We are building a campaign-finance compliance checking tool for political committees. The tool verifies that contribution and expenditure reports meet the requirements of either Federal (FEC) or Pennsylvania state campaign finance laws. It will also print out the finance reports in the proper PDF dictated by the state or fedeal governmetn.

It accepts financial data in Excel format, performs rule-based compliance checks for the selected jurisdiction, and produces a human-readable report of any errors or warnings.

The tool is configurable to adapt to changing legal limits and reporting periods, ensuring up-to-date compliance validation. It integrates key requirements from official FEC and Pennsylvania forms, without generating official filing notices (e.g. 48-hour notices) – The following sections detail the tool’s features, input format, configuration, and output, with references to relevant official sources for clarity and verification.

First User Input Jurisdiction Selection (Federal vs. Pennsylvania)
-------------------------------------------------

Upon starting the tool, the user must select the jurisdiction – either Federal (FEC) or Pennsylvania – which determines the rule set and forms to apply. This choice tailors the compliance checks and output format to the appropriate regulatory regime:

- Federal (FEC) Mode: The tool checks data against Federal Election Commission rules. It aligns with the requirements for FEC Form 3 (the _Report of Receipts and Disbursements_ for House/Senate campaign committees) and Form 3X (for PACs and party committees)[fec.gov](https://www.fec.gov/help-candidates-and-committees/forms/#:~:text=Form%203%3A%20Report%20of%20Receipts,and%20Disbursements)[fec.gov](https://www.fec.gov/help-candidates-and-committees/forms/#:~:text=Form%203X%3A%20Report%20of%20Receipts,and%20Disbursements). All relevant federal limits and prohibitions (e.g. contribution limits per election, source restrictions, itemization thresholds) are enforced. For example, the federal individual contribution limit ($3,300 per election for 2023-24) is built in[fec.gov](https://www.fec.gov/resources/cms-content/documents/contribution_limits_chart_2023-2024.pdf#:~:text=Individual%20%243%2C300,per%20year). The tool willproduce an FEC filing, and it ensures the data could be reported on the appropriate FEC forms without compliance issues.

- Pennsylvania State Mode: The tool checks data against Pennsylvania’s campaign finance laws and reporting forms. It reflects the requirements of the Pennsylvania Campaign Finance Report (DSEB-502) and the short-form Campaign Finance Statement (DSEB-503)[pa.gov](https://www.pa.gov/agencies/dos/resources/voting-and-elections-resources/campaign-finance-forms-and-reports.html#:~:text=%2A%20Campaign%20Finance%20Report%20%28DSEB)[pa.gov](https://www.pa.gov/agencies/dos/resources/voting-and-elections-resources/campaign-finance-forms-and-reports.html#:~:text=%2A%20Campaign%20Finance%20Statement%20%28DSEB). (DSEB-502 is the standard report for candidates, committees, and lobbyists disclosing contributions and expenditures, while DSEB-503 is a simplified statement allowed when totals do not exceed $250 in a reporting period.) In this mode, state-specific rules (such as the absence of contribution dollar limits for most donors at the state level [afj.org](https://afj.org/wp-content/uploads/2018/06/Pennsylvania-Campaign-Finance.pdf#:~:text=Individuals%20Unlimited%20Phila%3A%3A%20%243%2C0001%20per,election3%20Unlimited%20Unlimited%20Unlimited%20Unlimited), but prohibition of corporate donations [afj.org](https://afj.org/wp-content/uploads/2018/06/Pennsylvania-Campaign-Finance.pdf#:~:text=%EF%82%B7%20Corporations%2C%20labor%20unions%20and,may%20sponsor%20a%20political%20committee)) are applied. The tool helps ensure the data is compliant with Pennsylvania’s reporting law and can be readily transferred to the official forms.

Internal Handling: The jurisdiction selection influences which configuration profile (limits, thresholds, etc.) is loaded and which rule checks are active. For example, FEC mode will enforce per-election contribution limits and require donor occupation/employer disclosure for contributions over $200, while Pennsylvania mode will enforce its own disclosure rules and flag prohibited corporate contributions (since PA law doesn’t impose dollar limits on individual contributions, but bans corporate/union contributions directly to candidates[afj.org](https://afj.org/wp-content/uploads/2018/06/Pennsylvania-Campaign-Finance.pdf#:~:text=%EF%82%B7%20Corporations%2C%20labor%20unions%20and,may%20sponsor%20a%20political%20committee)). The user’s choice of jurisdiction is thus critical to contextually correct compliance checking.

