BEST PRACTICES REMINDER: The Office of the Commissioner of Political Practices strongly recommends that
candidates run every campaign expenditure out of their campaign bank account.
•
Best practices would be for candidates to obtain a debit card attached to the campaign bank account to
use for all campaign expenditures. Exclusive use of a debit card connected to the campaign bank account
when making campaign expenditures ensures that campaign funds are utilized and simplifies reporting
requirements for the candidate.
•
Exclusive use of a campaign debit card also reduces the chances that a candidate would need to provide
personal banking records or other personal financial information to the COPP in the event a campaign
finance complaint is filed. Limited use of a candidate’s personal bank account or funds for campaign
purposes is allowable if the activity is properly reported and disclosed by the candidate.
Candidate and Treasurer Guide to CERS Page 1
Introduction to the Campaign Electronic Reporting System
What is the Campaign Electronic Reporting System (CERS)?
Online reporting in CERS is required for all candidates and committees (13-37-225, MCA). CERS is a user-
friendly system that helps candidates and committees disclose and report the money they receive and spend
to support or oppose candidates and ballot issues.
Montana's campaign finance laws ensure that the public can engage with a transparent reporting of money in
elections. Each campaign finance report filed in CERS is publicly available and searchable (data is not public
until the report is filed). Candidates and committees ensure transparency in Montana’s democratic processes
by filing legally-required campaign finance reports. Campaign finance reports are reviewed by the Office of
Political Practices (13-37-121[1], MCA
).
COPP Compliance Specialists are available full-time during work hours (8:00 a.m. to 5:00 p.m., Monday-Friday)
to provide campaign finance reporting support to candidates and committees.
Who must use CERS to Register as a Candidate and Disclose Campaign Finance Reporting?
In accordance with 13-37-225 and 226, MCA, all candidates (statewide, state district, county, municipal, and
school candidates) must:
1.
File all forms electronically in the Campaign Electronic Reporting System (CERS).
2.
All candidates will follow the same reporting schedule (See the Reporting Calendars webpage for
report periods and report due dates).
To register, all candidates must first create a CERS account. Then, the candidate must file a Statement of
Candidate. This same account will be used to enter campaign finance reports.
Creating a CERS account and filing a Statement of Candidate is detailed below in Part 1.
Part 1: File a Statement of Candidate in CERS
Step 1: Access CERS
Access CERS through the COPP's homepage
Users should note that the Campaign Electronic Reporting System (CERS) is a standalone system that is
directly administered by the Office of Political Practices. To access CERS, you must log in via Okta. Okta is
a State of Montana application that is not unique to the COPP but is used as a portal to access a variety
of statewide resources. While users must use Okta to log into CERS, the two systems are different.
Whereas CERS is administered directly by the COPP, Okta is not.
Each candidate must log into their Okta account to access CERS. To access CERS:
1.
Visit the COPP’s website, https://politicalpractices.mt.gov/. From COPP’s homepage, click
the red ‘Access CERS’ icon on the right side of the screen.
2.
From the CERS dashboard, click the green ‘Access my Account’ icon. Doing so will prompt you
to login to CERS via Okta.
3.
Login to CERS via Okta:
•
If you already have an active Okta account, you may log in using that username and
password.
•
If you do not already have an active Okta account or cannot remember your login
information, Click the Login button. From there, Okta gives you the option to create a
new account (See the Okta home page).
•
If you have trouble accessing your Okta account, or do not remember your account’s
username or password, you can reset the username or password through Okta itself.
The COPP cannot assist you with resetting an Okta account username or password or
retrieving an existing username or password you have forgotten.
4.
After you successfully login via Okta, you will automatically be redirected back to the CERS
dashboard. If you are experiencing difficulty logging in through Okta or are not re-directed to
the CERS dashboard, please contact the COPP for assistance.
5.
To register a new candidate or campaign for a new election, make sure you have selected the
Candidates tab, and then click Add New Registration (See image below).
Candidate and Treasurer Guide to CERS
Page 4
Step 2: Determine if Your Candidate Name Already Exists in CERS. If Needed, Register Name
Before you can add a new registration, CERS requires you to search for the candidate’s name. This search avoids
duplicate entries for the same candidate for a single election year. If the candidate has previously filed a
Statement of Candidate in CERS, correctly searching and finding their name will auto-populate previously
entered information (e.g. candidate and treasurer contact and mailing information).
Regardless of whether you have ever filed a Statement of Candidate in CERS, you must search for the candidate
name. To search:
1.
Fill out the candidate’s last name and first name.
2.
Then, click the Search Candidate button.
3.
If the candidate previously registered in CERS for a prior election year, select that candidate by clicking
the box to the left of the prior registration for that candidate, and select the Add New Registration icon.
4.
If the candidate previously registered in CERS for the current election year, select that candidate
registration. If the candidate has already registered for the current election year but you are unable to
access the profile in CERS, please contact the COPP for assistance instead of creating a second profile.
5.
If the candidate’s name does not come up from a search, click Add New Registration to add a new
registration for that candidate for the current election year.
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Step 3: Enter in Candidate Campaign Information
1.
Click the upper dropdown option from the Statement of Candidate form and select your Campaign Type
(City, County, School, State District, or Statewide).
a.
Are you uncertain which specific office you will run for? Read about your options for filing as an
exploratory candidate here. Pursuant to 13-37-219, MCA,
a candidate who has not determined the
office to which the individual will seek nomination or election is subject to the lowest contribution
limitation of the offices the candidate is considering seeking.
2.
Fill out all information in the Candidate Information section. Any field with an *asterisk* is a required field
that must have data entered.
a.
In the field “Official campaign email address,” the email address entered will receive notifications
about filed campaign finance reports. This email address will also receive communications from the
Office of Political Practices (e.g. with report reminders, training opportunities, etc.).
b.
