Election Crime Bureau

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Sub-$200 Non-Itemization Threshold Creates Structural Audit Gap (US)

Established Fact

Federal law does not require campaigns to itemize contributions below $200 aggregate per donor per cycle. This threshold creates a structural incentive to keep individual fraudulent transactions sub-threshold, rendering them invisible to public FEC disclosure.

Citations

11 C.F.R. § 104.3(a)(4)(i) (specifying that authorized committees must report itemized individual contributions in Schedule A, Line 11(a)(i), for each contributor whose aggregate contributions exceed the statutory threshold). The FEC’s official guidance states: “A contribution from an individual is itemized on Schedule A . . . when it: Exceeds $200 or Aggregates over $200 when added to other contributions received from the same source during the election cycle.” FEC, Individual Contributions, https://www.fec.gov/help-candidates-and-committees/filing-reports/individual-contributions/

FEC, Campaign Guide for Congressional Candidates and Committees (Oct. 2021), at 99 (Ch. 13, §5: “When to Itemize Receipts”), https://www.fec.gov/resources/cms-content/documents/policy-guidance/candgui.pdf