RD344 - Virginia Department of Elections Campaign Finance Reports and Records Review – July 1, 2025


Executive Summary:

Purpose of Report

2022 Acts of Assembly Chapter 258 (HB 492), which added Va. Code § 24.2-948.5(*1), went into effect January 1, 2024. It requires that the Department of Elections (ELECT) review campaign finance reports and records prepared by a selection of candidate campaign committees within 180 days following the November General Election. The purpose of the review is to: (1) reconcile the balance in the campaign depository with the amounts reported in the candidate's reports of receipts and expenditures, and (2) review the reports for mathematical accuracy and facial completeness including the reporting of specific information required by law.

Following a random selection of seven candidate campaign committees at the State Board of Elections meeting on November 18, 2024, ELECT undertook a process for the review of campaign finance records and individual campaign committee record submissions. In furtherance of the statutory requirements, the Campaign Finance Reports and Records Review (referred to in this report as “CFR(*3)" or “review") was designed to focus on the required areas of campaign depository reconciliation, mathematical accuracy and facial completion of submission.

Key Findings and Highlights

• The review for the 2024 General Election (“2024 review") revealed an 84% Overall Compliance(*2) for areas that could confidently be tested:

o Reconciliation checks identified 77% accuracy compliance.
o Mathematical Accuracy checks confirmed the reliability of the selected campaign committee reports with 98% compliance.
o Facial Completeness checks showed 79% compliance.
o Timeliness checks had a rate of 95% across all committees indicating that committees effectively complied with the report submission timeline requirements.

• While the review revealed some mathematical discrepancies in reported data across the selected committees, most could reasonably be attributed to timing differences between financial statement production dates and the close of filing periods.

• Generally, selected committees complied with requests for financial records and supporting documentation (e.g., bank statements, copies of checks), though for a small percentage of requests either the documentation was not provided, provided and not reported, or the provided copies were illegible.

• The 2024 review highlighted several compliance challenges and limitations within the Virginia Campaign Finance System. Addressing these issues through targeted system improvements will enhance the system's transparency, accountability, and overall effectiveness in managing campaign finance activities and providing accessible, user-friendly data.(*3)

• While only one percent of candidate committees for local elections were required to be reviewed in 2024, the required data analysis was nevertheless a significant undertaking. The review in 2025 will be significantly larger in scope and must include all committees for candidates for statewide office, 10 percent of committees for candidates for House of Delegates, and one percent of committees for candidates for all other offices.(*4)
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(*1) See Appendix E for Statutory Excerpt of § 24.2-948.5
(*2) See Figure 3: Aggregate Review Results (all campaign committees)
(*3) As part of the budget from the 2025 General Assembly Session, ELECT was provided an appropriation to develop a plan for the replacement of the Committee Electronic Tracking (COMET) and Campaign Finance Management (CFM)
(*4) Va. Code § 24.2-948.5(B).