City, county, and school candidates must select whether their campaign will have a combined total
of contributions and expenditures of $500 or more in the Affidavit of Reporting Status section. Select
option B box for campaigns that will spend and receive under $500 combined, or option C for
campaigns that will spend and receive over $500 combined (Statewide and State District candidates
will not see this field).
c.
For information and guidance about campaign bank requirements, click here.
3.
Fill out information in the Campaign Treasurer Information section.
a.
A treasurer must be appointed and certified on the Statement of Candidate form. Candidates can
appoint themselves to be their own treasurers. If there are changes, an amended candidate
statement (C-1 or C-1A form) must be submitted within 5 days.
b.
Treasurers are responsible for depositing and disbursing funds and keeping accurate accounts. The
treasurer and deputy treasurer are the only people authorized to make deposits or draw checks on
the campaign account.
c.
Often candidates appoint themselves as either treasurer or deputy treasurer so they have access to
their campaign accounts.
4.
If relevant to your campaign, fill out the Deputy Treasurer Information section. Not all campaigns will have a
Deputy Treasurer. You will need to select the purple Add button, enter in the deputy treasurer’s information,
and click Submit.
5.
When all candidate information is entered, select Save at the bottom of the page.
6.
Verify all candidate information is correct. If you need to make edits, click the Edit Information button,
update info, and then click Save.
7.
Certify all information is true by clicking the Certification box at the bottom of the page.
8.
Select Submit and File.
9.
You will now receive an email verifying your successful filing to the email address you provided.
Candidate and Treasurer Guide to CERS
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10.
You have the option to file a Form C-3 (Code of Fair Campaign Practices) in CERS. Any candidate who desires
to subscribe to the Code of Fair Campaign Practices may file a Form C-3. Signing the form is voluntary, and a
failure or refusal to sign is not a violation of election law.
11.
You will now be able to navigate back to your CERS homepage. From this page, you can:
a.
Add a new registration or campaign finance report,
b.
View your registration,
c.
Amend your candidate statement or a campaign finance report,
d.
File and view C-3, and
e.
Create finance reports (Finance Reports).
Step 4: How to Update a Statement of Candidate
If any of the information in a candidate’s statement of candidate changes, the candidate must file an amended
Statement of Candidate that provides the new information within five days after the change occurs (13-37-204,
MCA, ARM 44.11.303(2)).
Your candidate registration must be updated in CERS if any of the below information changes:
•
The campaign type,
•
Candidate, treasurer, or deputy treasurer contact information (address, email, phone number, etc.),
•
Political party, and
•
Bank information.
To amend a candidate’s registration:
1.
Navigate to the CERS homepage, and login via Okta.
2.
Check the box next to the candidate’s name to select their current registration and click Amend Registration.
3.
Edit and amend the relevant information in the candidate’s Statement of Candidate. Click Save.
4.
Finally, check and certify that the registration information is true, complete, and correct, and then select
Submit and File to save the updates.
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CERS TIPS:
1.
A new campaign finance report cannot be created if a prior report has a status of
‘Pending.’
2.
Finance reports can be amended at any time after they have been successfully
filed (See Part 9 for details on amending reports).
3.
Campaign finance data can be entered at any time. Data is not public until a report
has been filed.
Part 2: Create a Campaign Finance Report
Select the Campaign Finance Report Type (C-5 C-7, or C-7E) and Set the Reporting Period
Once logged into CERS, candidates can easily file campaign financial reports. Click the Access My Accounts
button on the Welcome page (see below).
Select the candidate campaign account by checking the box next to the relevant election year and select the
Finance Reports button.
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From the following page, select the relevant campaign finance report to add (Add New C5, Add New C7, or Add
New C7E).
•
Form C-5 details all contributions received and expenditures made by a campaign during a specific
time frame and must be filed periodically by all statewide and state district candidates, as well as
county, city, and school candidates whose campaign contributions and expenditures meet or exceed
$500 (13-37-226, MCA
).
•
Form C-7, the Notice of Pre-Elections Contributions, must be filed by any candidate who receives $250
or more from a single source between the 15th day of the month preceding an election and the day
before the election (for both primary and general elections) and must be filed within two business
days after receipt of a contribution of $250 or more (13-37-226, MCA
).
•
Form C-7E, the Notice of Pre-Election Expenditures, must be filed by any candidate who makes a
campaign expenditure or incurs a debt of $250 or more between the 15th day of the month preceding
an election and the day before the election must file a C7-E disclosing that activity. Form C-7E must be
filed within two business days of the expenditure being made or the debt being incurred (13-37-226,
MCA).
After creating a new finance report, select the date range the report will cover by using the dropdown calendar
option (see image below).
This time period must mirror the reporting periods as defined on the COPP’s reporting page. The time period
covered by the report includes up to the fifth day before the due date of the appropriate report. All accounts
must be current up to the fifth day before the report due date.
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Navigate Tab Options in CERS (E.g. Contributions, Expenditures, Debts, Payments, etc.)
Campaign finance information is entered into CERS by candidates or treasurers via the following tabs (the
functions and purpose of each tab are detailed in Part 3 through Part 9):
1.
Contributions
By law (13-1-101(9), MCA
), a contribution is defined as a “…distribution of money or anything of
value to support or oppose a candidate or ballot issue.” If an individual, political committee, or other
entity provides a campaign with money or goods or services of value for free or at a reduced rate in
an effort to support your candidacy, that would be considered a contribution. In the Contributions
tab, report contributions received from 1) individuals, 2) committees, 3) fundraisers, 4) refunds, etc.,
4) loans, and 5) candidate contributions (contributions made personally by the candidate).
2.
