Microsoft Word - Campaign Finance Overview-StateCandidates 2016 FINAL.docx

CAMPAIGN

FINANCE

OVERVIEW

Independent

Expenditure

Committees

Published: July 2019

There has been no change in campaign finance statutes since

March of 2016.

This manual has been updated to include specific statutory

citations and clarify basic reporting requirements for

state Political Action Committees.

Provided pursuant to WIS. STAT. § 11.1304(3) and

in compliance with WIS. STAT. § 227.112.

 
Table of Contents 
REGISTRATION REQUIREMENTS ....................................................................................................... 4 
What is an Independent Expenditure Committee? ...................................................................... 4 
When is an Independent Expenditure Committee Required to Register? ................................... 5 
Completing a Registration Statement ......................................................................................... 6 
Amending a Registration Statement ........................................................................................... 6 
Penalty for Not Filing a Registration Statement ......................................................................... 6 
EXEMPTION FROM FILING CAMPAIGN FINANCE REPORTS ................................................................ 7 
Eligibility .................................................................................................................................... 7 
Financial Records During Exemption ......................................................................................... 7 
Revoking Exemption ................................................................................................................... 7 
FILING FEES ................................................................................................................................. 8 
CONTRIBUTIONS AND DISBURSEMENTS............................................................................................ 9 
Contributions ............................................................................................................................... 9 
Required Information for Contributions ............................................................................10 
Other Income from Businesses ................................................................................................. 10 
In-Kind Contributions ............................................................................................................... 10 
Returned Contributions ............................................................................................................. 11 
Contributions Transferred through Conduits ............................................................................ 11 
Corporate Contributions ............................................................................................................ 12 
Contribution Limits ................................................................................................................... 12 
Prohibited Contributions ........................................................................................................... 12 
Disbursements ........................................................................................................................... 13 
Required Information for Disbursements ..........................................................................13 
Obligations and Loans .............................................................................................................. 14 
Required Information for Obligations ...............................................................................14 
Required Information for Loans ........................................................................................14 
Independent Expenditures and Coordination ............................................................................ 15 
CAMPAIGN FINANCE REPORTS ....................................................................................................... 17 
Types of Reports ....................................................................................................................... 17 
How to Complete Campaign Finance Reports .......................................................................... 18 
Reporting Specific Express Advocacy (72-Hour Reporting) ................................................... 19 
No-Activity Report ................................................................................................................... 19 

ATTRIBUTION STATEMENTS (DISCLAIMERS) .................................................................................. 21

Formats for Disclaimers .....................................................................................................21

TERMINATION OF CAMPAIGN FINANCE REGISTRATION .................................................................. 23

Disposal of Residual Funds ...............................................................................................23

REGISTRATION REQUIREMENTS

What is an Independent Expenditure Committee?

An Independent Expenditure Committee is defined as:

any person, other than an individual, or any permanent or temporary combination of 2 or more

persons unrelated by marriage that satisfies any of the following:

(a) It has the major purpose of making independent expenditures, as specified in the person's

organizational or governing documents, the person's bylaws, resolutions of the person's

governing body, or registration statements filed by the person under this chapter; or

(b) It uses more than 50 percent of its total spending in a 12-month period on independent

expenditures and expenditures made to support or defeat a referendum. In this subdivision,

total spending does not include a committee's fundraising or administrative expenses.

WIS. STAT. § 11.0101(17).

An independent expenditure is defined as:

an expenditure for express advocacy by a person, if the expenditure is not made in

coordination with a candidate, candidate committee, candidate's agent, legislative campaign

committee, or political party, as prohibited under s. 11.1203.

WIS. STAT. § 11.0101(16).

The express advocacy requirement is defined as:

(11) “Express advocacy" means a communication that contains terms such as the following with

reference to a clearly identified candidate and that unambiguously relates to the election or defeat

of that candidate:

(a) “Vote for;"

(b) “Elect;"

(d) “Cast your ballot for;"

(e) “Smith for ... (an elective office);"

(f) “Vote against;"

(g) “Defeat;"

(h) “Reject;" or

(i) “Cast your ballot against".

WIS. STAT. § 11.0101(11).

When is an Independent Expenditure Committee Required to Register?

Under WIS. STAT. § 11.0602, a new independent expenditure committee must register within 10

business days of exceeding the threshold of $2,500 of activity in a calendar year.