This might be an example of a configuration file

federal:
  individual_limit: 3300      # per election
  multicandidate_pac_limit: 5000
  cash_contribution_limit: 100
  itemize_threshold: 200
  aggregation_window_days: 0   # aggregate entire cycle

pennsylvania:
  individual_limit: 9,000,000      # really unlimtied
  multicandidate_pac_limit: 9,000,000
  cash_contribution_limit: 100
  itemize_thresholds:
    - {max: 50, level: "UNITEMIZED"}
    - {min: 50.01, max: 250, level: "ITEMIZE_NO_EMPLOYER"}
    - {min: 250.01, level: "FULL_ITEMIZE"}

Input Data: Excel Sheets Format
-------------------------------

The tool accepts three Excel worksheets as input, each containing detailed transaction or entity data. All input sheets should include a header row with the prescribed column names. If there are extra columns they should be ignored. The required sheets and their fields are:

### 1\. Contributions Sheet

This sheet lists **all receipts** of the committee within (and relevant to) the reporting period. “Contributions” here include monetary contributions from individuals or entities, as well as other types of receipts (e.g. refunds, interest, loans, or in-kind contributions) if applicable. Each row represents a contribution or receipt transaction. The expected columns (fields) include:

* ID"Contact-",Names," ",
* Names
* Type
* First Name
* Middle
* Last Name
* email
* Phone
* Address 1
* Address 2
* City
* State
* Zip
* Date Recieved
* Amount
* Payment Method
* Contribution Type
* Credit Card Fee
* Note
* Check Date
* Check Number
* Deposit Date
* Embassy ID
* ActBlue ID
* Occupation
* Employer Name
* Employer Address
* Employer City
* Employer State
* Employer Zip

- **DateRecieved** - Date the contribution was received (format `YYYY-MM-DD`).

- **Amount** – Monetary amount of the contribution. Positive values indicate money received by the committee. _Negative values_ are allowed here to represent a **refund issued to a donor** or a bounced/returned contribution (see “Negative Values” below for handling).

- **Contribution Type** – Category of contribution (examples: “Individual”, “PAC”, “Party”, “Self-Fund”, “In-Kind”, “Loan”, etc.). This can be used to apply specific rules (e.g. PAC contributions have different limits than individual, loans are handled separately). NINA, we need to know what these ruls will be as the STATE and FEC

- **Aggregate to Date** – calculated field The total amount contributed by this donor for the election cycle or calendar year, up to and including this contribution. If the user provides this, the tool will use it to evaluate thresholds (like $200 itemization requirement or contribution limits). If not provided, the tool can calculate the aggregate by summing all contributions from the same contributor (using Contributor ID) within the relevant cycle (including prior periods if those are loaded or if a **prior aggregate** value is stored in Contacts). For FEC compliance, aggregate per donor per election is crucial for limit enforcement and for determining if a donor’s total exceeds itemization thresholds.

- **Notes** – _(Optional)_ A note about the contribution, e.g. “Dinner event fundraiser” or, for in-kind contributions, a description of the goods/services received. In FEC filings, in-kind contributions require a description of what was provided. The tool will ensure this field is present for in-kind contributions and will flag if missing. Also, earmarked contributions or those forwarded by intermediaries might be noted here (the tool would flag if additional disclosure like Form 3L might be required, though Form 3L is outside the main scope).

**Field Validations:** The tool will verify the contributions sheet for completeness and correctness: dates must fall within the selected reporting range (or relevant aggregate period for totals), amounts should be numeric, contributor references must match an entry in the Contacts sheet, and required descriptions must be present for applicable types. If any required field is missing or improperly formatted (e.g. a date that isn’t a valid date), an error will be flagged. NINA what else should we put in here

### 2\. Disbursements Sheet

This sheet contains all expenditures or disbursements made by the committee in the reporting period. Each row is an outgoing payment (e.g. operating expenses, contributions made to other committees, loan repayments, independent expenditures, etc.). Expected columns include:

* ID
* Names
* Date Issued
* Amount
* Payment Method
* Check Date
* Check Number
* Type
* Description of Expenditure
* Source Document
* Debt Repayment
* First Name
* Middle
* Last Name
* Address 1
* Address 2
* City
* State
* Zip
* Post Date
* Embassy ID

- **Date Issued** – Date the disbursement (expense) was made.

- **Amount** – Monetary amount of the disbursement. Positive values indicate money spent by the committee. _Negative values_ can be used to indicate money returned to the committee (e.g. a refund or rebate from a vendor). In practice, refunds of expenditures could also be recorded as a separate “receipt” in the Contributions sheet; however, if negative entries are provided here, the tool will interpret them as credits (see “Negative Values” handling). NINA - how are negative numbers handled and in what period

- **Description of Expenditure** – A description or category of the expense. This is a critical field for compliance: it should clearly explain what the funds were used for (e.g. "Office Supplies", "TV Advertising", "Donation to X Committee", "Polling", "Staff Salary", etc.). The tool will flag entries with missing or vague purpose descriptions, as both FEC and PA require _adequate purpose descriptions_ for expenditures[pa.gov](https://www.pa.gov/agencies/dos/resources/voting-and-elections-resources/campaign-finance-forms-and-reports.html#:~:text=,503)[fec.gov](https://www.fec.gov/help-candidates-and-committees/forms/#:~:text=Form%203%3A%20Report%20of%20Receipts,and%20Disbursements). For FEC, there is guidance on acceptable purpose descriptions; for PA, similar clarity is needed. The tool may use a configurable list of keywords or simply flag if the field is empty or too generic (e.g. “Miscellaneous” alone would trigger a warning).