Expenditures (Expenses)
By law (13-1-101 (19)(a), MCA
), an expenditure is defined as “a purchase, payment, distribution,
loan, advance, promise, pledge, or gift of money or anything of value made by a candidate or
political committee to support or oppose a candidate or ballot issue.” Expenditure details must be
disclosed in the Expenditures tab. An expenditure is any money a campaign spends in support of that
candidate. There are a few exceptions that do not need to be reported (
13-1-101(19)(b), MCA).
3.
Debts
A candidate must report the full name and mailing address of each person or entity to whom the
campaign owes a debt or financial obligation. Debt details must include: the amount, the date the
debt or obligation was contracted, and the purpose of the debt or contracted obligation. If the exact
amount is unknown at the time of filing, the estimated debt amount must be reported (ARM
44.11.506).
4.
Payments
A candidate must report information about all payments made on the campaign’s outstanding debts
or loans in the Payments tab. In this tab, previously reported debts or loans can be selected to
record payments.
Candidate and Treasurer Guide to CERS
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5.
Attachments
The ‘Attachments’ tab provides candidates the opportunity to add an invoice, receipt, or similar
documentation to their C-5 report as a means of fully explaining the purpose of a given expenditure.
Attachments must be PDF documents, and the file size must be under 5MB.
6.
Summary
The Summary tab keeps a running total of money received and spent by the campaign during the
current reporting period. The summary details the campaign’s bank balance at the start of the
reporting period, all reported contributions received by the campaign, total campaign expenses, and
the ending bank balance for both the primary and general election accounts.
7.
File
The File tab is where the final steps of filing a campaign finance report are completed. To file a
report, check the box to certify that all information is correct, and then click the “Certify and File”
button.
8.
Help
Help tabs are available at both the main tab and subtab levels. Reference these for tab overviews,
tips, and links to resources and Montana campaign finance law.
Candidate and Treasurer Guide to CERS
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Part 3: Add Contributions in CERS
Types of Contributions
Contributions can come from: individuals other than the candidate, political committees (ballot issue committees,
incidental committees, independent committees (PACs), and political party committees), joint fundraising
committees, and self-contributions from the candidate.
Contributions limits
exist for both a primary and general election and apply to all contributions received from
committees or individuals (candidate contributions to their own campaign are exempt from contribution limits).
If a candidate does not have a primary election, they can receive contributions only for the general election.
Reference this link
for information on bank requirements if a candidate may have both a primary and a general
election.
All contributions are entered into CERS under the Contributions parent (main) tab. A contribution will be entered in
the below subtabs based on the contribution type.
1. Individual Contributions
Contributions received from individuals other than the candidate must be entered in the “Individuals” tab.
Individual contribution details must include whether the contribution is designated for the primary or
general election, the date the contribution was received, information about the individual (name, address,
employer and occupation are all required for individuals who contribute $50 or more), and whether it was
a monetary or in-kind contribution. All in-kind contributions must include a description of the specific
items or services received by the campaign.
** Individual contribution limits
apply to all contributions received from individual donors and aggregate
contributions are automatically tracked by CERS. Candidates cannot accept anonymous contributions.
Details at 13-37-217, MCA.**
2. Committee Contributions
Contributions received from a political committee must be entered in the “Committee” tab. Committee
contribution details must include: whether the contribution is designated for the primary or general
election, the date the contribution was received, information about the committee (committee type,
committee name, and the committee address), and whether the contribution was a monetary or in-kind
contribution. All in-kind contributions must include a description of the specific items or services received
by the campaign.
** Committee contribution limits
apply and aggregate contributions are tracked and displayed in CERS.**
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3. Fundraiser Contributions
Contributions of $50 or less received at mass collection events (pass-the-hat event, selling campaign t-
shirts, raffle tickets, an auction, etc.) may be recorded and reported in the “Fundraiser” tab as one lump
sum entry. Each individual fundraising event held by the campaign should be reported separately as its
own event. For example, if you held a fundraising dinner that also had a silent auction and a pass-the-hat
activity, that represents three required reporting activities (dinner, silent auction, pass-the-hat).
Reported fundraiser information must include: whether the contributions received at the event go to the
candidate’s primary or general account, the date and location of the event, the type of event, the
approximate number of attendees, the number of tickets sold (if relevant), and the total amount raised
(ARM 44.11.406
). Any individual contributions of $50 or more received at a fundraiser event must be
reported in the Individual Contributors section of the report.
** Anonymous contributions are illegal. The source of contributions from a fundraiser must always be
recorded, even if an individual’s fundraising-related contribution does not meet the $50 reporting
threshold. This also ensures that if an individual contributes $50 in the aggregate or more, their
contributions can be correctly reported (Any individual contribution of $50 or more must be reported
under the “Contributions” tab’s “Individual” option). **
4. Refunds, Etc.
The “Refunds, etc.” tab is where refunds, rebates, or other indirect contributions received by the
campaign are reported. An example would be interest earned from the campaign’s bank account, rebates
given to a campaign for bills already paid to vendors, or refunds given to a campaign for services the
campaign reported paying for but were not actually provided, so the money was returned to the
campaign by the vendor.
5. Loan Contributions
By definition, any loan to a campaign is a contribution (ARM 44.11.405). All contribution limits apply to
campaign loans. Any loan (regardless of its amount) made to the campaign during the current reporting
period is reported in the “Loans” tab, even if the loan is repaid during the same reporting period. A
candidate would report their own personal loans made to their campaign in this “Loans” subtab. Any
repayment for a loan is reported in the Payments tab.
6. Self Contributions
Contributions made from a candidate to their own campaign are entered in the “Self Contribution” tab.
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Page 13
Add a New Contribution
To add in contribution information, open the relevant Contributions subtab (Individual, Committee, Fundraiser,
Refunds, Etc., Loan, or Self), and select the purple Add button. Contribution information can also be edited and deleted
in the subtabs.
