and how we interact with representatives of all levels of government on behalf of Bank of America.
All political activities carried out on behalf of Bank of America are managed by the leaders within the Public Policy Department, who report to the Strategy and Public Policy Executive. The Strategy and Public Policy Executive is responsible for the department's policies, activities and legal compliance with the advice of the Compliance Department and legal counsel. The Public Policy Executive reports at least annually to the Corporate Governance, ESG, and Sustainability Committee, which is comprised solely of independent members of our Board of Directors, on significant policies and practices concerning political contributions, major lobbying priorities and principal trade association activities that relate to the company's public policy objectives.
In general, Bank of America employees may make personal contributions, within applicable legal limits, to political candidates, political parties, political action committees, and other entities that make political expenditures. Financial industry regulations and state or local laws prohibit employees of particular lines of business or employees with certain coverage responsibilities from making certain political contributions or engaging in certain political activities. Bank of America has identified the employees who are covered by such restrictions and requires that those employees pre-clear any contributions with designated Compliance personnel.
Bank of America maintains a robust government relations and political activity compliance program. We are committed to complying with internal policies, all relevant state, federal, and international laws and regulations including SEC Rule 206(4)-5, MSRB Rule G-37, CFTC Rule 23.451, and applicable state and local restrictions on corporate political activity. All contributions made and disclosed by Bank of America are in compliance with Bank of America's internal policies.
For additional information concerning Bank of America's political activities and related policies and procedures, contact Bank of America's Public Policy Department.
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