Responding to FEC "Requests for Additional Information" (RFAI)
Responding to FEC “Requests for Additional Information” (RFAI) is one of the most stressful yet routine aspects of managing a federal campaign’s compliance infrastructure. When the Reports Analysis Division (RAD) flags an issue, it is not just a paperwork annoyance; it is a potential threat to your campaign’s narrative and credibility. In the high-stakes world of Democratic politics, where we are fighting to protect democracy against well-funded Republican opponents, maintaining a pristine regulatory record is essential. A mishandled RFAI can lead to audits, fines, and worst of all, negative headlines that the GOP machine will weaponize against your candidate. Whether you are running a tight Congressional race or a sprawling Super PAC, understanding the nuances of FEC inquiries ensures that your war chest stays secure and your team stays focused on the Blue Wave.
Mastering the Art of Responding to FEC "Requests for Additional Information" (RFAI)
The context for receiving these inquiries often stems from the sheer volume and complexity of data that modern campaigns process. The Federal Election Commission’s Reports Analysis Division assigns analysts to review every report filed by your committee to ensure compliance with the Federal Election Campaign Act. When their internal review thresholds trigger a flag—whether for mathematical discrepancies, excessive contributions, or missing donor information—they issue an RFAI. For Democratic campaigns leveraging high-volume grassroots fundraising through ActBlue, the data reconciliation process can be intense. The goal is not merely to answer the question but to demonstrate a culture of compliance that discourages further scrutiny. Ignoring an RFAI or providing an inadequate response can lead to enforcement referrals or audits, draining resources that should be spent on voter contact and media buying.
Leveraging Technology for RFAI Prevention and Response
While the strategy is human, the execution relies heavily on the software stack you choose. There is no single “RFAI button,” but top-tier campaign finance platforms provide the infrastructure to prevent errors and manage responses. Integrated Solutions Political (ISPolitical) is a favorite for many Democratic treasurers because it hosts a dedicated directory of common RFAIs with recommended responses and deadline calendars. Their system is designed to provide instructions keyed to specific FEC form language, helping staff understand exactly how to correct summary page discrepancies or explain prohibited contributions. Alternatively, Aristotle Campaign Manager and Aristotle 360 offer enterprise-grade compliance with robust voter file integration. By using their zip-to-district matching and address verification, you can significantly reduce the “missing or invalid address” RFAIs that plague campaigns with messy data. For smaller committees with limited budgets, the official FECFile software is free and functional, though it lacks the automated error-checking and support teams found in commercial tools.
The Strategic Workflow for Responding to an RFAI
When your committee receives a letter, the clock starts ticking. The tactical execution of responding to FEC “Requests for Additional Information” (RFAI) depends entirely on the nature of the inquiry. If the RFAI cites a mathematical error or missing data—such as failing to aggregate year-to-date totals or omitting employer information—the correct response is usually to file an Amended Report. This replaces the original filing with corrected data. However, if the RFAI questions the legality or nature of a transaction, such as a complex earmarked contribution or a debt settlement, filing an amendment may not be enough. In these cases, you must file a “Miscellaneous Text Submission” (Form 99) or enter memo text in your software to provide a narrative explanation. The key is to be concise, accurate, and timely. The FEC provides a “safe harbor” if you respond adequately by the deadline, so never let a due date pass without action.
Three Costly Compliance Mistakes to Avoid
Even experienced treasurers can stumble when the pressure is on. The first major mistake is ignoring the nuance of the analyst’s question. If an analyst asks for clarification on a specific disbursement, providing a generic boilerplate response often triggers a second RFAI, elevating the risk level. The second mistake is failing to address the root cause. If you receive an RFAI for accepting contributions over the limit, simply refunding the money is the immediate fix, but failing to update your donation page limits or compliance filters guarantees the problem will recur. Finally, never treat the RFAI count as a vanity metric. While we want to minimize them, the FEC explicitly states that the number of amendments is not necessarily a negative factor if the responses are adequate. It is far better to amend a report and fix the record than to hide an error and face an enforcement action later.
Pre-Filing Best Practices to Stop RFAIs Before They Start
Prevention is the highest form of strategy. To stop RFAIs before they are generated, your campaign must adopt a rigorous pre-filing checklist. This starts with data hygiene. Ensure your fundraising platform—typically ActBlue for our side—is syncing correctly with your compliance software (like ISPolitical or Aristotle) to capture all conduit information and employer data. Utilize the “compliance check” features in your software to flag prohibited sources or aggregate limits before you upload to the FEC. Additionally, maintain a strict calendar of filing deadlines. A “Failure to File” RFAI is the most avoidable yet damaging error a campaign can make. By standardizing your reconciliation process and reviewing the FEC’s “Best Practices” training materials, you turn compliance from a liability into a stable foundation for your campaign’s victory.
The Sutton & Smart Difference
In a political landscape defined by razor-thin margins and aggressive opposition research, you cannot afford to have your momentum stalled by regulatory errors. Your Republican opponents are looking for any excuse to file a complaint or push a narrative of incompetence. At Sutton & Smart, we provide the full-stack infrastructure that Democratic Whales rely on. Beyond strategy, we specialize in Joint Fundraising Committee (JFC) Compliance and high-level financial logistics. We ensure that your fundraising success translates into clean, compliant reports that withstand scrutiny, allowing you to focus on winning the argument while we handle the data. Don’t let paperwork derail progress—let’s build a campaign that is as disciplined as it is passionate.
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Jon Sutton
An expert in management, strategy, and field organizing, Jon has been a frequent commentator in national publications.
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Have Questions?
Frequently Asked Questions
No. An RFAI is a request for clarification or correction. However, failing to respond adequately or establishing a pattern of non-compliance can lead to an audit or enforcement referral.
It depends on the issue. If the RFAI asks for missing data or corrections to figures, you must file an Amended Report electronically. Narrative explanations are filed via Form 99 or memo text.
No software automates the negotiation with the FEC. However, platforms like ISPolitical provide templates and guidance, and systems like Aristotle help prevent the data errors that cause them.
This article is provided for educational and informational purposes only and does not constitute legal, financial, or tax advice. Political campaign laws, FEC regulations, voter-file handling rules, and platform policies (Meta, Google, etc.) are subject to frequent change. State-level laws governing the use, storage, and transmission of voter files or personally identifiable political data vary significantly and may impose strict limitations on third-party uploads, data matching, or cross-platform activation. Always consult your campaign’s General Counsel, Compliance Treasurer, or state party data governance office before making strategic, legal, or financial decisions related to voter data. Parts of this article may have been created, drafted, or refined using artificial intelligence tools. AI systems can produce errors or outdated information, so all content should be independently verified before use in any official campaign capacity. Sutton & Smart is an independent political consulting firm. Unless explicitly stated, we are not affiliated with, endorsed by, or sponsored by any third-party platforms mentioned in this content, including but not limited to NGP VAN, ActBlue, Meta (Facebook/Instagram), Google, Hyros, or Vibe.co. All trademarks and brand names belong to their respective owners and are used solely for descriptive and educational purposes.
https://ispolitical.com/responding-to-fec-requests-for-additional-information-rfais/
https://ispolitical.com/responding-to-fec-requests-for-additional-information-rfais-failure-to-file/
https://www.fec.gov/data/browse-data/