Once the purple Add button has been selected, the below screen will appear. Within the screen, there are two tab
options: Row Details and Entity Search.
The Entity Search tab is a great way to streamline entering in contribution data. This tab gives users the option to auto-
populate previously entered contributor information. If an individual or entity has already been entered into CERS, this
search option allows the information to be pulled up and does not require a manual entry.
To search for an individual or entity to identify them as the source of a contribution:
1.
Select the Entity Type (Bank, Business, or Individual).
2.
Enter in the entity or individual’s name.
3.
Make sure to select the Search All Campaigns box to search data beyond the data your campaign has entered
in CERS.
4.
Select the Search button to see if the entity or individual already exists in the system.
i.
If the correct information is in the “Entity Search Results” section, check the box next to the relevant
entity, and hit Select. You will then be redirected automatically to the Row Details screen.
ii.
If no “Entity Search Results” appear, click Create New Entity to manually enter the information. Once
the information is entered, click Submit. The next screen redirects to the Row Details screen.
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The Row Details tab is where users enter specific and identifying information about campaign contributions.
1.
Select the “Election Type” dropdown to designate the election the contribution will support (Primary or
General),
2.
The date the contribution was received (the date the contribution was received by the campaign must
be used, NOT the date the contributions was deposited into the campaign account),
3.
If the contributor was not found in the Entity Search tab, enter in the information to identify the
contributor source (e.g. name, address, occupation and employer for individual contributions, the
committee type, name, and address for committee contributions).
4.
An in-kind contribution means the furnishing of services, property, or rights without charge or at a
charge which is less than fair market value (ARM 44.11.403
). Frequently, in-kind contributions come in
the form of services for which charges usually are made but which are rendered to the campaign free of
charge or at a discounted amount. If something is sold to the campaign at less than fair market value,
the difference must be recorded as an in-kind contribution. A detailed description is required for all in-
kind contributions.
5.
The In-Kind Description section must describe the in-kind contribution the candidate has reported
receiving and must be detailed enough to distinguish between items or services that may be similar in
nature.
6.
When entering data into the Refunds, Etc. tab, select the dropdown Transaction Type (Refund, Rebate,
Interest, Other), and add in information about the original transaction (date, description).
Once all contribution details have been entered into the Row Details section, select the Submit button, and then select
the blue Save button.
The Save button must be selected after every entry or CERS may override that entry or duplicate the entity for each
subsequent entry you make.
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Often-Missed Contributions
1.
Reporting Payment for a Candidate’s Personal Expenditure Made on Behalf of Their Campaign:
For a candidate to reimburse themselves for personal expenditures made on behalf of the campaign, the
candidate must first report the activity as a loan provided to the campaign. This provides candidates two (2)
options:
Option 1 is for the candidate to provide a direct monetary loan from the candidate’s personal bank
account to the campaign, depositing those funds in the campaign bank account. This monetary
transfer would be reported as a loan from the candidate in Contributions tab and the Loan subtab on
the relevant campaign financial report. A candidate may use campaign funds to reimburse themselves
for any monetary loan they have made to their own campaign. Reimbursement payments made from
the campaign account would be recorded using the Payments tab.
Option 2 is for a candidate to report each campaign expenditure made using their personal bank
account or personal funds as an in-kind loan from the candidate in the Contribution tab’s Loan subtab.
Each In-Kind loan must provide the date the activity was carried out, the monetary value of the
activity, the name of the vendor or business entity the candidate originally paid, and an in-kind
description of the nature of the specific item(s) or service(s) provided. This description would require
the same level of detail or information as is required for campaign expenditures. Any reimbursement
payments made from the campaign account back to the candidate would be recorded using the
Payments tab.
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Part 4: Add Expenditures in CERS
All campaign expenditures must be entered in the Expenditures subtab.
To add in an expenditure, select the Expenditures subtab, and click the purple Add button. Expenditure information
can also be edited and deleted in this subtab.
Once the purple Add button has been selected, the below screen will appear. Within the screen, there are two tab
options: Row Details and Entity Search.
The Entity Search tab is a great way to streamline entering in expenditure data. This tab gives users the option to auto-
populate previously entered expenditure information. If an individual or entity has already been entered into CERS,
this search option allows the information to be pulled up and does not require a manual entry.
To search for an individual or entity to identify them as the source of an expenditure,
1.
Select the Entity Type (Bank, Business, or Individual).
2.
Enter in the entity or individual’s name.
3.
Make sure to select the Search All Campaigns box to search data beyond the data your campaign has
entered in CERS.
4.
Select the Search button to see if the entity or individual already exists in the system.
iii.
If the correct information is in the “Entity Search Results” section, check the box next to the relevant
entity, and hit Select. You will then be redirected automatically to the Row Details screen.
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PLEASE NOTE that the CERS software limits each field description to a 150-character limit. If more detail is
needed, you may add an attachment to the report as a PDF file. To add an attachment:
1.
First, check the box that states “check this box if you have attachments for this transaction”. Second,
2.
Navigate to the Attachments tab and add your attachment. Attachments must be in PDF format and
must be under 5MB in size.
Example attachments would include: a copy of an invoice received from ‘Very Good Building Co.’ for
campaign yard signs; a copy of a receipt received from ‘Mailers of Montana’ for campaign mailers; etc.
iv.
If no “Entity Search Results” appear, click Create New Entity to manually enter the information. Once
the information is entered, click Submit. The next screen redirects to the Row Details screen.
The Row Details tab is where users enter specific and identifying information about campaign expenditures.
1.
If the expenditure was not found in the Entity Search, enter in the information to identify the expenditure
entity (e.g. name and address of the vendor),
2.
Select the “Election Type” dropdown to designate the election the expenditure was made for (Primary or
General),
3.
