The Unique Role of Non-Connected PACs in Modern Politics

Political Action Committees (PACs) remain a cornerstone of campaign finance in the United States, providing individuals and organizations a structured way to pool resources and support candidates or causes. Among the various types of PACs, the non-connected PAC stands out for its independence. Unlike connected PACs, which are tied to a corporation, labor union, or membership organization, non-connected PACs are formed by groups of individuals with a shared political interest. They are not beholden to a single sponsor, giving them significant flexibility in fundraising, spending, and forming alliances. However, this independence does not mean isolation. Non-connected PACs can magnify their influence by collaborating with other political entities—including other PACs, party committees, advocacy groups, and even candidates—as long as they navigate the complex web of campaign finance laws effectively.

The ability to collaborate strategically allows non-connected PACs to punch above their weight, accessing shared resources, broader audiences, and deeper expertise. In the current fragmented media and fundraising environment, no political actor can succeed alone. The most effective non-connected PACs actively seek partners to co-host events, pool advertising dollars, coordinate on policy messaging, and build coalitions for voter outreach. This article explores the practical strategies, legal guardrails, and real-world benefits of such collaborations.

Defining Non-Connected vs. Connected PACs

To fully appreciate the collaborative potential of non-connected PACs, it is important to understand what sets them apart. A connected PAC is established by a corporation, trade association, or labor union, and it can solicit contributions only from that entity’s restricted class (e.g., executives, shareholders, or members). The sponsoring organization covers administrative costs, and the PAC's activities must align with the sponsor’s interests. In contrast, a non-connected PAC is voluntarily formed by any group of individuals. It can solicit contributions from the general public, including anyone who supports its mission, but it must pay all administrative and fundraising expenses from its own treasury. This independence allows non-connected PACs to pivot quickly, embrace niche issues, and forge partnerships across ideological boundaries without seeking permission from a corporate parent or union board.

The Rise of Independent Expenditure Committees

Since the Supreme Court’s 2010 decision in Citizens United v. FEC, non-connected PACs have increasingly taken the form of independent expenditure-only committees (commonly known as Super PACs). These entities can raise unlimited sums from individuals, corporations, and unions and spend unlimited amounts to advocate for or against candidates, provided they do not coordinate directly with those candidates’ campaigns. This legal framework has opened the door for expansive collaborative efforts: several Super PACs focusing on the same issue can join forces, or a non-connected PAC that also runs a traditional PAC can partner with allies on both independent expenditure and direct contribution activities. Understanding this landscape is essential for any non-connected PAC seeking to collaborate without running afoul of the law.

Strategies for Collaboration: Expanding the Playbook

The original article listed four key strategies. Here we expand each into actionable, detailed approaches that non-connected PACs can implement today.

Joint Fundraising: Mechanics and Best Practices

Joint fundraising allows two or more political committees to pool resources when soliciting contributions from donors. The committees share the proceeds according to a predetermined formula, and donors write one large check (subject to applicable limits) that is then divided among the participants. For non-connected PACs, joint fundraising events can be held with other PACs, party committees (like state party committees or the Democratic/Republican national committees), or even candidate committees under certain conditions.

Key considerations include:

  • Custodial bank account: A joint fundraising committee typically opens a separate custodial account to collect contributions, which are then disbursed to the participating committees within legal limits.
  • Disclosure: Each committee must report its share of the proceeds separately to the Federal Election Commission (FEC). The joint fundraising committee itself also files reports.
  • Pro-rata allocation: The allocation of funds must respect each committee’s contribution limits; for example, a non-connected PAC can receive up to $5,000 per year from an individual, while a state party committee receives up to $10,000 per year from the same individual (under federal law).

By partnering with a well-funded state party or a national PAC, a smaller non-connected PAC can gain access to high-dollar donors it could not reach on its own. A typical joint fundraising event might involve hosting a reception where attendees give a single check that supports both the non-connected PAC and a partner committee, building goodwill and expanding the donor base for all participants. For detailed legal guidance, consult the FEC’s joint fundraising page.

Coordinated Advertising and Media Campaigns

Non-connected PACs can amplify their message by pooling funds for advertising buys. This is most common for issue advocacy—ads that promote a policy position or educate the public on a topic without expressly advocating for the election or defeat of a candidate. Since issue ads are not subject to the same coordination restrictions as campaign ads, multiple PACs can safely contribute to a shared media fund, hire the same ad agency, and run the same spots in the same media markets.

For express advocacy (ads that say “vote for” or “vote against”), non-connected PACs must avoid coordinating with candidates or their campaigns, but they can still coordinate with other non-connected PACs and party committees that are also making independent expenditures. Through independent expenditure sharing, committees can:

  • Share polling data or voter modeling (provided they do not coordinate with a candidate).
  • Split the cost of a large television or digital ad buy, stretching each committee’s budget further.
  • Develop a unified message calendar to saturate the airwaves during a critical period.