All independent expenditure committees must register with the Wisconsin Ethics

Commission. WIS. STAT. § 11.0102(1)(a)4m. Independent expenditure committees register

online at http://cfis.wi.gov. To complete the committee registration you must print the form

and send a signed copy to the Wisconsin Ethics Commission either electronically or by mail.

When the signed registration statement is received, the Commission will activate the

independent expenditure committee on CFIS.

After the registration statement has been filed and the committee has been activated, an

independent expenditure committee may resume making disbursements and incurring

obligations. WIS. STAT. § 11.0602(2). The committee’s financial activities must be reported

on campaign finance reports (ETHCF-2S, 2SE, 2SU or 2NA), unless the committee has

claimed an exemption from filing finance reports. These reports will disclose information

on the receipts, expenditures, incurred obligations and loans of the committee.

It is important to note that some entities not required to register as independent expenditure

committees (individuals, or groups that spend less than 50% of their funds on independent

expenditures) are still required to report spending on disbursements made for the purpose of

express advocacy if they spend more than $2,500 within 60 days of a primary or election. WIS.

STAT. § 11.1001. See the “Reporting Specific Express Advocacy (72-Hour Reporting)”

section for more details.

Completing a Registration Statement

Registration statements are completed electronically using the Campaign Finance Information

System (CFIS) website. The website address is https://cfis.wi.gov. For information about filing a

registration statement, please click on the “Need Help? Review the User’s Guide and FAQ” link

at the bottom of every CFIS web page.

Information required on the registration:

1. The name and mailing address of the independent expenditure committee;

2. The name and mailing address of the treasurer and any other custodian of books and

accounts. Unless otherwise directed by the treasurer on the registration form and except as

otherwise provided in this chapter or any rule of the commission, all mailings that are

required by law or by rule of the commission shall be sent to the treasurer at the treasurer's

address indicated upon the form;

3. The name and address of the depository account of the independent expenditure committee

and of any other institution where funds of the committee are kept; and

4. The name and address of the independent expenditure committee's sponsoring organization,

if any.

WIS. STAT. § 11.0603(1).

A sponsoring organization is defined as an entity that establishes, administers, or financially

supports a political action committee or an independent expenditure committee. WIS. STAT. §

11.0101(31).

Amending a Registration Statement

When any of the information reported on the registration statement (CF-1) changes, the statement

must be amended by filing an amendment to the CF-1. The CF-1 must be amended and submitted

to the Ethics Commission within 10 days of the change. Committees must update their

registration statements online in CFIS. WIS. STAT. § 11.0603(3).

Penalty for Not Filing a Registration Statement

If a required statement or amendment is not filed on time, the registrant may be subject to a civil

penalty of up to $500 for each violation. WIS. STAT. § 11.1400(1).

EXEMPTION FROM FILING CAMPAIGN FINANCE REPORTS

Eligibility

Committees may be eligible for an exemption from filing campaign finance reports if the

committee anticipates that it will not accept contributions, make disbursements, or incur loans and

other obligations in an aggregate amount exceeding $2,000 in a calendar year. WIS. STAT. §

11.0104.

An indication of limited activity (exemption) under this section is effective only for the calendar

year in which it is granted. WIS. STAT. § 11.0104(2). The Ethics Commission is seeking guidance

from the Attorney General’s office on interpreting and enforcing this statute. Pending that

guidance or legislative change, the Ethics Commission is not requiring committees to renew their

exemption status annually.

If a committee wishes to renew or update its exempt status, it should file an amendment to the

registration statement (CF-1).

Financial Records During Exemption

When a committee is exempt, it is not required to file any campaign finance reports. WIS. STAT. §

11.0104(2). However, the treasurer is required to keep financial records adequate to meet the

requirements of campaign finance law. Records must be kept of all contributions to the committee

and of all expenditures for the previous three years. WIS. STAT. § 11.0601(4).

Revoking Exemption

If, at a later date, the committee expects to exceed the $2,000 limit on contributions, disbursements,

or obligations, the committee must amend its campaign registration statement by checking the box:

“This registrant is no longer eligible to claim exemption,” on the registration statement. An

amendment to the registration statement must be filed with the Wisconsin Ethics Commission

within ten days. WIS. STAT. § 11.0603(3)(a). The committee is then required to file campaign

finance reports beginning with the next regular report due after the earlier of either the date that

the amended registration was filed or the date that the committee exceeded $2,000 in aggregate

contributions, disbursements, or obligations. WIS. STAT. § 11.0104(3).