The date of the expenditure,
4.
The amount of the expenditure,
5.
Check the box if the expenditure is a refund for a contribution that was over the contribution limit,
6.
Under “Description of Expense,” candidates are required to describe the expenditure (campaign mailers,
television advertisements, etc.). Please keep in mind that any expenditures made to a “consultant, advertising
agency, polling firm, or other person that performs services for or on behalf of a candidate, political
committee, or joint fundraising committee must be itemized and described in sufficient detail to disclose the
specific services performed by the entity to which payment or reimbursement was made”, (
13-37
-229(2)(b),
MCA),
7.
Once all expenditure information has been entered into the Row Details section, select the Submit button, and
then select the blue Save button. The Save button must be selected after every entry or CERS may override
that entry or duplicate the entity for each subsequent entry you make.
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Often-Missed Expenditures
1.
Candidate Filing Fee: The candidate’s filing fee is a mandatory reportable expenditure. The filing fee can be
paid either out of the candidate’s campaign account (if funds are available), or out-of-pocket by the candidate
using personal funds. If personal funds are used, the filing fee needs to be reported as either an in-kind
candidate contribution (if the candidate does not want to be reimbursed for that expense) or as an in-kind
candidate loan (if the candidate wants to be reimbursed).
2.
Social Media: Any campaign that spends money on social media ads must disclose this expenditure with the
same level of detail as any other expenditure. Best practice is to include the date(s) an individual ad ran, the
social media platform the ad appeared on, and a brief description of the ad.
3.
Payments to Consulting Firms, Advertising/PR Agencies: As noted above, any expenditure paid to a “consultant,
advertising agency, polling firm, or other person that performs services for or on behalf of a candidate, political
committee, or joint fundraising committee must be itemized and described in sufficient detail to disclose the
specific services performed by the entity to which payment or reimbursement was made”, (13-37-229(2)(b),
MCA),
4.
Vendor Fees (e.g. ActBlue, Revv, etc.)
Any vendor fees, processing fees, or other costs associated with a contribution-processing vendor (e.g. PayPal,
ActBlue, Win Red, etc.) must be reported as an expenditure.
Example: a candidate uses PayPal as an intermediary for individuals to make contributions to the campaign.
The campaign receives a $100.00 contribution from an individual via PayPal, and PayPal assesses a
processing fee of $2.00 on this transaction. The candidate would need to report receiving $100.00 (the
full amount of the contribution) from the individual, as well as an expenditure of $2.00 to PayPal for
the processing fee.
If a vendor fee, processing fee, or other cost is applied to contributions received, the following detail must
be included to fully describe the expenditure:
1.
Entity Name: The vendor name (e.g. PayPal, ActBlue, etc.),
2.
Election The election relevant to the contribution fees (primary or general), and
3.
Description of Expense: The dates and total value of the contributions represented by the fees. For
example: “$35 in ActBlue fees for $185 in contributions received from 10/1-10/15/20.”
Candidate and Treasurer Guide to CERS
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5.
Gas and Mileage: Gas and mileage must be reported as an expenditure if paid for from the campaign account
(e.g. with a campaign’s debit card).
•
If the candidate’s campaign uses a rental car for campaign-related expenses, the cost of the rental car
and the cost of fuel must each be reported as expenditures.
•
The COPP recommends that candidates who use their personal vehicle for campaign-related travel
report the use of the vehicle and fuel costs based on the federal reimbursement rate,
which accounts
for both the cost of the gas and the cost of the vehicle’s use.
•
If a candidate uses their personal vehicle, they would report the mileage as either an in-kind loan (if
they seek reimbursement from the campaign) or as an in-kind contribution.
Candidate and Treasurer Guide to CERS
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Part 5: Add Debts in CERS
All debts or other monetary obligations (e.g. debts or loans) owed by a campaign must be reported in the subtab of
the Debts tab.
To add in a debt or loan, select the Debt/Loan Payments subtab, and click the purple Add button. Debt and loan
information can also be edited and deleted in this subtab.
Just like with adding in contributions and expenditures, campaigns are also advised to use the Entity Search tab to
streamline entering in debt and loan data.
The Entity Search tab gives the option to auto-populate previously entered expenditure information. If an individual or
entity has already been entered in CERS, this search option allows the information to be pulled up and does not
require a manual entry.
To search for an individual or entity to identify them as the source of a debt or loan,
1.
Select the Entity Type (Bank, Business, or Individual).
2.
Enter in the entity or individual’s name.
3.
Make sure to select the Search All Campaigns box to search data beyond the data your campaign has entered
in CERS.
4.
Select the Search button to see if the entity or individual already exists in the system.
i.
If the correct information is in the “Entity Search Results” section, check the box next to the relevant
entity, and hit Select. You will then be redirected automatically to the Row Details screen.
Candidate and Treasurer Guide to CERS
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ii.
If no “Entity Search Results” appear, click Create New Entity to manually enter the information. Once
the information is entered, click Submit. The next screen redirects to the Row Details screen.
The Row Details tab is where users enter specific and identifying information about campaign debts and loans. To
enter a debt or loan, disclose:
•
The full name, entity type, and complete mailing address of the individual or business to whom the
debt is owed,
•
The election that the debt or loan serves,
•
The date the date was incurred/agreed to,
•
The debt or loan amount. If the exact amount of a debt or obligation is not known, the estimated
amount must be reported (ARM 44.11.506
).
•
A detailed description of the debt or loan in the Purpose of Debt section (a debt or loan description
must have the same level of detail as an expenditure description),
Once a new debt has been entered into the Row Details section, select the Submit button, and then select the blue
Save button. The Save button must be selected after every entry or CERS may override that entry or duplicate the
entity for each subsequent entry you make.