A real-world example: several environmental non-connected PACs often collaborate on ads promoting climate change legislation, combining their resources to run ads in key swing districts. The result is greater market penetration and a louder collective voice without violating any coordination rules. For more on the difference between issue and express advocacy, see the OpenSecrets guide to issue advocacy.

Policy Alliances and Coalition Building

Non-connected PACs can also collaborate on the substantive policy goals they support. This often takes the form of coalitions that bring together PACs, advocacy groups, think tanks, and sometimes even for-profit entities to lobby for specific legislation or ballot initiatives. Unlike electoral coordination, policy coalition work is governed by separate lobbying disclosure laws, but it can be done with far fewer restrictions than campaign activities.

Steps to build a successful policy alliance:

  1. Identify shared goals: Find other PACs or groups that champion the same legislation, regulatory change, or court rulings.
  2. Create a formal coalition structure: A memorandum of understanding can outline each member’s financial commitment, staffing, and messaging roles.
  3. Tackle education and advocacy: Jointly produce white papers, host briefings for congressional staff, and organize advocacy days.
  4. Leverage each member’s network: One PAC may have strong grassroots supporters, another may have high-profile endorsers, and a third may have deep relationships with key lawmakers.

For example, the Campaign Legal Center sometimes partners with reform-oriented non-connected PACs to advance campaign finance transparency legislation. These alliances maximize influence without requiring any single PAC to carry the entire lobbying burden.

Voter Mobilization and GOTV Efforts

Non-connected PACs often engage in voter registration, voter education, and get-out-the-vote (GOTV) drives. These activities, when conducted independently from candidates, are generally permitted and can be much more effective when done in concert with other political entities. Collaboration can take the form of:

  • Shared door-knocking operations: Two PACs covering the same battleground state can share field staff, canvassing routes, and digital tools.
  • Phone banking and text banking: Jointly sponsored phone banks enable volunteers to contact voters across multiple districts, ensuring message discipline.
  • Voter registration drives: Partnering with civic engagement nonprofits that have 501(c)(3) status (like the League of Women Voters) can help PACs reach unregistered voters, provided the PAC does not steer voter registration toward one party.

Importantly, when a non-connected PAC partners with a candidate’s official campaign for GOTV, very strict rules apply—such activities are considered coordination and must be counted as in-kind contributions subject to contribution limits. To avoid this, many PACs collaborate with state party committees, which have separate GOTV programs that permit leveraging party resources without triggering a direct contribution to any candidate.

Shared Data and Analytics

In the data-driven age of modern elections, having access to sophisticated voter files, modeling, and targeting tools is a key asset. Non-connected PACs can pool resources to license high-quality voter data from vendors like Catalist or TargetSmart, or they can share internal survey research as long as they do not share that data with a candidate’s campaign (which would constitute an in-kind contribution). Data-sharing agreements among non-connected PACs should be documented and kept exclusively within the group of PACs to avoid the appearance of coordination with candidates. This approach allows each small PAC to gain insights that only large, well-funded campaigns usually have, making their independent expenditures far more effective.

Collaboration cannot succeed without a thorough understanding of the legal environment. Non-connected PACs must comply with federal campaign finance laws (primarily the Federal Election Campaign Act) and applicable state laws. Ignorance of the rules can result in fines, legal sanctions, or even the dissolution of the committee.

Federal Campaign Finance Laws (FECA and BCRA)

The FEC oversees all federal PACs. Non-connected PACs are subject to contribution limits: they can accept up to $5,000 per year from an individual and give up to $5,000 per election to a candidate committee. They can also make unlimited independent expenditures, but those expenditures must be reported to the FEC. The Bipartisan Campaign Reform Act (BCRA) of 2002 placed additional restrictions on issue ads that mention a candidate in the final weeks before an election, requiring disclosure of donors. Any collaborative advertising should be reviewed by counsel to ensure it fits within the proper legal category.

Contribution Limits and Coordination Restrictions

The biggest legal minefield for collaborating PACs is the prohibition on coordinated communications with a candidate’s campaign. If two non-connected PACs jointly produce an ad that expressly advocates for a candidate, and they coordinate its content, timing, and targeting with that candidate’s campaign, the cost of the ad may be treated as a contribution to the candidate—potentially exceeding the $5,000 limit. However, the two PACs can work together on that ad without violating coordination rules, as long as no candidate or party committee is involved in the decision-making. Similarly, when a non-connected PAC and a state party committee collaborate, they must be careful not to let the party committee direct the PAC’s independent spending in ways that benefit a particular candidate.

The FEC provides a set of coordination regulations (11 CFR 109) that define when a communication is coordinated. Any PAC manager planning a collaborative project should review these regulations or hire an experienced campaign finance attorney.

Disclosure and Reporting Requirements

Every collaborative endeavor generates a paper trail. For joint fundraising, both the joint fundraising committee and each participating PAC must file reports. For independent expenditure sharing, each PAC must report its own share of the expenditure, including the name of the entity that paid the vendor and the names of donors who contributed more than $200 specifically to that expenditure (if the funds were designated). The FEC’s electronic filing system (FECFile) can help streamline reporting, but accuracy is paramount. For example, if PAC A pays the full cost of an ad and PAC B reimburses PAC A, both transactions must be reported as independent expenditures or contributions depending on the arrangement.

