The Trump campaign recently announced their June fundraising totals, which indicate that his new online effort was able to begin bringing in millions of dollars, with 94% of those funds from donations of under $200. What the release did not indicate, however, was any sort of momentum with Republican major donors, who currently face difficult choices in what has become the most unpredictable election year in most of our lifetimes. 

During past cycles, presumptive nominees such as George W. Bush, John McCain, and Mitt Romney moved swiftly well in advance of the national convention to establish a sense of unity, if for no other reason than to self-servingly send a clear message to party major donors and conservative activists that the party apparatus was on the same page as them. Because there has not been this outreach from Donald Trump, in this election if Republican donors are going to open their purse strings and become engaged, then they owe it to themselves to understand how different types of donations will be used.  

The 2008 and 2012 general elections offered a linear set of options for major party donors. You first gave the maximum amount allowed under FEC limits directly to the campaign, then gave to the RNC Victory joint fundraising committee (JFC). In the case of Mitt Romney’s effort in 2012, donors had a third option — Restore Our Future was an efficient, administratively lean and well-run super PAC that independently supported Romney. This year, the decision tree of where to give is far different for Republicans donors. 

First, there is the issue of a nominee that pledged on numerous occasions to self-fund his campaign. Despite the lack of an FEC filing to prove it, Donald Trump claims that he has officially forgiven his personal loans of $50 million to his campaign. Assuming that is true, the next step for Trump to successfully raise money is to immediately demonstrate that he’s serious about investing in his own campaign, and that means putting $200 million or more of his own money behind his bid. That commitment will open up skeptical donor pockets and start Trump down the road towards the $400 million of direct campaign funds that he will need to run even the barest bones national campaign. 

Donors considering whether and where to give need to determine if their priority is to support Trump presidential efforts or to retain a Republican majority in the Senate. For the presidential effort, Trump Victory JFCs are vehicles designed to give the RNC and Trump team full control over the donated funds. 

If a donor would rather focus on sustaining Republican control over the U.S. Senate as an insurance policy against a corrupt Clinton presidency or an unpredictable Trump administration, then the National Republican Senatorial Committee’s (NRSC) “Targeted State Victory” JFC is a new option. This committee partners with state parties in Arizona, Colorado, Florida, Nevada, New Hampshire, Ohio, Pennsylvania and Wisconsin; states with highly competitive Senate races. 

Finally, sophisticated donors are aware that they should prioritize giving personal money to candidates and party JFCs before turning to super PACs. With that in mind, any super PAC that is conducting low-dollar fundraising prospecting on the Internet or through direct mail should immediately raise suspicion of being a “scam PAC” set up to enrich consultants and not campaigns.  Die-hard Trump supporters would be wise to avoid these operations, and instead cut a check to the Trump campaign or a JFC. 

We live in an increasingly complicated world of campaign finance rules. Donors who possess the means to financially support the candidate or party of their choosing owe it to themselves to be educated and strategic about who receives their money. That’s the only way to ensure that donor funds are spent efficiently and effectively. 

Charlie Spies, leader of Clark Hill PLC’s national Political Law practice, has served as election law counsel for the Republican National Committee and also CFO and counsel for Mitt Romney’s 2008 presidential campaign, as well as counsel to Restore our Future and Right to Rise USA, the two largest super PACS in history.