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Part 6: Add Payments (on Debts and Loans) in CERS
All outstanding loans reported in the Contributions tab and debts or obligations reported in the Debts tab appear in
the Payments tab.
To enter payments on a loan or debt,
1.
Select the check box next to the relevant loan or debt in the Payments tab.
2.
Then, select the purple + Add button to record a new payment.
3.
Enter in the date of the loan or debt payment, the amount paid, click Submit, and then Save. The Save button
must be selected after every entry or CERS may override that entry or duplicate the entity for each subsequent
entry you make.
To view recorded payments that have been made on a loan or debt,
1.
Select the check box next to the relevant loan or debt in the Payments tab,
2.
Then, reference the data in the Payments History section.
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Part 7: Understand the Summary Tab
The Summary tab keeps a running total of money received and spent by the campaign during the current reporting
period.
The Summary tab details the campaign’s bank balance at the start of the reporting period, all monetary contributions
received by the campaign, the total amount of all campaign expenditures, and the ending bank balance for both the
account (this is done for both the primary and general accounts).
•
Cash in Bank is the ending balance of the previous report (this will be $0 for the initial report). Please note
that the beginning balance (cash in bank) includes all funds the candidate reported as having received on
previous finance reports; this includes both contributions and loans.
•
Receipts represent all contributions received during the current reporting period. These are added to the
Cash in Bank balance and reflected in the Subtotal amount.
•
Expenditures represent all campaign expenditures made by the candidate during the current reporting
period and are subtracted from the Subtotal.
•
The difference between the Subtotal and current reporting period Expenditures is shown as Cash in Bank
– Ending Balance. This balance should correspond with the candidate’s accounts as of the closing date of
the reporting period; that is, the fifth day before the report is due.
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Part 8: File a Campaign Finance Report
Select the File tab to file a campaign finance report.
There are a few options on the File tab:
1.
Display the names and address of contributors who have contributed less than $50? Select this first box if
you want your publicly available campaign finance reports to show information about contributors who
made contributions less than $50. If the option is not selected, CERS automatically aggregates those
contributions and includes them as one mass contribution on the public view version of the report.
2.
Closing Report: Select the second box ONLY if this is the candidate’s closing report. A closing report should
ONLY be filed when a candidate’s debts and obligations are settled and no further activity will occur (13-37-
228(3), MCA). See this link for details about how to close a campaign account and disperse surplus funds.
3.
Certification: Select the third box to certify that the information in the report is true, complete, and correct
to the best of your knowledge. Then, click Certify and File.
If a filed campaign finance report needs to be amended later, this is possible by going back to the committee
dashboard, selecting the specific report, and selecting the “Update or Amend Report” button.
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Part 9: Report Review Process & How to Amend a Campaign Finance Report
The COPP reviews all campaign finance reports and sends the candidate an Inspection Report.
An Inspection Report is a COPP inspection that occurs each time a candidate files a campaign finance report leading
up to an election. The Inspection Report notes all changes a candidate must make to each campaign finance report in
order to comply with Montana law. A CFR Inspection Report will only detail one specific financial report, which will
be stated in the “Reference Report” field.
An Exam occurs after an election and serves as a final and cumulative inspection of all financial reports filed by a
candidate or committee (13-37-123, MCA
). All campaign finance reports are included in the Exam, and the COPP
alerts the candidate or committee to all outstanding items or issues that must be addressed by the candidate or
committee.
The COPP is available to assist candidates and committees in correcting or addressing all items noted in the CFR
Compliance report. However, it is the responsibility of the candidate or committee to ensure all reporting
requirements have been met.
With every Inspection Report and the Exam, the candidate must amend the specific campaign finance report where
issues are noted. A campaign finance report can be amended by navigating back to the candidate dashboard and
selecting the blue Finance Reports button. Then, select the relevant campaign finance report and select Update or
Amend Report. Update information as necessary. Save changes. Finally, re-file the campaign finance report.
Read more about the COPP’s inspection and exam process and view a sample Inspection Report here.
Candidate and Treasurer Guide to CERS
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Part 10: Post-Election Options for a Campaign Account
This section contains information managing surplus funds and outstanding debts for:
1.
Candidates who do not continue after the primary, and
2.
Candidates who continue to the primary.
The information in this part is also provided on COPP’s website.
Surplus Campaign Funds after the Primary Election
If you don't advance to the general after the primary election, and your primary campaign account has surplus funds,
you have two options for the funds. A candidate may:
1)
Return the contributions to contributors, or
2)
Donate the funds to a non-profit (this must be reported in a C-5 report as a campaign expenditure).
Note: A candidate may not contribute surplus campaign funds to another campaign, including the
candidate's own future campaign (for example, running for the same office during the next election), or use
the funds for personal benefit.
If you do advance to the general election, leftover funds may be moved from a candidate's primary account to the
general account.
•
To report this in a C-5, report the transfer in the C-5 that covers the date the money was transferred. You will
report the removal of money from the primary account as a primary expenditure under Expenditures. Then,
you will report the transfer of the primary funds to your general campaign account under Contributions
(Fundraiser subtab), as a general fundraiser contribution.
Surplus Campaign Funds after the General Election
If you dispose of all campaign funds by your post-general C-5 reporting deadline, all transactions can be detailed
on the post-general C-5 report. Your options to dispose of funds by the post-general C-5 due date are to:
1)
Return the funds to contributors. These returned contributions would be reported in your post-
general C-5 report as an expenditure. You must include the full name and mailing address of the
recipient.
2)
Donate the funds to a nonprofit. Report this transaction in a C-5 report as an expenditure.
If y
ou have funds remaining after the post-general C-5 report deadline, you must dispose of the surplus funds within
120 days after you've filed your closing C-5 campaign finance report. You have the following options for the surplus
funds:
1)
Donate the funds to a nonprofit. These donations must be reported on a C-118 campaign finance form.