State-Level Variations

Non-connected PACs that operate in state or local elections must navigate a patchwork of state laws. Some states impose lower contribution limits, restrict who can give to PACs, or prohibit certain types of coordinated spending. For example, California requires monthly reporting and bans corporate contributions to candidate campaigns, which affects non-connected PACs that accept corporate funds (if they intend to support state candidates). A non-connected PAC collaborating with a state party or local ballot measure committee should consult the applicable state election board or secretaries of state. Resources like the National Conference of State Legislatures can provide an overview of state laws.

Practical Examples of Successful Collaboration

While the legal landscape is intricate, many non-connected PACs have thrived through collaboration. These examples illustrate the potential.

Issue-Based Coalitions

One well-known case is the collaborative work among several environmental non-connected PACs during the 2020 election cycle. Groups like the League of Conservation Voters (LCV) Victory Fund, the Sierra Club’s political committee, and the Environmental Defense Action Fund worked together on a shared independent expenditure campaign targeting Senate races in Arizona, Colorado, and Maine. They aligned their messaging on climate action, coordinated media buys in overlapping markets, and shared voter targeting models. Each PAC remained independent and filed its own reports, but they operated from a common strategy developed through weekly coalition calls. This collaboration allowed them to efficiently allocate resources, avoid duplicating efforts, and maximize the impact of their spending.

Political Party Partnerships

State party committees often serve as ideal partners for non-connected PACs that want to engage in voter mobilization without coordinating directly with candidates. A non-connected PAC focused on economic opportunity might partner with a state Democratic or Republican party committee to fund a shared field program that registers low-income voters and educates them on economic issues. Because party committees can engage in coordinated activities with their own candidates (subject to separate limits), the PAC’s cooperation with the party does not create a prohibited coordination with specific candidates, provided the party uses its own judgment in allocating the resources. The PAC’s contribution to the party committee must be disclosed and is subject to the usual limit for contributions to party committees ($10,000 per year for a state party committee under federal law). This model allows the PAC to reach a broader base while leveraging the party’s infrastructure.

Overcoming Challenges in Collaboration

Collaboration is not without obstacles. Non-connected PACs must maintain their distinct identities while pooling resources, and they must guard against missteps that could trigger legal scrutiny.

Maintaining Independence While Collaborating

One of the greatest challenges is ensuring that the collaboration does not erode the PAC’s independence or make it appear to be acting as an arm of a candidate or party. To preserve independence:

  • Document all agreements: Write down the terms of cost-sharing, decision-making, and resource allocation. This documentation can prove that the PAC operated independently if ever questioned by regulators.
  • Separate decision-makers: The people making strategic decisions for the non-connected PAC should not serve simultaneously on the board of the partner entity unless there is a clear firewall.
  • Keep candidate interaction to a minimum: Limit interactions with candidates to public events or through channels that are clearly not about coordination (e.g., open forums, published statements).

Managing Conflicts of Interest

When two or more non-connected PACs collaborate, they may have slightly different priorities or donor bases. For example, one PAC may want to focus on a primary election while the other wants to save resources for the general. Clear governance from the outset—such as a written coalition agreement with voting procedures—can prevent disputes. Additionally, if a PAC’s major donors object to a particular partner, the PAC must decide whether to proceed or risk losing support. Transparent communication with donors about collaborative activities is essential to maintain trust.

The Future of Non-Connected PAC Collaboration

Looking ahead, several trends will shape how non-connected PACs collaborate. The increasing use of digital fundraising platforms (like ActBlue and WinRed) enables small PACs to band together in joint fundraising appeals sent to massive email lists. The rise of cryptocurrency and decentralized finance may create new opportunities for pooled contributions, although the FEC has yet to issue comprehensive guidance on crypto contributions. Additionally, the continued growth of Super PACs suggests that collaboration among them will intensify, particularly as technology enables real-time data sharing via APIs. However, regulatory changes—such as new rules on coordination or enhanced disclosure requirements—could alter the calculus. Non-connected PACs that build collaborative muscles now will be best positioned to adapt to whatever comes next.

Conclusion: Amplifying Voice Through Partnership

Non-connected PACs are uniquely positioned to shape political discourse precisely because they lack a corporate or union sponsor. This independence gives them the agility to form partnerships based on shared values rather than institutional loyalty. Through joint fundraising, coordinated advertising, policy coalitions, overlapping voter outreach, and shared data, these PACs can achieve outcomes far greater than what any one committee could produce alone. The legal landscape is complex but navigable with competent legal advice and a commitment to disclosure. By embracing collaboration, non-connected PACs not only expand their own reach but also strengthen the democratic process—amplifying the voices of the citizens who fuel them. In an era of rising polarization and runaway campaign costs, smart collaboration may be the most effective tool a non-connected PAC has.