We are trying to decide whether debit cards are permitted for Federal Election Campaigns. The Federal campaign law at 11 CFR 103.3(a) says: "A committee shall make all disbursements by check or similar drafts drawn on an account at its designated campaign depository, except for expenditures of $100 or less made from a petty cash fund maintained pursuant to 11 CFR 102.11."
We need to know whether the use of a debit card could be construed as a "similar draft." A representative of an election committee asserts that "industry best practices" consider debit cards to be the same as a draft. To us, a check or draft typically means paper. But we'd be happy to be wrong.
Does anyone know of a definitive ruling? Does everyone else give debit cards to federal campaigns?
I thought getting old would take longer.