FILING FEES

Every independent expenditure committee whose disbursements exceed a total of $2,500 in any

calendar year must pay an annual filing fee of $100. The payment is made to the Ethics

Commission and is due no later than January 15

following the calendar year for which the fee

was required. WIS. STAT. § 11.0102(2).

If a committee becomes subject to registration during the year, it must pay the fee when it

registers. WIS. STAT. § 11.0102(2)(b). If a committee terminates during a year, and spends more

than $2,500 in that year, the registrant must pay the $100 filing fee with its termination request.

WIS. STAT. § 11.0105(2).

Any committee required to pay the filing fee that fails to do so within the time prescribed will be

referred to the Commission for further action. The statutes provide for a forfeiture of $500 plus

three times the filing fee ($300), or $800 total. WIS. STAT. § 11.1400(4).

CONTRIBUTIONS AND DISBURSEMENTS

Independent expenditure committees are required to make full reports of all contributions,

disbursements, and obligations received, made and incurred by the committee. Each report needs

to include information covering the period since the last date covered on the previous report. WIS.

STAT. § 11.0604(1)(a).

Contributions

“Contribution” means any of the following:

1. A gift, subscription, loan, advance, or transfer of money to a committee;

2. With the committee's consent under WIS. STAT. § 11.1109, a transfer of tangible personal

property or services to a committee, valued as provided under WIS. STAT. § 11.1105;

3. A transfer of funds between committees; or

4. The purchase of a ticket for a fundraising event for a committee regardless of whether the

ticket is used to attend the event.

WIS. STAT. § 11.0101(8)(a).

“Contribution” does not include any of the following:

1. Services that an individual provides to a committee, if the individual is not specifically

compensated for providing the services to the committee;

2. Any unreimbursed travel expenses that an individual incurs to volunteer his or her personal

services to a committee;

3. The costs of preparing and transmitting personal correspondence;

4. Interest earned on an interest-bearing account;

5. Rebates or awards earned in connection with the use of a debit or credit card;

6. A loan from a commercial lending institution that the institution makes in its ordinary course

of business;

7. The reuse of surplus materials or the use of unused surplus materials acquired in connection

with a previous campaign for or against the same candidate, political party, or recall if the

materials were previously reported as a contribution;

8. The cost of invitations, food, and beverages in connection with an event held in a private

residence on behalf of a candidate committee;

9. Any communication that does not expressly advocate for the election or defeat of a clearly

identified candidate;

10. A communication made exclusively between an organization and its members. In this

subdivision, a member of an organization means a shareholder, employee, or officer of the

organization, or an individual who has affirmatively manifested an interest in joining,

supporting, or aiding the organization;

11. Any cost incurred to conduct Internet activity by an individual acting in his or her own behalf,

or acting in behalf of another person if the individual is not compensated specifically for those

10  
services, including the cost or value of any computers, software, Internet domain names, 
Internet service providers, and any other technology that is used to provide access to or use 
of the Internet, but not including professional video production services purchased by the 
individual; 
12. Any  news  story,  commentary,  or  editorial  by  a  broadcasting  stations,  cable  television 
operator, producer, or programmer, Internet site, or newspaper or other periodical publication, 
including an Internet or other electronic publication unless a committee owns the medium in 
which the news story, commentary, or editorial appears; or  
13. An  expenditure  of  funds  by  a  sponsoring  organization  for  an  independent  expenditure 
committee’s administrative or solicitation expenses. 
 
WIS. STAT. § 11.0101(8)(b). 
 
Required Information for Contributions 
 
1.  The date, full name, and street address of each person who has made a contribution to the 
independent expenditure committee, together with the amount of the contribution. WIS. 
STAT. § 11.0604(1)(a)1. 
2.  The occupation, if any, of each individual contributor whose cumulative contributions to the 
independent expenditure committee for the calendar year are in excess of $200. WIS. STAT. § 
11.0604(1)(a)3. 
3.  An  itemized  statement  of  each  contribution  made  anonymously  to  the  independent 
expenditure  committee.  If  the  contribution  exceeds  $10,  the  independent  expenditure 
committee  shall  specify  whether  the  committee  donated  the  contribution  to  the  common 
school fund or to a charitable organization and shall include the full name and mailing address 
of the donee. WIS. STAT. § 11.0604(1)(a)4. 
4.  A statement of totals during the reporting period of contributions received and contributions 
donated. WIS. STAT. § 11.0604(1)(a)5. 
 
