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Understand the information required, the follow-up process, and the records your committee needs to retain.
A contributor gives $500 through your online platform, providing a name and mailing address but leaving the occupation and employer fields blank.
That omission is not yet a compliance failure. It becomes one if the committee takes no action within the following 30 days.
Federal law addresses this situation through the standard known as best efforts to document receipts. It is among the less visible sources of reporting deficiencies, regulatory inquiries, and late-cycle remediation work—and at 9Seven Consulting, we regularly encounter it at well-funded, well-staffed committees whose operations are otherwise sound.
This guide explains what the best efforts standard requires and what it means for committee leadership.
What the Best Efforts Standard Requires
For any individual contributing more than $200, a committee must report four items: the contributor's full name, mailing address, occupation, and employer.
Contributors frequently omit this information, and the law recognizes as much. It does not require a committee to report information it cannot obtain. It requires the committee to demonstrate that it made a genuine and properly documented attempt to obtain it.
That is the essence of best efforts. Compliance is measured not by whether the contributor responded, but by what the committee did when the contributor did not.
It follows that the record of the request carries more weight than the information itself. A committee that requested the information correctly and retained the record is in compliance. A committee that received the information but maintained no process is exposed the first time its practices are examined. The underlying rule is set out at 11 CFR 104.7.
When Best Efforts Applies
The best efforts threshold is $200, but the measurement period depends on the type of committee.
Candidate committees. The obligation applies to any individual whose contributions exceed $200 over the election cycle.
PACs and party committees. The obligation applies to any individual whose contributions exceed $200 within a calendar year.
Two features of the rule are frequently misunderstood.
The threshold is cumulative. A contributor who gives $150 in March and $150 in August has crossed it, even though neither contribution did so individually. The rule applies to the aggregate, not to individual contributions.
The obligation applies regardless of solicitation. An unsolicited contribution received by mail carries the same requirements as one the committee actively pursued.
The Four Components of Best Efforts
1. Requesting the information at the point of solicitation
Every written solicitation must request the contributor's name, address, occupation and employer, and must include a statement that federal law requires the committee to collect this information. That statement is what brings the solicitation within the best efforts standard.
The requirement extends to online contribution pages, reply devices and checkout screens — not only the solicitation letter. A request that appears in the letter but not on the accompanying reply device does not satisfy the standard.
The request must also be clear and conspicuous. A notice printed in smaller type than the surrounding material, or placed where it is easily overlooked, does not qualify. The rule is designed specifically to prevent committees from minimizing it.
2. Following up within 30 days
Where a contributor has not provided the required information, the committee must make at least one follow-up request within 30 days of receiving the contribution.
The rules governing that follow-up are more restrictive than committees often expect:
It may not include a solicitation. This is the most common error we encounter. A request for employer information that also invites an additional contribution does not qualify as a valid follow-up, and it negates the committee's best efforts position.
It may not address any other subject. Newsletters, event invitations and campaign updates must be excluded. The committee may thank the contributor.
Mailed requests must include a pre-addressed return envelope.
Telephone requests must be memorialized in a written record. An undocumented call is treated as though it did not occur.
Email is permitted and is the method most committees use.
It must restate the best efforts notice regarding the requirements of federal law.
The committee must retain records of each request. A follow-up that cannot be substantiated has no value if the committee's practices are reviewed.
3. Using information already in the committee's possession
If the contributor does not respond, the committee's obligation continues.
Where the required information already exists in the committee's own records — its contributor database, fundraising records or reports filed earlier in the same cycle — the committee must use it.
This is the deficiency Thomas Datwyler most frequently identifies when our firm assumes responsibility for a committee's books. The employer information is present in the prior year's records, while the current report reads "information requested." To an outside reviewer, that indicates a committee that did not consult its own files.
4. Correcting reports when information arrives late
When a contributor supplies the information after the committee has filed, the committee may either amend the original report or include the corrected information in its next regularly scheduled report, with a reference to the original filing.
Either approach must cross-reference the earlier report, and the obligation applies only to contributions received during the current two-year cycle.
Why Best Efforts Warrants Leadership Attention
Candidates and committee leadership rarely perform this work themselves. It nonetheless merits their attention for four reasons.
It generates regulatory correspondence. Incomplete contributor information is among the most common reasons committees receive a Request for Additional Information. The response period is 35 days and cannot be extended.
It consumes capacity at the worst possible time. These deficiencies surface during report preparation, when the committee's staff is most constrained. Remediating months of incomplete records immediately before a filing deadline is entirely avoidable.
It is public. Committee reports are reviewed by journalists, opposition researchers and competitors. A filing with extensive "information requested" entries reflects on how the committee is managed.
A proactive filing can prevent it. A committee may submit a written description of its best efforts procedures at the beginning of a cycle, which may prevent later inquiries regarding missing contributor information. The submission is optional and requires modest effort. Thomas Datwyler recommends it to every committee our firm serves; few committees undertake it independently.
Where Committees Fall Short on Best Efforts
These are the deficiencies we encounter most often when a new client transfers its records to us:
The follow-up included a solicitation, which invalidates it regardless of intent.
The online contribution page treated employer as optional without the required notice. The platform's default configuration becomes the committee's compliance exposure.
The 30-day period was measured from the wrong date. It runs from receipt of the contribution, not from the start of report preparation.
No one was assigned responsibility. This is the root of each deficiency above, and the reason best efforts fails at otherwise disciplined committees. The work is not complex; it is recurring work with a deadline that is easy to lose sight of.
How 9Seven Consulting Manages Best Efforts
Committee leadership should be focused on the campaign, not on incomplete contributor records.
We manage best efforts as a standing component of every engagement Thomas Datwyler oversees. Thomas Datwyler designed the process, and we apply it consistently across every client: we review contribution pages and solicitation materials before they are released, track follow-up requests against the date each contribution was received, maintain records in a form that can be produced on request, and file corrections when late information arrives. Clients are generally aware of this work only because their reports are clean.
9Seven Consulting was founded in 2013 by Thomas Datwyler, former controller of a $52 million presidential campaign. The firm has served more than 400 political committees, filed more than 4,000 FEC reports and reconciled more than 7,500 bank statements.
Committees whose reports carry contributions with incomplete employer information and no documented best efforts follow-up should address that gap before the next filing.
Frequently Asked Questions
What does best efforts mean for a campaign?
Best efforts means a committee is not penalized for contributor information it genuinely could not obtain, provided it can demonstrate that it requested the information properly, within the required period, and retained the records.
What contributor information must a committee collect?
Full name, mailing address, occupation and employer, for any individual contributing more than $200 — measured over the election cycle for candidate committees and over the calendar year for PACs and party committees.
How long does a committee have to follow up?
Thirty days from receipt of the contribution. At least one follow-up is required, whether or not the contribution was solicited.
May a follow-up request include a contribution link?
No. This is the most common error we encounter. A follow-up that solicits a contribution does not satisfy the requirement.
What if the contributor never responds?
The committee has met the best efforts standard, provided it requested the information correctly, documented the request and used any information already in its own records.
Who should manage best efforts for a committee?
A professional with defined responsibility and an established process. Thomas Datwyler and our team at 9Seven Consulting manage best efforts for campaigns, PACs, party committees and nonprofits, including the optional procedural filing that helps prevent regulatory inquiries.
This article is general information about federal campaign finance reporting. It is not legal advice.
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