Mission Complete: The Post-Election Winding Down Checklist for Treasurers
You asked: The election is over. Can I just empty the bank account and walk away?
The direct answer is absolutely not. “Ghosting” the FEC and the IRS is a federal offense.
Whether you are popping champagne or packing boxes, the days following the election are the most dangerous for a Treasurer. You are exhausted, the staff is leaving, and the adrenaline is gone. Yet, this is exactly when the regulatory clock starts ticking.
Leaving a campaign committee “open” indefinitely bleeds money through bank fees, compliance software costs, and ongoing reporting requirements. Worse, failing to officially close your payroll tax accounts can lead to years of automated penalty notices from the state.
Use this “Winding Down” protocol to close the books cleanly.
Phase 1: The “Zero Balance” Objective
You cannot terminate a committee with the FEC until your Cash on Hand is $0.00 and your Debts are $0.00.
Step 1: Clear All Outstanding Checks:
Chase down every consultant and canvasser who hasn’t cashed their check yet. You cannot close the bank account until these clear.
Pro Tip: If a vendor has vanished, do not just keep the money. You may need to follow state “unclaimed property” laws.
Step 2: Asset Disposition (The “Fire Sale”):
You have 10 laptops, 5 iPads, and office furniture. You cannot simply give these to the candidate or staff (that is personal use of campaign funds).
Sell them at Fair Market Value to the candidate, a future campaign, or a third party. Deposit the proceeds back into the campaign account to pay off debts.
Step 3: Debt Settlement:
If you lost and have debt, you must negotiate. If a vendor agrees to settle a $10,000 bill for $5,000, you must file a Debt Settlement Plan (FEC Form 8). The FEC must review and approve this before you pay the settlement amount.
Phase 2: The Final Filings (FEC & IRS)
This is the “Compliance Shield” in action. Do not assume these agencies know you are done just because the election date passed.
The “Termination Report”:
On your final FEC report (Form 3), check the “Termination Report” box.
Warning: The FEC analyzes this report rigorously. If there is a $5 discrepancy in your Cash on Hand, they will reject the termination, forcing you to keep filing reports.
The IRS “Final Return”:
When we file your Q4 Form 941 (Employer’s Quarterly Federal Tax Return), we must check the box that says “Final Return” and enter the date final wages were paid.
If you miss this checkbox, the IRS computers assume you are still operating and will fine you for failing to file in Q1 of next year.
Phase 3: State Tax Account Closure
This is where most campaigns get stuck in “zombie mode.”
- State Unemployment Agencies: You must formally notify the state Department of Labor that the business has ceased operations. If you don’t, they will assign you a maximum tax rate and send collections agents after the committee for “unpaid” taxes on $0 wages.
- Secretary of State: If you registered as a distinct legal entity (LLC or Inc.), you must file Articles of Dissolution.
Phase 4: The 4-Year Archival Rule
Once the bank account is closed, you are not free yet. You are now the “Custodian of Records.”
- IRS Rule: You must keep all employment tax records (W-4s, I-9s, payroll logs) for 4 years after the tax was due.
- FEC Rule: You must maintain records of all receipts and disbursements for 3 years after the termination report is filed.
- The Strategy: Do not leave these boxes in the candidate’s garage. Scan everything. Upload it to a secure cloud drive. If an audit comes in 2027, you need to be able to find a specific canvasser’s timesheet from October 2024 within 24 hours.
How AccuPay Locks the Door
Closing a campaign is often harder than starting one because there is no staff left to help.
AccuPay Systems manages the exit process for you. We automatically flag your final payroll returns as “Final” with the IRS and state agencies. We generate a digital “Audit Packet” containing all payroll journals and tax filings, perfectly organized for your 4-year retention requirement.
We ensure that when you walk away, you never have to look back.