Other Income from Businesses 
 
Occasionally,  a  committee  may  receive  other  income,  like  interest  on  a  savings  or  checking 
account, or a refund of a security deposit, from a business. This other income is not a contribution 
and may be accepted from any type of business. WIS. STAT. § 11.0101(8)(b). The income should 
be reported as “Other Income,” in campaign finance reports. WIS. STAT. § 11.0604(1)(a)10.  
 
In-Kind Contributions  
  
An in-kind contribution is any good, service, or property offered to the committee free of charge 
or at less than the usual cost, or payment of a registrant’s obligations for such goods, services or 
property. WIS. STAT. § 11.0101(8)(a)2. For example, if a volunteer purchases stamps that are used 
for a mailing and is not reimbursed for the cost of the stamps, the value of the stamps is an in-kind 
contribution to the independent expenditure committee from that volunteer. When an individual 
is paid to work on behalf of an independent expenditure committee by another committee or some 
other  person,  the  payment  for  those  services  is  an  in-kind  contribution  to  the  independent 

11  
expenditure committee that benefits from the work. If a person or another committee offers to 
provide food and beverages for a fundraiser at less than the ordinary market price, the difference 
between the ordinary market price and the cost to the independent expenditure committee is an 
in-kind contribution from the person or committee.  
 
Before making an in-kind contribution to a committee, the contributor is required to notify an 
authorized person and obtain either oral or written consent to the in-kind contribution. WIS. STAT. 
§ 11.1109. If the contributor does not know the actual value of the in-kind contribution, a good 
faith and reasonable estimate of the fair market value should be provided. WIS. ADMIN. CODE ETH 
1.20(5). 
  
Reporting In-Kind Contributions in CFIS 
 
An in-kind contribution received by the independent expenditure committee is reported as both a 
receipt and expenditure. This procedure allows the committee to disclose the receipt of the 
contribution on its campaign finance report along with cash contributions received. Then, in order 
to  keep  the  committee’s  cash  balance  accurate,  the  amount  of  the  in-kind  is  reported  as  an 
expenditure. The two entries offset each other and do not affect the cash balance.  
  
If an estimate of the value of an in-kind contribution is the only value available at the time the 
committee is  required  to  file  a  report, the  committee  must  report the  estimated  value  of  the 
contribution.  WIS. ADMIN. CODE ETH 1.20(7). When the actual value of the estimated in-kind 
contribution is known, the actual amount is reported as a contribution and an expenditure by 
amending the campaign finance report which the in-kind contribution was originally reported in. 
Id. 
  
Returned Contributions  
  
A committee may return a contribution at any time before or after it has been deposited. WIS. STAT. 
§ 11.1110(1). Any contribution a committee returns to the donor after depositing it in the campaign 
account must be reported as a returned contribution to the contributor. A committee that accepts 
an unlawful contribution, reports that contribution, and returns that contribution within 15 days of 
the filing date for that report, does not violate the contribution or source limits. WIS. STAT. § 
11.1110(2)(b). 
 
Contributions Transferred through Conduits 
  
A conduit is any individual, committee or group that  receives contributions from individuals, 
deposits those contributions in a financial institution, and then transfers the contributions to a 
candidate or political committee selected by the original contributor. WIS. STAT. § 11.0101(7).  
The  conduit  may  not  exercise  any  discretion  over  the  amount  or  ultimate  recipient  of  the 
contributions.  WIS. STAT. § 11.0701(3).  Conduits  are  required  to  register  with  the  Ethics 
Commission. WIS. STAT. § 11.0702.  
  

12  
Reporting Conduit Contributions in CFIS 
 
Conduits are required to provide a transmittal letter with contribution checks sent to a receiving 
committee. The transmittal letter must identify the organization as a conduit, and list the individual 
contributors, the amount of each individual’s contribution, and the date the individual authorized 
the contribution. WIS. STAT. § 11.0704(1).  
  
Contributions  transferred  through  conduits  are  reported  as  contributions  received  from  the 
individuals  listed  in  the  transmittal  letter.  WIS. STAT. § 11.1106(2).  These  contributions  are 
reported under the individual’s name. WIS. STAT. § 11.1106(1). They are subject to itemization on 
the same basis as other individual contributions. WIS. STAT. § 11.0604(1)(a). 
 
