Federal Election Commission (FEC)

within 10 days of the change^{1, 2}

for three years after the filing date of the report they relate to^{3, 4, 5, 6}

When the treasurer dies, the committee may accept no contribution and make no expenditure while the office of treasurer is vacant, so it is frozen until a successor is named.^{1, 7, 6}

A committee that designated an assistant treasurer on its Statement of Organization avoids the freeze: that person assumes the treasurer's duties on a temporary or permanent vacancy.^{1, 7}

When the candidate dies, the authorized committee does not dissolve. It keeps filing routine reports on Form 3 (House or Senate) or Form 3P (Presidential) until it formally terminates.⁸

The treasurer or a successor winds down operations, paying or settling debts and refunding or donating remaining funds, and then files a termination report.⁸

Remaining campaign funds may be refunded to contributors, given to charities described in 26 U.S.C. § 170(c), transferred without limit to a national, state or local party committee, donated to state and local candidates as state law allows, or used for another lawful purpose that is not personal use.^{9, 10}

The family cannot keep the money. A contribution "shall not be converted by any person to personal use," and in AO 2024-10 the Commission read that ban as reaching a former officeholder or, for a deceased officeholder, the estate.^{10, 11}

An authorized committee's termination report discloses all receipts and disbursements not previously reported and the purpose of any remaining funds, with a treasurer-signed statement that no noncash committee assets will be converted to personal use.¹²

Campaign funds cannot pay expenses related to deaths within the candidate's family; those are personal use. They may cover funeral, cremation and burial expenses only for a candidate or campaign worker whose death arises out of, or in the course of, campaign activity; otherwise the estate pays.^{13, 14}

A deceased person's estate may pay a bequest to a candidate or political committee, subject to the contribution limits. The Commission treats the estate as the testator's successor and a "person" under the Act, with the limits and prohibitions that applied in life.¹⁵

A committee may accept a contribution from an estate made through a testamentary trust, and it must disclose both the trust's name and the decedent's name on its report.^{16, 17}

Where a bequest exceeds the annual limit, the estate, a trustee or an escrow agent holds the balance and pays it out over successive years within the limits. That mechanism survived a First Amendment challenge in LNC v. FEC.^{15, 18}

The FEC does not accept a death certificate as a stand-alone notification. Instead the committee, through a successor treasurer or the estate representative, acts on its FEC filings.¹⁹

The FEC does not pay survivor benefits; it is a regulatory agency that oversees campaign finance disclosure. What it offers survivors is procedural: closing the committee properly, so the estate is not exposed to continuing reporting liability and remaining funds go to a permitted use.¹⁹

The termination report has no deadline. It may be filed any time the committee no longer receives contributions or makes expenditures, and may be combined with a regularly scheduled report.^{8, 20}

The reporting obligation ends only when the FEC issues a termination approval letter. Filing the termination report alone does not close the committee, and every otherwise-required report continues on schedule until the letter arrives.²⁰

The six-month window in 11 CFR 113.2(a)(2) is for winding down the office of a former federal officeholder after leaving office. It is not a deadline for winding down the campaign committee, which has none.^{21, 9}

A committee under FEC enforcement (a Matter Under Review), audit or litigation cannot terminate until the matter is resolved.⁸

A debt settlement plan must be filed before the termination report, the creditors must already have agreed, and no payment may be made to a listed creditor until the Commission's review is complete.^{22, 23}

If debt settlement fails, an inactive committee may ask the Reports Analysis Division in writing for administrative termination. The Commission weighs factors such as under $5,000 of annual activity, no contributions in the prior year, and debts exceeding cash on hand, and approves or disapproves in writing.²⁴

The treasurer signs and files all committee reports, authorizes expenditures or appoints an agent to do so, and keeps the committee's records.^{1, 6, 7}

When the FEC brings an enforcement action against a committee, the treasurer is usually named as a respondent in an official capacity, and in a personal capacity for a knowing and willful violation or for intentionally avoiding the operative facts.¹

The successor treasurer or the estate representative is responsible for keeping the committee's records after the candidate or original treasurer dies.³

The committee's assigned analyst in the Reports Analysis Division answers filing-specific questions, and registered committees can look up their analyst on fec.gov. The Information Division answers campaign finance law questions and supplies forms.^{25, 26}

Electronic filers obtain an electronic filing password for the new treasurer before the next report is due. The Electronic Filing Office handles filing technical support and passwords.^{1, 26}