A PAC or independent expenditure committee runs two digital programs at once. One raises money for the committee. The other spends that money to persuade voters and turn them out. They use the same tools, digital ads and texting, but they answer to different rules and should be measured in different ways.
Know what kind of committee you are
Committee type decides what you can raise and how you can spend it.
A traditional PAC accepts contributions subject to limits and can give directly to candidates. A super PAC (formally an independent expenditure-only committee) can raise unlimited amounts from individuals and many organizations, but it cannot contribute to candidates or coordinate with them. Some committees run separate accounts for each type of activity. State-level committees follow their own state's rules, which vary widely on limits, registration and reporting.
A 501(c)(4) is not a PAC. Some (c)(4)s make independent expenditures, which brings FEC or state reporting and keeps political activity from becoming their primary purpose, but they are a different kind of organization with different rules. If your group is both, keep the entities, accounts and lists separate.
Independence is the rule everything else depends on
An independent expenditure is a communication that expressly advocates for or against a clearly identified candidate and is not coordinated with that candidate, the candidate's committee or a party. Coordination turns the spending into a contribution, which a super PAC cannot make and a traditional PAC can make only within its contribution limits.
In practice, independence comes down to what you know and where it came from. Use only public information: the candidate's public statements, voting record, website, news coverage and public filings. Do not take direction on messaging, targeting, timing or spending from the campaign, directly or through a go-between.
The weakest point is usually a shared person or vendor. Federal rules treat common vendors and former campaign staff as possible paths for coordination. If a vendor works for both a candidate and a committee in the same race, it needs a written firewall: different staff on each account, no shared files or meetings about the race, and a policy every staff member has signed. Ask any vendor you hire whether they work for a candidate in your race and how their firewall works.
Reusing a campaign's own materials is another trap. Footage, photos or graphics the campaign produced can create problems even when they are posted publicly. Get counsel's sign-off before using anything the campaign made.
Disclaimers on ads and texts
Every public communication from the committee needs a "paid for by" disclaimer naming the committee. Independent expenditures also need a statement that the communication is not authorized by any candidate or candidate's committee. A standard version:
Paid for by [Committee Name] ([website]). Not authorized by any candidate or candidate's committee.
Fundraising solicitations need disclaimers too. Federal rules have specific provisions for digital ads and for formats too small to fit a full disclaimer, and several states have stricter or different requirements. Most major ad platforms also require the committee to complete a political-ad authorization before ads run. Start it well before launch.
For texts, identify the committee by name, include opt-out language and respect quiet hours (8 a.m. to 9 p.m. in the recipient's local time is the common standard, and some states are narrower). How disclaimer rules apply to text messages differs by jurisdiction, so confirm the format with counsel before the first send.
Reporting independent expenditures on deadline
Federal independent expenditures above set thresholds must be reported to the FEC within 48 hours, and within 24 hours in the final weeks before an election. The trigger is generally when the communication is publicly disseminated, which for a digital program means when ads start running or texts start going out. States run their own reporting schedules, often on short clocks near Election Day.
The practical step is to give your treasurer a dated record of every flight and send: when it started, what it cost, which candidate it was about, and whether it supported or opposed them.
Raising money for the committee
Committee fundraising is donor acquisition and donor upgrades, and it works the same way it does for a campaign. Digital ads build the list and bring in first gifts. Texts bring those donors back.
Committees have a harder pitch than candidates. Donors know the candidate. They often do not know the committee. Good fundraising copy for a committee ties the gift to a specific, visible action:
"We're putting the ad exposing Rep. Doe's vote on drug prices in front of voters in the 5th District this week. Chip in $15 to keep it running through the weekend: [link]"
That message names the race, the action and the deadline. It must also be true, so keep the fundraising calendar matched to the spending plan.
Two compliance items matter here. The committee has to make its best efforts to collect the name, address, employer and occupation of donors who give more than $200, which donation platforms handle if the forms are set up correctly. And the committee must screen out prohibited sources, such as foreign nationals.
Every ad and every text gets a refcode on ActBlue, or a source code on EveryAction, so each gift is matched to the message that raised it. That is how you know which creative earned its budget and which did not.
Persuasion and turnout spending
Persuasion and turnout are different jobs. Persuasion ads aim at voters who could go either way and give them a reason to move: a contrast on a single issue, a vote they did not know about, a local story. Turnout messages aim at supporters who might stay home and give them the date, the polling place and a nudge.
For persuasion, a short video or a static graphic built around one claim with a cited source usually beats a list of grievances. Write the claim so it holds up to fact-checking. Committee ads draw scrutiny from reporters and the opposing campaign, and a correction story costs more than the ad was worth.
Texting fits turnout well. A useful sequence includes a reminder that early voting has opened, a polling-place lookup the weekend before, and an Election Day message. Each message should be short and carry one link. Long texts split into multiple segments (a standard SMS segment holds 160 GSM-7 characters), which raises cost and can arrive out of order.
Test creative before the money is committed
Run several versions of each message early, with real budget behind each, and let the results decide where the rest goes. Test one thing at a time where you can: the issue, the messenger, the opening line, the image. For fundraising, the comparison is straightforward because refcodes tie dollars to each version. For persuasion, you need a measure of persuasion itself, covered below.
Keep a log of what you tested and what won.
Measuring each kind of spending
Fundraising is measured in dollars by refcode: money raised, number of donors and repeat gifts per message. Those numbers are exact because each gift carries its code.
Persuasion is harder. Reach and frequency tell you who saw the ad and how often, which is necessary but does not show minds changed. To measure lift, hold out a randomly selected group of the target audience that does not see the ads, then survey both groups. A difference in support between them is your effect. Platform lift studies do a version of this. Polling your target audience before and during the flight is another check, and it is work we do alongside the ad program. Treat any single result with care when the sample is small.
Turnout can be measured after the election, when voter files show who voted. Compare turnout among people you texted with a held-out group you did not. Planning that holdout before the program starts is what makes the measurement possible.
This is general information, not legal advice. Check specifics with your compliance counsel.
If you run a PAC or IE committee and want ads, texts and refcode reporting built for your program, talk to us.