Corporate Contributions 
 
Unlike other registered committees, independent expenditure committees may receive 
contributions from corporations, cooperatives, associations, unions, and American Indian Tribes. 
WIS. STAT. § 11.1112.  
 
Contribution Limits 
 
Unlike other registered committees, there are no contribution limits on donations to independent 
expenditure committees. WIS. STAT. § 11.1104(13). 
 
Prohibited Contributions  
  
Certain contributions are prohibited by Wisconsin law. An independent expenditure committee 
may not accept the following types of contributions:  
  
1.  Anonymous contributions of more than $10 (WIS. STAT. § 11.1108);  
2.  Contributions in cash of more than $100 (WIS. STAT. § 11.1107); 
3.  Contributions  given  in  the  name  of  someone  other  than  the  contributor  (WIS.  STAT.  § 
11.1204(1)); or 
4.  Contributions from foreign nationals (WIS. STAT. § 11.1208(4)). 
 
An independent expenditure committee should monitor contributions carefully. If the committee 
is aware that a contribution was potentially one which is prohibited under Wisconsin law, the 
committee  should  ensure  that  the  contribution  is  lawful.  WIS.  STAT.  §  11.1204(3).  It  is 
recommended that a committee not accept any contributions if the committee cannot determine 
whether the contribution is lawful.  
 
 
 
 

Disbursements

“Disbursement” means any of the following:

1. An expenditure by a committee from the committee's depository account;

2. The transfer of tangible personal property or services by a committee;

3. A transfer of funds between committees; or

4. The purchase of a ticket for a fundraising event for a committee regardless of whether the

ticket is used to attend the event.

WIS. STAT. § 11.0101(10)(a).

“Disbursement” does not include any of the following:

1. A communication made exclusively between an organization and its members. In this

subdivision, a member of an organization means a shareholder, employee, or officer of the

organization, or an individual who has affirmatively manifested an interest in joining,

supporting or aiding the organization;

2. A communication or Internet activity by an individual acting in his or her own behalf, or

acting on behalf of another person if the individual is not compensated specifically for those

services, including the cost or value of computers, software, Internet domain names, Internet

service providers, and any other technology that is used to provide access to or use of the

Internet, but not including professional video production services purchased by the individual;

3. Any news story, commentary, or editorial by a broadcasting station, cable television operator,

producer, or programmer, Internet site, or newspaper or other periodical publication,

including an Internet or other electronic publication unless a committee owns the medium in

which the news story, commentary, or editorial appears;

4. A nominal fee paid for a communication to the general public;

5. An expenditure of funds by a sponsoring organization for an independent expenditure

committee's administrative or solicitation expenses; or

6. An expenditure of funds for an independent expenditure committee's fundraising and

administrative expenses.

WIS. STAT. § 11.0101(10)(b).

Required Information for Disbursements

1. The date, full name, and street address of each committee to which the independent

expenditure committee has made a contribution, together with the amount of the contribution.

WIS. STAT. § 11.0604(1)(a)2.

2. An itemized statement of every disbursement exceeding $20 in amount or value, together with

the name and address of the person to whom the disbursement was made, and the date and

specific purpose for which the disbursement was made. WIS. STAT. § 11.0604(1)(a)8.

3. A statement of totals during the reporting period of disbursements made. WIS. STAT. §

11.0604(1)(a)10.

Obligations and Loans

Independent expenditure committees are required to make full reports of all obligations received,

made and incurred by the committee. The committee needs to include in each report information

covering the period since the last date covered on the previous report. WIS. STAT. § 11.0604(1)(a).

“Obligation” means any express agreement to make a disbursement, including the following:

1. A loan or loan guarantee;

2. A promise to purchase, rent, or lease tangible personal property; or

3. A promise to pay for a service that has been or will be performed.

WIS. STAT. § 11.0101(23).

Required Information for Obligations

1. An itemized statement of every obligation exceeding $20 in amount or value, together with

the name of the person or business with whom the obligation was incurred, and the date and

the specific purpose for which each such obligation was incurred must be reported in

campaign finance reports. WIS. STAT. § 11.0604(1)(a)9.

2. A statement of the balance of obligations incurred as of the end of the reporting period. WIS.

STAT. § 11.0604(1)(a)11.