2)
If elected, you can establish a constituent services account. This requires you to file a C-118C form and
put the money in a bank account with "constituent services" in the account title. Please note that there
are specific legal requirements for a constituent services account:
Candidate and Treasurer Guide to CERS
Page 27
a.
You will need to include a copy of the transaction where you've moved money from a campaign
account to a constituent services account.
b.
The C-118C form must be filed with 135 days after you've filed a closing campaign report.
c.
Any candidate who opens a constituent services account is required to file C-8 reports.
d.
Funds in a constituent services account are restricted to being used for certain activities and
require detailed accounting and period reports. See 13-37-402, MCA and ARM 44.11.701
through 44.11.711.
Post-Election Outstanding Debts
To pay down campaign debt, you can continue to receive contributions after an election.
•
For example, if you have primary campaign debt, whether you continue to the primary election or not, you
can continue to receive primary contributions to pay the campaign loans or debts down.
•
Please note that contribution limits apply, they apply per election, and each contribution must be
designated for either your campaign’s primary or general account and kept separate. You can continue to
receive contributions designated for a specific campaign as long as the individual or entity has not reached
their contribution limit for that specific election. This explains why general election contributions cannot
be applied retroactively to debt accrued and reflected by your primary campaign account.
•
Section 13-37-241, MCA, provides that, under certain circumstances, a candidate is not required to pay off
primary election debt with primary election funds. In addition, following the general election, the
candidate may repay a loan the candidate made to the campaign with primary or general election funds.
If you will no longer seek out contributions to pay for your campaign's debts or loans, you have a few options to
close your account and settle outstanding loans and debts:
1.
Option 1: You can forgive loans you made, as the candidate, to your campaign. First, the self-loan must
already have been reported as a loan in a previous C-5 report. Then, to forgive your personal loan to your
campaign, simply email the COPP at cppcompliance@mt.gov and state, "I am forgiving my candidate loan of
$XXXX money for my campaign."
2.
Option 2: If your campaign owes outstanding loans and/or debts made to entities that are not yourself (e.g.
to a printing company, a vendor, a business, etc.), you may use your personal funds (not your campaign
funds) to pay off those obligations.
i.
You will report this as an in-kind loan to your campaign (under Contributions, Loan [Use the blue
"Add Candidate Loan" button in the "Row Details" section], list the "In-Kind Description" as
"campaign debt/loan repayment," or something similar). This will then create a candidate loan for
the pending loans or debt balance. Your account will continue to reflect a negative balance with this
in-kind candidate loan.
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ii.
Then, 'forgive' this 'new' loan by emailing cppcompliance@mt.gov and stating in the email that you
will not personally seek reimbursement from the campaign for this in-kind loan, and that the loan
was made to pay off existing campaign obligations. You must include the 1) vendor, 2) date, and 3)
amount information for those obligations in the email. This explanation is needed because your
CERS account will continue to reflect a negative balance for the campaign even after this activity.
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Part 11: Filing a Closing Report
Every candidate must file a closing report. Closing reports must be filed when all debts and obligations are
satisfied, and no further campaign activity is anticipated following an election.
Some campaigns have continued to make expenditures after the election that are not campaign related. This is
not permissible. If all the debts and obligations of the campaign have been met, the closing report has been
submitted and there is still a balance in the campaign account the campaign has several options to choose
from to dispose of the surplus funds or property. Review Part 10 to understand your options on pending debt
and loans or surplus campaign funds.
A closing report is simply a final C-5 that is filed as a closing report. This can also be the candidate's required
post-general C-5 report if no campaign account transactions (e.g. paying back outstanding loans or debts)
remain.
To file a report as a closing report, check the "Is this a closing report" box on the File tab (see below image),
certify the information is true, complete, and correct, and file the report.
Part 12: Frequently Asked Questions and Additional Resources
1.
I forgot my Okta login information or I cannot access CERS through Okta. How do I regain
access to my CERS profile?
First, it’s important to know that Okta is a State of Montana application that is not unique to the
COPP but is used as a portal to access a variety of statewide resources. While users must use
Okta to log into their CERS profile, the two systems are different. Whereas CERS is administered
directly by the COPP, Okta is not.
If you have trouble accessing your Okta account, or do not remember your account’s username
or password, you can reset the username or password through Okta itself. The COPP cannot
assist you with resetting an account username or password in Okta or retrieving an existing
username or password you have forgotten.
To reset a username or password in Okta, click on the “Need help logging in?” prompt. Then
follow the instructions provided by Okta.
If you or someone connected to your campaign creates a new Okta profile, with a unique
username and password, this new Okta account will NOT provide instant access to your previous
CERS profile.
If you do not have the Access ID for a CERS profile, or you are trying to access CERS via a new or
reset Okta account, the COPP may be able to assist you. To do this, contact the COPP by
emailing cpphel[email protected] or cppcompliance@mt.gov,
ask for your Access ID, and briefly explain
the nature of your relationship with the campaign/committee whose CERS profile you wish to
access. Upon verification, the COPP will work with you to update your Access ID.
Once you receive an updated Access ID, log into CERS and enter that Access ID as described
a
bove. Once the Access ID for a certain CERS profile is reset by the COPP, any Okta accounts that
previously had access to that profile no longer will have access. Keep that in mind before a
request to reset the Access ID is made, as other individuals who had access to the CERS profile
before would no longer have access without using your newly created Okta account or entering
the new Access ID themselves.
Please note that the COPP reserves the right to deny an Access ID reset request depending on
the circumstances, timing, or nature of the request.
Candidate and Treasurer Guide to CERS
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2.
When does my campaign finance data in CERS become public?