- **Expenditure Type/Category** – NINA CHECK ALL OF THIS: A classification of the disbursement, such as “Operating Expense”, “Contribution Made”, “Independent Expenditure”, “Loan Repayment”, etc. This helps apply specific rules. For example, if _Independent Expenditure_ is indicated, the tool will apply additional checks relevant to independent expenditures (like 24/48-hour reporting triggers in both jurisdictions). If _Contribution Made_ (i.e. your committee gave money to another candidate/PAC), different limits or aggregate tracking might apply (federal law limits how much a candidate committee or PAC can contribute to another, and those limits would be in the config). If not explicitly provided, the tool might infer type from context (e.g. if Payee is another political committee in Contacts, it might assume it’s a contribution to that committee).

### . Contacts Sheet

This sheet provides a master list of entities and people** referenced in the other sheets. It contains detailed information for each contributor or payee, which is used both for populating reports and for certain compliance checks (e.g. verifying donor eligibility or required information). Each row is a contact with the following fields:

* Name
* Total Contribution
* Total Disbursement
* Type
* First Name
* Middle
* Last Name
* Address 1
* Address 2
* City
* State
* Zip
* Occupation
* Employer
* Email
* Phone
* Employer Address 1
* Employer Address 2
* Employer City
* Employer State
* Employer Zip
* Link to Contributions
* Link to Disbursements
* Contributions copy

NINA for all of the fields we need to know which ones are required for the program and which ones can be ingored

**Field Validations:** The Contacts sheet is checked to ensure required fields are present for each type of contact. The tool will flag if an individual lacks an address, city, state, or ZIP (all must be reported for itemized contributions). It will flag if occupation/employer fields are blank for an individual who contributed over the threshold. The user should be able to say it is okay as is or go back to fix the file

Reporting Date Range Selection
------------------------------

The user can specify the reporting date range for which compliance is being checked (typically this corresponds to a specific report period, such as a quarter, pre-election report, calendar year, etc.). NINA are things in the app that tell you what reporting period. if so we need to develop a list of both.

- **Filtering Transactions:** Upon selecting the date range, the tool will include only those contributions and disbursements whose dates fall within the start and end date (inclusive). HOWEVER, it will go from the beinging of a peiod to an end of a period also sepcified by the user to see if any one person or committee exceed the amount they can give but it occurred in more than one transaction come up with examples

- **Aggregate Calculations:** NINA this is for making notes like if someone hit $in the period

- **Reporting Period Selection:** THESE MIGHT BE DIFFERENT FOR PA and FEC

## Compliance Checks and Rules

### Pennsylvania

### FEC

Negative Numbers Allowed in specific contexts, like:

Returned checks (e.g., insufficient funds): report as negative entries on the same line/category originally reported (e.g., Schedule A for contributions)

Refunds of contributions previously received: also negative entries on Schedule A, reducing cumulative totals.

Contribution Refunds
Schedule B is used to report refunds of previously itemized contributions

Include contributor's name, address, date, amount, and reason (“contribution refund”).

Applies to individuals, party committees, and other PACs (Line 20a, 20b, or 20c).

Always itemized—no matter the amount

NOTE may not be programmatic checking but
Redesignations
If a contribution exceeds limits or is improperly labeled:

You may presumptively reattribute (e.g., split between spouses if both are named on the check).

Or presumptively redesignate (e.g., move excess from primary to general).

Must notify donor within 60 days, and report with a memo entry referencing the original and new attribution

Best Efforts Compliance
For any contribution over $200, you must collect:

Full name

Mailing address

Occupation

Employer

If you can’t get this, you must:

Include a clear request on your donation forms

Make one follow-up attempt within 30 days of receiving the donation

This protects the campaign under the FEC’s “best efforts” standard (11 CFR §104.7)

In-Kind Contributions
Must be reported twice:

On Schedule A as a contribution received.

On Schedule B as an expenditure made.

Label clearly as "in-kind" with a description like “polling,” “event space,” or “graphic design.”
.
Cash on Hand
Line 8 of the Summary Page (Page 2) is calculated:

Line 25 (start cash + receipts) minus Line 26 (disbursements) = Line 27 (end cash)

You cannot manually insert or fudge cash balances—they must reconcile across reports.