Required Information for Loans

Each loan of money made to an independent expenditure committee in an aggregate amount or

value in excess of $20, must be reported with all of the following:

1. The full name and mailing address of the lender;

2. A statement of whether the lender is a commercial lending institution;

3. The date and amount of the loan;

4. The full name and mailing address of each guarantor, if any;

5. The original amount guaranteed by each guarantor; and

6. The balance of the amount guaranteed by each guarantor at the end of the reporting period.

WIS. STAT. § 11.0604(1)(a)7.

Independent Expenditures and Coordination

An independent expenditure is an expenditure for express advocacy that is not made in

coordination with a candidate, candidate committee, candidate’s agent, legislative campaign

committee, or political party. WIS. STAT. § 11.1101(16).

Independent expenditure committees may not make contributions to candidates, party

committees, legislative campaign committees, or political action committees. WIS. STAT. §

11.0601(3)(b). This prohibition applies to both monetary contributions and in-kind contributions.

Independent expenditure committees may not coordinate their spending with candidates or party

committees, because a coordinated expense qualifies as a contribution. WIS. STAT. §

11.1203(2)(b)2.

The definition of coordination is listed below:

For purposes of this section, an expenditure for express advocacy is coordinated if any of the

following applies:

1. The candidate, candidate's agent, legislative campaign committee of the candidate's political

party, or the candidate's political party communicates directly with the political action

committee, independent expenditure committee, other person, or individual making the

expenditure to specifically request that the political action committee, independent

expenditure committee, other person, or individual make the expenditure that benefits the

candidate and the political action committee, independent expenditure committee, other

person, or individual explicitly assents to the request before making the expenditure; or

2. The candidate, candidate's agent, legislative campaign committee of the candidate's political

party, or the candidate's political party exercises control over the expenditure or the content,

timing, location, form, intended audience, number, or frequency of the communication.

WIS. STAT. § 11.1203(2)(a).

Express advocacy means:

A communication that contains terms such as the following with reference to a clearly

identified candidate and that unambiguously relates to the election or defeat of that

candidate:

(a) “Vote for;”

(b) “Elect;”

(d) “Cast your ballot for;”

(e) “Smith for ... (an elective office);”

(f) “Vote against;”

(g) “Defeat;”

(h) “Reject;” or

(i) “Cast your ballot against.”

WIS. STAT. § 11.0101(11).

An independent expenditure committee must report all of its receipts and expenses, including its

independent expenditures as required by WIS. STAT. § 11.0604(1)(a).

17  
CAMPAIGN FINANCE REPORTS 
  
All registrants that are not exempt from filing must file campaign finance reports. Committees 
must continue to file periodic reports until their committee is terminated. The reports must be 
submitted electronically via CFIS (https://cfis.wi.gov/). WIS. STAT. § 11.1304(6). 
 
The  information  listed  on  the  campaign  finance  report  discloses  the  financial  activity  of  the 
independent  expenditure  committee.  The  law  requires  disclosure  of  contributions  received, 
disbursements made, and incurred obligations. WIS. STAT. § 11.0604(1)(a). Committee treasurers 
must exercise diligence in acquiring and furnishing the contributor information required on the 
receipt schedules. Committees are required to make a “good faith effort” to obtain all information 
required on the reports. WIS. STAT. § 11.0103(1)(a). For all contributors, the report must disclose 
the individual’s name and address. WIS. STAT. § 11.0604(1)(a)1. If the individual’s cumulative 
contributions  exceed  $200,  you  must  also  provide  the  individual’s  occupation.  WIS.  STAT.  § 
11.0604(1)(a)3. 
 
Types of Reports  
  
All committees must file continuing reports in January and July of each year until they terminate 
their registration. Independent expenditure committees that make expenditures for or against 
candidates on the ballot must file a pre-primary and a pre-election report due 8 days before the 
primary or general election.    
 
Reporting Periods and Elections:  
 
Spring Primary: A committee that engages in activity concerning a spring primary must file: (1) a 
pre-primary report; (2) a pre-election report; and (3) annually in each year of an election cycle, a 
report on January 15 and July 15. WIS. STAT. § 11.0604(2). 
  
Spring Election: A committee that engages in activity concerning a spring election must file: (1) 
a pre-election report; and (2) annually in each year of an election cycle, a report on January 15 
and July 15. WIS. STAT. § 11.0604(3).   
  
