For all his golden stashes, former President Donald Trump is notoriously stingy—with his personal funds as well as the hundreds of millions of dollars he’s extracted from his supporters over the years. And that’s all the more reason why government watchdogs are raising the alarm about new campaign finance filings that show, a month before the midterm elections, $20 million in political donations from Trump.
Trump’s largest contribution ever came from his Save America leadership PAC on Oct. 3 to the new super PAC-Bloc Trump, it’s called. Make America Great Again Inc. On the same day, the old pro-Trump super PAC threw another $8.9 million behind the new group.
Super PACs can spend unlimited amounts of money to support candidates, so on the face of it, the donation could be said to be a generous contribution from Trump to MAGA because during a critical election. But as some campaign finance experts have pointed out, the specifics here suggest that Trump is actually trying to get around legislation that would prevent him from spending his personal stash on the 2024 presidency.
Paul S. Ryan, a veteran campaign finance lawyer now the deputy executive director at the Funders Committee for Civic Participation, said it was “the only plausible explanation.”
“The only thing Trump can’t do with the millions and millions of dollars he’s pouring into his leadership PAC is to support himself. The only reasonable explanation for this move is to divert that money to be spent on his own campaign,” Ryan told The Daily Beast.
Jordan Libowitz, communications director at Citizens for Responsibility and Ethics in Washington, made a similar observation.
“Trump can use Save America money for pretty much anything he wants—except to support his own campaign,” Libowitz said. “If he wants to use it to help the Republicans in the midterms, he’ll just do it. Trump is always about Trump. This is probably a way for him to move money to help the candidacy before he declares.
When Trump created Save America after the 2020 election, he established it as a leadership PAC, which has both advantages and disadvantages. For Trump, the obvious benefit would be weaker regulations on spending — the leadership PAC is notorious as a “slush fund” for personal expenses. Trump could take the millions he raised and spend it on his business, his friends, and his wife’s favorite luxury designers, for example.
But the big drawback for Trump, as he prepares for his 2024 comeback, is that he cannot use the leadership PAC money to finance his own political activities. That’s a lot of money—a total of $138 million so far—with about $70 million still just sitting in its flagship fundraising account.
However, one thing Trump can do with that money is spend an unlimited amount to help his allies. In fact, Save America can act exactly like a super PAC in that regard. Which, according to the deputy executive director of the documented Brendan Fischer, shows that the Trump team is trying to “create deniability” so that they can spend money later to support the Trump presidency 2024.
“Once Trump becomes the candidate, it’s clearly illegal to transfer Save America funds to a super PAC. But Trump seems to be trying to create deniability by making the transfer now, and by having MAGA Inc. spend some money in mid-2022. That way, the Trump team can argue that Save America gave to MAGA Inc. to support Trump-backed candidates, and it happened that the super PAC ended up with the remaining money that independently chose to spend supporting Trump 2024,” said Fischer. .
Further, if Trump’s true goal is to support MAGA’s midterm candidates, Fischer said, there is no reason for Trump to give Save America funds to a super PAC. In fact, the move is actually more of a limitation on how Trump can help his friends.
“As a hard money Pac, Save America actually has MORE flexibility to support other candidates than the super Pac,” explained Fischer. “Both Save America and MAGA Inc. can spend an unlimited amount on ads supporting a candidate, but only Save America can donate directly to a candidate. By transferring Save America funds to a super PAC, that money can no longer be used for direct contributions .
Ryan agreed. “The transfer of money shows that he wants to spend himself,” he said. “It’s illegal, but that’s probably the motivation and he’s probably going to get away.”
Ryan was referring to federal laws that restrict candidates from coordinating with super PACs on fundraising and spending efforts — charges that are notoriously difficult to justify.
Aaron Scherb, senior director of legislative affairs at Common Cause, said Trump would launch, thanks to federal enforcement historically in question.
“Coordination is still definitely illegal here, even though the FEC has shown no appetite to enforce coordination rules and laws. There’s no smoking gun here per se, but it looks like loophole exploitation, and the three GOP commissioners have shown zero willingness to investigate and enforce existing coordination laws,” Scherb said. “Until they do, special interests and dark money groups will continue to exploit loopholes to victimize voters every day.”
But with this loophole, Trump has turned the traditional “dark money” move on its head. For years, candidates have tried to find loopholes that would allow them to tap super PAC money, which can be raised from megadonors and corporations in unlimited amounts. Trump’s Save America PAC, however, has a different donor base.
“What Trump is doing is preying on small donors,” Ryan said. “He doesn’t have to go the super PAC megadonor route, because he takes every dollar he can swindle from small-dollar, often elderly donors, and puts it into his campaign coffers. This move seems to serve that purpose — finding a way to put that swindled money to political use.” .
The Department of Justice has reportedly opened an investigation into Save America’s fundraising practices, after members of the 6th House Window Committee laid out what they think is a wire fraud scheme to bilk donors out of hundreds of millions of dollars through false elections.
Fischer said that, at the end of the day, the bottom line won’t lie.
According to the FEC report, the MAGA Inc. super PAC has spent about $11 million in the midterm elections. However, Fischer said, that doesn’t mean the group used Trump’s money, as the super PAC has also raised more than $11 million from sources other than Save America.
“This means the $20 million transferred from Save America to MAGA Inc is effectively still available for Trump’s 2024 run,” Fischer said. “And any transfers from Save America to super PACs in these final weeks before the election will likely never be spent.”