Fair Warning: We are in Middle of 48-Hour Report Window

ElectaFile Short Summary: 48-Hour Reports are “Extra” Reports that must be filed between February 18, 2024 and March 5, 2024

ElectaFile readers are superstars. You all have complete command of the reporting schedules. You know 1Q Plus Reports are due this coming Tuesday, Feb. 27, 2024 (The books “closed” on February 17, 2024).

Today we’re writing about something called 48-Hour Reports. 48-Hour Reports are extra reporting obligations for any campaign, party or PAC committee that receives a contribution of $1,000 or more (in-kind contributions included!) at any time from February 18, 2024 through March 5, 2024.

Start here with this screenshot from the State Board’s Manual:

Here’s a ledger of 48-Hour Reports filed so far this month: https://cf.ncsbe.gov/CFDocLkup/DocumentResult/?year=2024&reports=%27IR48H%27

Why the Extra Report? 48-Hour Reports are designed to make transparent larger contributions in the run up to the primary election that otherwise would not be reported until your 2Q Report is filed this summer. 48-Hour Reports close the reporting gap, which is a policy choice by the law that $$$$ coming into a committee right before an election ought to be disclosed.

Why 48-Hours? This is the time period by which committees must make the report of receiving $1,000 or more from contributor. This is the old “greater than or equal to” arithmetic sign from back in the day. $1,000 or more must be reported. This includes in-kind contributions.

How Do We Make The Report When the Mail is Slow? Recognizing that the speed of mail often takes more than 48-Hours (reducing the benefit of the law’s policy choice in favor of disclosure), the State Board of Elections allows 48-Hour Reports to be submitted through e-mail scan or facsimile.

What Forms do We Use? If you want to hand mark your report and just scan and email it in, you can use this form for simple contributions equal to or exceeding $1,000.00. If the contribution is an in-kind contribution, then you also need to complete this form.

What’s the Biggest Trap for the Unwary? The biggest trap by far is all of your other reports track funds in a rolling fashion, i.e., the starting balance on a report tracks the ending balance on the prior report. For 48-Hour Reports, you’re just disclosing the money coming in as a stand alone proposition. You’re not also simultaneously reporting flow of funds, which is the exception.

Do You Still Need to Report the Money Later? Yes. In addition to reporting the contribution on the 48-Hour Report you file separately, you’ll also report the contribution (don’t forget in-kind!) again on your 2Q Report filed this summer. That’ll ensure that the flow of funds is properly reported.

What About Independent Expenditure Committees? IE Committees also have 48-Hour Report obligations. If they spend $5,000 or more or receive $1,000 or more in the window, they’ve got a reporting obligation. Here’s a screen shot on what the State Board has to say:

You can use ElectaFile to file 48-hour reports from the comfort of your own keyboard. We even gin up the e-mail and send it for you when you click “file”.

If you need more information, the State Board Manual is a great resource from which we’ve taken today’s screenshots.

Regardless of how you file, be sure to get it done!

Go get’em!

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