Partisan Primary: A committee that engages in activity concerning a partisan primary must file: 
(1) a pre-primary report; (2) a pre-election report; (3) in an odd-numbered year, a report on January 
15 and July 15; and (4) in an even-numbered year, a report on January 15 and July 15 and on the 
4th Tuesday in September. WIS. STAT. § 11.0604(4).  
  
General Election: A committee that engages in activity concerning a general election must file: 
(1) a pre-election report; (2) in an odd-numbered year, a report on January 15 and July 15; and (3) 
in  an  even  numbered  year,  a  report  on  January  15  and  July  15  and  on  the  4th  Tuesday  in 
September. WIS. STAT. § 11.0604(5). 
 

Special Elections: In addition to the pre-primary and pre-election reports described above, a

committee may also have to file a post-election report within 45 days if January or July report has

not been filed. WIS. STAT. §§ 11.0604(3)(c) and 11.0604(5)(d).

Reporting deadlines can be found on the Ethics Commission’s website at:

https://ethics.wi.gov/Pages/CampaignFinance/ReportPeriods.aspx

How to Complete Campaign Finance Reports

There are two ways to enter campaign finance transactions (contributions and disbursements):

• Using the online screens in the Campaign Finance Information System (“CFIS”), and

• Using the CFIS upload templates.

Every committee must use one of the specified, approved forms. WIS. STAT. § 11.1304(1). A

committee that chooses to use an upload template with schedule detail must use the approved

template. Committees can find upload templates on the CFIS site in the “Upload Transactions”

section of the menu.

For detailed instructions on how to complete and file the campaign finance report, go to

https://cfis.wi.gov and click on the CFIS Manuals link in the center of the page, or go to the

Ethics Commission CFIS Manuals & Frequently Asked Questions page:

https://ethics.wi.gov/Pages/CampaignFinance/CFISManuals.aspx.

Filing Reports in CFIS

Independent expenditure committees file campaign finance reports electronically through the CFIS

website. The help screens on that site may answer some of your questions. When you have entered

all transactions for a reporting period, the CFIS system will automatically generate the report for

you and place all transactions on the appropriate schedules.

Independent expenditure committees are required to provide a statement of the cash on hand at the

beginning and end of each reporting period. WIS. STAT. § 11.0604(1)(a)6. The committee will be

prompted to provide the beginning and ending cash balances when certifying the campaign finance

report in CFIS. This will appear on the summary page of the report generated by CFIS.

All contributions received by the committee must be reported in Schedule 1 (Receipts) of the

campaign finance report. Contributions and loans from individuals are listed in Schedule 1A

(Contributions Including Loans from Individuals). Contributions from other committees are

reported in Schedule 1B (Contributions from Committees). All other income such as loans from

financial institutions, contributions returned from other registrants, refunds, returns of deposits or

interest on investments are reported in Schedule 1C (Other Income and Commercial Loans). The

date which must be provided for all contributions is the date the committee received the

contribution, that is, the date it acquired possession and control of the contribution, not the date of

deposit or date on the check (unless all dates are the same). WIS. STAT. § 11.0103(2)(a)1.

All money spent by the committee is reported in Schedule 2 (Disbursements) of the campaign

finance report. General operating expenditures are listed in Schedule 2A (Gross Expenditures).

Contributions to other independent expenditure committees or referendum committees are listed

in Schedule 2B (Contributions to Committees).

Additional information required to be disclosed is reported in Schedule 3 (Additional Disclosure)

of the campaign finance report. All obligations of the committee such as unpaid debts are listed in

Schedule 3A (Incurred Obligations Excluding Loans). Loans and the individuals who guarantee

loans for the committee are listed in Schedule 3B (Loans).

Reporting Specific Express Advocacy (72-Hour Reporting)

Independent expenditure committees that spend more than $2,500 on express advocacy in the 60

days before a primary election must also file a special report documenting their expenditures

within 72 hours of making the disbursement. It is the date the communication takes place, not

necessarily the day the expense is paid, that determines whether it falls within the 60-day period.

WIS. STAT. § 11.0605(1)(a).

Committees required to file 72-hour reports (CF-7) of independent expenditures must file on the

CFIS website.

Directions on filing these reports in CFIS can be found in the CFIS User’s Guide:

https://ethics.wi.gov/Pages/CampaignFinance/CFISManuals.aspx.

