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When Donald Trump officially announced on Tuesday that he’s running for president again in 2024, the fundraising race reset.
But in many ways, that race never stopped. The former president has been raising money ceaselessly over the last year, and while his massive war chest might seem like an asset, in reality it could also pose some liabilities—especially as Trump tries to lock his grip on an increasingly nervous Republican Party.
The biggest single problem for Trump is that he cannot jumpstart his campaign with any of the money he’s been raising into his flagship Save America leadership PAC, which would otherwise give him an intimidating $70 million advantage.
There’s a hard rule against candidates using leadership PACs to support their own political efforts, so Trump’s campaign can’t touch any of that money. And that fact has led him to adopt some creative, confusing, and possibly unlawful ways of moving it around.
First, Trump created a new campaign committee for his 2024 re-election bid—“Donald J. Trump for President 2024.” That will give the one-term hopeful a more or less clean start on fundraising, albeit with some key structural benefits over his rivals.
One of those advantages is the extensive donor contact list Trump has built up over the years. Trump has used that information to raise money since leaving the White House, but he has to find a way for the new campaign to get its hands on that valuable data—and he doesn’t want to have to pay for it.
The Trump team will solve that problem with a joint fundraising committee, called “Trump Save America Joint Fundraising Committee.” (Not to be confused with Save America, or his Save America Joint Fundraising Committee, of course.) That new group will serve to connect the new campaign to Save America, opening up access to that valuable donor data.
But that still leaves the biggest question unanswered. Even after barraging donors with Save America fundraising requests for the last two years—including through automatically recurring donation schemes and potentially fraudulent promises—Trump now finds himself unable to put that money where he needs it the most. He’ll have to start fresh, and find a way to motivate and sustain a small-dollar base that’s coming off of a midterm fundraising blitz and is already dangerously exhausted.
Jordan Libowitz, communications director at government watchdog Citizens for Responsibility and Ethics in Washington, explained that even though Trump wields a huge bankroll—with nearly three times more cash on hand than the Republican National Committee—Trump has hemmed himself in.
“It comes back to what I see as really the most basic thing: Donald Trump doesn’t like spending money on anything that isn’t Donald Trump—and he doesn’t even like spending his own money on Donald Trump,” Libowitz said. “He loves to spend other people’s money.”
Over the last two years, Trump has chosen to raise money for his personal leadership PAC, which Libowitz described as “just shy of a slush fund.”
But recent data shows that Trump’s once mighty army of small-dollar donors might not be able and willing to give him what he needs.
“That’s a real concern,” Libowitz said. “They’re not megadonors. They only have so much money, and they’ve been getting asked to hand it over consistently for years now.”
While Trump has spent nearly all of the last two years licking his wounds at his Mar-a-Lago resort compound, he has also been bleeding his small-dollar donors dry. And it’s getting harder to convince them to part with their money. Trump’s most recent campaign finance filings revealed a total loss of more than $13 million, and every dollar he raises now is nearly wiped out by fundraising costs alone.
To solve that problem, Trump’s allies have created super PACs to solicit money from wealthy backers in unlimited amounts.
But that’s created another headache, because the committees are really starting to pile up.
The full Trump-aligned apparatus counts at least nine separate active political committees. But because they often reuse the same names, it’s maddening to keep track of them. And all the old committees in this armada still have money left over, too—more than $10 million combined, though Trump can’t lay claim to all of it.
Here they are, in all their homonymous glory:
Donald J. Trump for President 2024
Trump Save America Joint Fundraising Committee
Save America (leadership PAC; $69.7 million in the bank)
Make America Great Again PAC (converted from the old Trump campaign; $1.1 million in the bank)
Save America Joint Fundraising Committee (splits money between Save America and MAGA PAC; $6.3 million in the bank)
Make America Great Again, Inc. (new super PAC; $23.4 million in the bank)
Trump Make America Great Again (small-dollar joint fundraising committee between the old campaign and the Republican National Committee; reportedly started winding down last year; $5.4 million in the bank)
Trump Victory (high-dollar joint fundraising committee between the old campaign and RNC; reportedly winding down; $1.8 million in the bank)
In all, these committees sit on $111.5 million. And campaign finance rules mean that Trump’s new campaign won’t be allowed to access the vast majority of it—including all that super PAC megadonor cash.
But that doesn’t mean he won’t attempt to skirt those rules. In fact, it appears he’s already trying to do just that.
The first indicator came last month, when the Save America leadership PAC transferred a whopping $20 million to the new Make America Great Again Inc. super PAC (MAGA Inc.).
The move raised eyebrows among legal observers, who said it appeared Trump was trying to get a jumpstart on his campaign by funding a super PAC that would support him in the future. Only problem: That’s against the law.
Brendan Fischer, deputy director of good government watchdog Documented, told The Daily Beast that, with the midterms over, it is “even more obvious” that the MAGA Inc. super PAC “was never really about helping other candidates, and always about helping Trump.”
“When it comes to helping Republicans in the midterms, MAGA Inc. was kind of a bust. It spent money late on races that were already saturated, and the roughly $16 million it spent may not even put it in the top 20 outside spending groups,” Fischer said, pointing out that all this was happening while Save America’s bank account was full to the brim with money he could have spent on those races.
However, Fischer said, since Save America’s funds can’t be used to support Trump’s presidential run, he transferred the money to MAGA Inc.
“The super PAC spent a relatively small amount in the final stretch of the midterms, and the remainder will almost certainly be spent backing Trump’s 2024 run,” he said.
On Monday, the nonpartisan government watchdog Campaign Legal Center filed a complaint with the FEC, accusing Trump of breaking the law on the eve of his big announcement.
Saurav Ghosh, CLC’s director of federal campaign finance reform, told The Daily Beast that Trump clearly wants to be able to use the money he’s raised for himself, but the law stands in the way of that.
Ghosh said that those coordination rules are “often openly trampled by candidates, particularly ones running for president.”
“Presidential candidates want to get a leg up and start out with as big a war chest as possible. It’s clear that Trump saw Save America as that war chest from the very beginning, and his legal team put together one way for this pot to be available on day one,” Ghosh said. “Unfortunately, the law accounts for not when you announce you’re going to run, but when you decided that you were going to run. So the decision to transfer all this money is a violation of that law.”
Still, this all leaves Trump with the enviable problem of what to do with his nearly $70 million in Save America funds—much of which he raised on the back of the Big Lie, and can spend on essentially anything but his own campaign.
“It’s really a question of what does he do next,” Ghosh said. “You can only spend so much money with direct transfers to other candidates and on staging events, but eventually you run out of ways to spend the money. At this point the midterms are over and the only thing he can spend the ads on is for himself. So what he’s doing is putting it into a vehicle that can buy ads for Donald Trump, and attack his opponents.”
Libowitz echoed that point, and said Save America’s millions, which can be transferred directly to campaigns and spent on political ads for other candidates, could serve as a “carrot and stick”—to both incentivize allies and intimidate rivals.
As for those rivals, Trump’s chief concern, Florida Gov. Ron DeSantis, happens to face a problem similar to Trump.
“DeSantis is raising this absurd amount of money into his state PAC, clearly given to him by donors with the understanding that he’s going to run for president,” Ghosh said. Like Trump, DeSantis can’t put that money toward a federal presidential campaign, and he can’t transfer it to a pro-DeSantis super PAC.
“No one will ever do this, but you can refund it and ask those donors to give it instead to a committee that you’ve set up for a federal campaign,” Ghosh said. “But you can’t just move the money wherever you want.”