Joint Fundraising Committees (JFCs): Setup and Allocation Rules
Understanding Joint Fundraising Committees (JFCs): Setup and Allocation Rules is the single most effective way for Democratic campaigns to legally aggregate high-dollar checks and compete with the GOP’s corporate war chest. As we prepare for another cycle of record-breaking spending, JFCs allow candidates, party committees, and leadership PACs to band together. This structure maximizes donor impact without violating individual contribution limits. It is not just a loophole; it is a critical piece of infrastructure for scaling resources to protect democracy and ensure we have the funds to fight back against MAGA extremism.
Joint Fundraising Committees (JFCs): Setup and Allocation Rules for Winning Campaigns
The Republican machine has mastered the art of bundling big money through opaque channels, but Democrats can fight back transparently using JFCs. A Joint Fundraising Committee is a federally registered political committee that serves as a fundraising vehicle for two or more participants. Instead of asking a donor to write five separate checks to five different entities—such as your campaign, the state party, and a leadership PAC—you ask for one large check. The JFC then acts as a clearinghouse, splitting that money according to a strict legal formula. This reduces friction for your biggest supporters and allows your campaign to pool costs for expensive events or high-end direct mail. It is about efficiency and leverage. While there is no ‘subscription fee’ for a JFC like a SaaS product, the cost is in the complexity of compliance and legal structuring.
Establishing the Legal Framework
Before you raise a dime, the regulatory setup must be bulletproof. There is no software tier to select; the ‘pricing’ is essentially your legal and compliance retainer. First, you must designate a Joint Fundraising Representative (JFR), which can be a new standalone committee or one of the participating committees. You will file FEC Form 1, specifically checking the boxes that indicate this is a joint effort. Crucially, you must draft a written Joint Fundraising Agreement. This document is not optional; it is the legal backbone that defines liability, roles, and the allocation formula. Without this signed agreement in place before the first solicitation, every contribution you accept is a potential FEC violation. Your costs here are driven by the complexity of the agreement and the number of participants involved.
Tactics: Mastering the Allocation Formula
The heart of Joint Fundraising Committees (JFCs): Setup and Allocation Rules lies in the math. Your agreement must state exactly how funds are distributed—typically strictly by percentage or by a ‘waterfall’ method where the first X dollars go to the candidate, the next Y dollars to the state party, and the remainder to the national committee. When you use platforms like ActBlue, this logic must be mirrored in the backend. If a donor gives $10,000, the system must split it precisely per your agreement while ensuring no single participant receives more than their individual legal limit. If a participant hits their limit, the overflow must cascade to the next participant or be refunded. This requires tight integration between your compliance team and your NGP VAN data to track aggregate limits across all entities.
3 Costly Mistakes to Avoid
First is the Notice Failure. Every solicitation—whether a gala invite or a digital ad—must include a specific Joint Fundraising Notice listing all participants and the allocation formula. If you miss this, the money might need to be refunded. Second is Improper Expense Allocation. You cannot just have the wealthiest committee pay for everything to subsidize the others. Costs for fundraising events must be allocated based on the same formula used for proceeds, or else it constitutes an impermissible in-kind contribution (unless participants are affiliated party committees). Third is Ignoring State Laws. If your JFC includes state-level candidates, you are now navigating a minefield of conflicting federal and state reporting schedules. Stick to federal participants unless you have specialized counsel.
Pre-Launch Checklist
Before you send that first invite, ensure you are ready. 1. Agreement Signed: Do you have a fully executed Joint Fundraising Agreement? 2. Bank Account Open: Does the JFR have its own bank account to escrow funds before distribution? 3. Tech Stack Aligned: Is your ActBlue page set up to split funds, and is NGP VAN ready to import JFC transfers? 4. Treasurer Trained: Does your compliance officer understand how to report gross receipts on the JFC report and net transfers on the participant reports? 5. Donor Notice Drafted: Is the allocation disclaimer on every piece of collateral?
The Sutton & Smart Difference
Defeating well-funded incumbents requires every financial tool available, but the complexity of JFCs scares off many campaigns. Do not let compliance anxiety leave money on the table. Sutton & Smart specializes in high-level Democratic strategy, including ‘Joint Fundraising Committee (JFC) Compliance’ and ‘High-Dollar Bundler Strategy.’ We handle the Heavy Logistics—from drafting the allocation waterfall to auditing your FEC filings and ActBlue integration—so you can focus on working the room. In a race decided by margins, superior infrastructure beats hope every time.
Ready to Maximize Your Fundraising?
Contact Sutton & Smart today to streamline your JFC setup and power your path to victory.
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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. Donors are still subject to individual limits for each participating committee. The JFC simply aggregates these limits into one transaction, allowing for a larger single check that is then split up.
There is no government fee, but legal and compliance retainer fees vary. Operational expenses are typically deducted from the proceeds raised before distribution.
Generally, no. Coordination rules prevent candidates from fundraising jointly with independent expenditure-only committees (Super PACs) in ways that bypass limits, though specific non-federal fundraising rules are complex.
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://www.law.cornell.edu/cfr/text/11/9034.8
https://www.wiley.law/newsletter-Sept_2017_ELN-Joint_Fundraising_101-Transparency_and_Compliance
https://www.cityandstateny.com/politics/2024/02/joint-fundraising-committees-are-funneling-huge-amounts-money-ny-house-races/393928/
