Unpresidented
For a former president, Trump’s fundraising operation has been unprecedented in modern memory. As will his all but inevitable plunge back into the pool, the third consecutive run for an elected president.
But that operation must work within regulatory constraints, and by forcing the issue early, Trump risks repeating a mistake he made in 2020—tapping donors dry just as the race hits the home stretch.
The Labyrinth
The full Trump money apparatus is so large and incestuous that his own team can’t seem to make sense of it, as Pay Dirt reported last month.
But at the center of that labyrinth are three main committees, which Trump’s fundraisers configured to give the former president maximum control over a huge stream of the Republican Party’s cash flow.
That overhaul wasn’t just about money—it may have been partly responsible for salvaging Trump’s standing within the GOP.
The operation kicked in just weeks after Trump left office, while the GOP was trying to gather itself after the tumult of Jan. 6 and impeachment, and many party leaders were quietly looking elsewhere for leadership. But Trump’s quick financial moves gave him some leverage over the party that he desperately needed at the time.
No Limit Hold ’Em
Trump still has a long way to go. While he personally might like to run a forever campaign, the government puts limits on how much money he can raise to fuel it—and when.
The first issue is the donations themselves. The Federal Election Commission allows candidates to raise a maximum $2,900 per donor for the primary, and another $2,900 for the general election—although supporters can max out with one lump $5,800 gift before the primary.
That means Trump has a ceiling. And he might bump up against it—again.
With weeks to go before the 2020 election, Trump’s donor receipts began to drop off. That’s because, unlike any other president, Trump never stopped raising money after taking office, and after three years of hitting up donors, those contribution limits had begun to kick in across the board.
While Trump could put himself in a similar bind for 2024, he’s got more in the tank. At the end of 2017—the equivalent of the end of 2021, in terms of election cycles—Trump held a little less than $20 million in his campaign account.
I’m Not Here to Make Friends
Those walls are still up today. And on the other side of fundraising—spending—Trump hasn’t been exactly the most generous gatekeeper. With a few exceptions, he’s kept his hoard to himself.
As Pay Dirt previously reported, Trump did put more than $3.1 million into two PACs backing former GOP Sen. David Perdue’s failed gubernatorial bid in Georgia—though Trump bailed on Perdue just ahead of the election. A super PAC targeting Trump nemesis Rep. Liz Cheney (R-WY) got multiple six-figure gifts as well. And—as the Jan. 6 committee pointed out on national television—Trump also shined a million-dollar smile on the conservative nonprofit that employs his former chief of staff, Mark Meadows.
But in the run-up to the 2020 election, Trump gave less than $40,000 to candidates—total. Over that same time period, his campaign dropped $1.5 million at his own properties. With a field of 2024 GOP challengers quietly amassing in the wings, however, Trump may need to rethink this “I alone” strategy.
I Am the Law
A senior Trump campaign adviser told The Daily Beast that the team isn’t concerned about bleeding donors out too early. They anticipate they’ll be able to evenly parcel out the cash with data-driven recurring small-dollar donations—which are currently the focus of investigations in at least four states.
Whenever he announces, Trump will convert his Make America Great Again PAC back to his official campaign committee. But at that point, he won’t be allowed to tap his biggest account to support his campaign—the $100 million currently stashed in his “Save America” leadership PAC.
It’s likely, then, that Trump will first carve out a massive slice of cash for his campaign—which he may have already done.
Thanks to reporting rules, we won’t see that transfer of funds until the next round of reports are due in July. And with Trump’s layered committees, we might have to wait months later if the transfer happens after June 30.
Such a move could also test legal standards about which money can be designated for campaign activity. Small wonder, then, that Trump fretted so much about those rules while mulling an official announcement over the last year.
But even that’s a bit of a head-scratcher. Out of dozens of referrals, the FEC’s Republican commissioners have never—not once—voted to take legal action against Trump, even when the agency’s own internal attorneys have found “reason to believe” his committees committed violations.
It’s possible that Trump’s team will interpret this pattern as a sign, and feel emboldened to experiment with creative fundraising approaches. Unless, of course, the Jan. 6 committee’s investigation shuts them down first.
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