When a committee submits a 72-hour report, the treasurer will also file an oath that the

committee has not coordinated with the candidate committee. An oath is repeated for each

separate communication and filed with each 72-hour report. Since oaths must be notarized, a

copy of each 72-hour report must always be mailed, emailed, or faxed to the Ethics Commission.

Some entities not required to register as independent expenditure committees (individuals, or

groups that spend less than 50% of their funds on independent expenditures) are still required to

report spending on express advocacy if they spend more than $2,500 within 60 days of a primary

or election. The requirements for reporting and filing an oath are the same as the requirements for

the 72-hour reports described in this section. WIS. STAT. § 11.1001.

No-Activity Report

If an independent expenditure committee receives no contributions, makes no disbursements and

incurs no obligations during a reporting period, the registrant may file a “No Activity Report.”

This form should be used only when there has been no financial activity and the cash balance

remains unchanged during the reporting period. WIS. STAT. § 11.0103(3).

ATTRIBUTION STATEMENTS (DISCLAIMERS)

Attribution statements, commonly referred to as disclaimers, are statements required to be placed

on any communication containing express advocacy in order to identify the person(s) who paid for

and/or authorized the communication. WIS. STAT. § 11.1303(2).

No disbursement by independent expenditure committees may be made anonymously and no

contribution or disbursement may be made in a fictitious name or by one person or organization

in the name of another. WIS. STAT. § 11.1303(1).

Every printed advertisement, billboard, handbill, sample ballot, television or radio advertisement,

or other communication containing express advocacy which is paid for by any contribution or

disbursement shall clearly identify its source. WIS. STAT. § 11.1303(2)(a).

Every communication containing express advocacy the cost of which is paid for or reimbursed by

a committee, or for which a committee assumes responsibility, whether by accepting a contribution

or making a disbursement, shall identify its source by the words "Paid for by" followed by the

name of the committee making the payment or reimbursement or assuming responsibility for the

communication and may include the name of the treasurer or other authorized agent of the

committee. WIS. STAT. § 11.1303(2)(b).

Attribution statements must be readable, legible, and readily accessible. WIS. STAT. §

11.1303(2)(g).

Attribution statements do not apply to communications containing express advocacy printed on

small items, which would normally require a disclaimer, but cannot be conveniently printed,

including text messages, social media communications, and certain small advertisements on

mobile phones. WIS. STAT. § 11.1303(2)(f).

Formats for Disclaimers

When a communication is paid for by a committee, the disclaimer must include the words “Paid

for by,” followed by the name of the committee:

“Paid for by the ABC Committee.”

WIS. STAT. § 11.1303(2)(b).

The disclaimer may also include the name of the treasurer or other authorized agent:

“Paid for by the ABC Committee, James Jones, Treasurer.”

When a committee places a communication for express advocacy that is not in coordination with

a candidate (an independent expenditure), that committee should include the words "Not

authorized by any candidate or candidate's agent or committee" in the attribution:

“Paid for by ABC Committee, Not Authorized by

Any Candidate or Candidate’s Agent or Committee”

WIS. STAT. §11.1303(2)(d).

TERMINATION OF CAMPAIGN FINANCE REGISTRATION

An independent expenditure committee may terminate its registration if it meets the following

requirements:

1. Determines that all financial activity will stop, and that it will no longer receive contributions,

make disbursements, or incur obligations;

2. Files a termination campaign finance report showing that all incurred obligations have been

paid or satisfied, and that the cash balance has been reduced to zero; and,

3. Completes a request for termination by filing a termination report. See the “Termination a

Committee” Quick Tip Sheet for more details: https://ethics.wi.gov/Resources/CFIS-

TerminatingCommittee.pdf.

WIS. STAT. § 11.0105.

Disposal of Residual Funds

Residual funds may be used for any purpose that is not for an individual’s strictly personal use and

is not prohibited by law, including:

1. Repay any outstanding loans. If loans are not repaid, they must be forgiven before the

committee can request termination;

2. Returning money to contributors in amounts that are not more than the contributor’s original

contribution (note: the committee or treasurer may choose which contributors to refund. The

committee is not required to pro-rate and return a portion to all contributors);

3. Donating money to any tax-exempt charitable organization or the Common School Fund;

4. Transferring money to another registrant within the permitted contribution limit; or

5. Using any combination of the above.

WIS. STAT. §§ 11.0105, 11.1208(2)(a).

Prior to making these disbursements of residual funds, make sure the committee does not have any

pending fees or settlement offers.