Debit cards for Federal Election Campaigns

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?

It would appear they are allowed. Whether you want to allow it is another matter.

http://www.fec.gov/law/policy/guidance/internal_controls_polcmtes_07.pdf

Thank you.

" Whether you want to allow it is another matter."

I'm sure we will. We like this Congressman.