Data entered into CERS is not public until a campaign finance report is filed. This means that a campaign can
enter in financial data the moment a transaction occurs. The COPP strongly advises campaigns to be proactive
in entering campaign finance data. There is always a five-day window between a period a report covers (e.g.
March 16-April 15) and when the report is due (e.g. April 20). It is not advised for campaigns to wait until the
last moment to enter a campaign finance report’s data.
3.
How do I include an attachment with my campaign finance report?
Candidates may add an attachment to any expenditure disclosed on a campaign finance report. For example, a
candidate could include a receipt or invoice received from a vendor as an attachment to fully disclose a
campaign expenditure. To add an attachment to your report:
First, check the box that states “check this box if you have attachments for this transaction”.
Then navigate to the Attachments tab and add your attachment (by clicking the ‘add’ icon). Attachments must
be in PDF format and must be under 5MB in size.
Click the ‘Add Attachment’ icon to select the PDF file. Provide a file name for the attachment, describe the
attachment under ‘Description’ (for example: Advertising Professionals of Montana social media invoices),
enter the Reference Date for the expenditure the attachment is meant to accompany, and choose the
Reference Type (expenditure).
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As with any other expenditure, be sure to ‘Submit’ and ‘Save’ your attachment!
4.
How do I report expenditures made to consultants, firms, agencies, etc.?
Individual consultants or other individual professional service providers and Consulting firms, advertising
agencies, P.R. groups, polling services, etc.
Candidates should keep in mind that any expenditures made “made to a consultant, advertising
agency, polling firm, or other person that performs services for or on behalf of a candidate, political
committee, or joint fundraising committee must be itemized and described in sufficient detail to
disclose the specific services performed by the entity to which payment or reimbursement was
made”, (13-37-229(2)(b), MCA
).
In other words, any expenditures made to a group providing professional services must be
described with sufficient detail to fully identify the specific service or services provided. If a group is
being compensated to provide more than one specific task or service, each individual task or service
they perform must be identified. As stated in Commissioner Mangan’s Dismissal in the matter of
Strandberg v. Cooney, COPP-2020-CFP-001,
for expenditures made to an individual consultant or
other individual providing a professional service “a combination of position and/or consultant
responsibilities are considered acceptable by the COPP for disclosure purposes”.
Words or phrases commonly used by candidates and committees alone to describe expenditures
made to individual consultants that the COPP will not consider as adequately detailed include
consulting; consulting services; general consulting; campaign services; professional services;
research; etc. These terms would be considered inadequate because they do not disclose or
identify the specific service or services provided.
Alternatively, the COPP will consider the following terms or phrases acceptable because they easily
identify the “position and/or consultant responsibilities”: digital media consulting; fundraising
consulting; campaign strategy consulting; social media ad design; digital fundraising; opposition
research; issue research- tax policy; candidate likeability polling; GOTV planning.
Candidate and Treasurer Guide to CERS
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Example: the Leslie Knope for City Council campaign hires an advertising agency to handle
the design of the campaign’s social media ads, research effective voter outreach and
advertising opportunities, and manage when the campaign’s television ads are run on local
stations. Under the requirements of
13-37-229(2)(b), MCA, candidate Knope would be
required to itemize and describe each specific service provided.
Expenditures that resemble this hypothetical example are frequently reported by Montana
candidates and committees but are often described using only generic terms such as
advertisements, research, or campaign services. These terms would be considered
inadequate because they do not disclose the specific services provided or easily identify all
services provided. Instead, the campaign would be required to use descriptors that more
accurately identify the specific services provided, such as social media ad design, voter
outreach research, and media commercial production.
Candidate and Treasurer Guide to CERS
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Campaign
travel
Any payments made to travel agencies, travel planners, firms, or other professional travel
service providers are subject to 13-37-229(2)(b), MCA’s requirement that the “specific
services provided” be identified.
Legal Payments or Legal Fees
When describing the expenditure of campaign funds for legal payments or legal fees, the
COPP will accept the following descriptions: legal services- compliance; legal services-
active representation/defense; or legal services-retainer fee.
Miscellaneous Items
“Bookkeeping,” “campaign bookkeeping/accounting,” or “budget work” will be
considered acceptable to describe budget management, budget balancing, bill
processing and payment, and/or campaign accounting work.
“Campaign compliance services” or “campaign reporting” will be considered
acceptable to describe payments made to another entity related to the compilation of
filing of financial reports with the COPP on behalf of the campaign or committee.
“Campaign meal” or “staff meal” will be considered acceptable to describe payments
made to cover food expenses incurred by campaign staff when campaigning if date or
location information is provided.
Additional Resources
It is a COPP priority that campaign finance be an accessible subject for voters, candidates, committees,
lobbyists, and all Montanans. For more details on campaign finance requirements for candidates and
treasurers, each candidate and treasurer should familiarize themselves with this Accounting and
reporting Manual for Candidates and Treasurers.
This list has links to all the webpages this guide referenced:
•
Campaign Finance Laws
•
Guide to Registering as a Candidate
•
Filing as an Exploratory Candidate
•
How to Report a Self-Loan to Your Candidate Campaign Account
•
How to Report a Paid Communications, Attribution (Paid for By) Information
•
Candidate Campaign Finance Forms
•
Candidate Reporting Calendar
•
Contribution Limits
•
The COPP’s Inspection and Exam Process
•
How to Close out a Candidate Campaign Finance Account
Candidate and Treasurer Guide to CERS Page 35
Questions? Contact the Office of Political Practices.
Candidates and treasurers should contact the COPP office when assistance is needed. We are available
to support all candidates and treasurers.
- Phone: (406) 444-2942
-
Office: 1209 8th Avenue, Helena, MT
-
General Email: cpphelp@mt.gov
-
Compliance Email: cppcompliance@mt.gov
- Fax: 406-444-1643
@MontanaCOPP
@MontanaCOPP
