After looking through the National Republican Trust PAC FEC filings again, I noticed that the registration was hand-delivered to the FEC on 9/29/08 but the registration itself was dated 9/26/08.

Contributions for the period beginning 9/26/08 and ending 10/15/08 totaled $462,651. A number of those contributions are dated 10/01/08.

Wisconsin-based Maelstrom Technologies charged the PAC $21,017 through 10/15 to process credit cards.

In an amendment to the registration dated 10/29. the PAC added a bank in Wisconsin as a depositary.

Curious. More on accounting for the contributions later.

Rick Wilson, a National Republican Trust PAC consultant, told Greg Sargent on 10/30 that the network attorneys had vetted the ads and they were good to go. (Wilson's company, Intrepid Media, produced the ads.)

Wilson also told Sargent that by the next day (10/31), the National Republican Trust PAC will have spent $2 million on the national buy. This is in addition to running ads previously in Ohio, Pennsylvania and Ohio.

Where did the cash come from to pay for the ads? After reading the FEC guidelines, I can't see how a two-week old committee could have legitmately qualified for a multi-million dollar loan.

Per FEC:

Loans
A loan to a committee is a contribution to the
extent that it remains outstanding. 100.52(b)(2).
(Loans from banks are not contributions if they
meet certain conditions; see page 16.)

Repayments made on a loan reduce the amount
charged against the lender’s contribution limit.
However, a loan that exceeds the lender’s limit is
unlawful even if repaid in full.

Endorsements and Guarantees of Bank Loans
An endorsement or guarantee of a bank loan is
a contribution. The amount guaranteed counts
against the endorser’s or the guarantor’s limit only to the extent that the loan remains outstanding. Repayments on the loan proportionally reduce the amount charged against each endorser’s (or guarantor’s)contribution limit.

If a loan agreement does not stipulate the amount
for which each endorser or guarantor is liable, then the contribution amount of each endorser or guarantor is determined by dividing the total amount of the loan by the number of endorsers or guarantors. 100.52(b)(3) and 100.82(c).

Bank Loans
Unlike other loans, a loan or line of credit from a bank is not considered a contribution if the conditions set forth below are satisfied. If a loan fails to meet any of these conditions, it is considered a prohibited contribution from the lending institution.

Conditions
A committee may obtain a loan or line of credit
from a bank provided that the loan:
1. Bears the bank’s usual and customary interest
rate for the category of loan involved;
2. Is evidenced by a written instrument;
3. Is subject to a due date or amortization schedule; and
4. Is made on a basis which assures repayment.
100.82(a)(1)-(4).

Methods of Assuring Repayment
A loan is made on a basis which assures repayment
if it is obtained using one or more of the following authorized methods of securing the loan:

Collateral. A loan may be secured using assets of
the committee, such as real estate, personal property,negotiable instruments and stocks. The fair market value of the assets pledged must, on the date of the loan, equal or exceed the amount of the loan and any senior liens. The committee must ensure that the bank has established a “perfected security interest” in the collateral (that is, taken steps to protect its interest in the collateral in the event that the committee defaults on the loan).
100.82(e)(1).

Guarantees or Endorsements. A loan may also
be secured using guarantors or endorsers, who
agree to repay the loan should the committee default. As previously stated, an endorsement or guarantee of a bank loan is considered a contribution by the endorser or guarantor and is therefore subject to the law’s prohibitions and limits on contributions.100.82(e)(1)(ii).

Pledge of Future Receipts. A committee may
pledge its future receipts as security for the loan; the amount of the loan must not exceed a reasonable estimate of anticipated receipts, based on documentation provided by the committee (such as cash flow charts or fundraising plans).

Future receipts may include, for example, anticipated contributions or interest income. The loan agreement must require the committee to deposit the pledged funds into a separate account established for this purpose. If the account is established at a depository other than the lending institution, the committee must assign the account’s funds to the lender and notify the depository of the assignment.
100.82(e)(2).

Other Methods of Assuring Repayment
The Commission may, on a case-by-case basis,
approve other methods of assuring repayment.
100.82(e)(3). A committee may wish to request
an advisory opinion from the Commission before
entering into an alternative repayment agreement