# Club for Growth Action 6.3M to Win It Back PAC **[[Win It Back PAC]]**, FEC committee **C00844613**, disclosed **$6,300,000.00** from **[[Club for Growth Action]]** on its **October monthly Form 3X** — file **2020535**, `F3XN`, report code `M10`, received **2026-10-13T13:08:01** (FEC local time), coverage **2026-09-01 to 2026-09-30**, signed by treasurer Adam Rozansky. ## Terms | Item | Detail | |---|---| | Recipient | **Win It Back PAC**, FEC **C00844613**, Super PAC (IE-only), first filed 2023-07-05, **2001 L St NW Ste 600, Washington DC 20036** | | Contributor | **Club for Growth Action**, FEC **C00487470**, Super PAC (IE-only), first filed 2010-08-11, **2001 L St NW Ste 600, Washington DC 20036** | | Structure | **Four itemised Line 11(c) rows** totalling $6,300,000.00. Three are itemised at or above $1M: **$2,200,000.00** (2026-09-02), **$1,600,000.00** (2026-09-03), **$2,100,000.00** (2026-09-08). The fourth is **$400,000.00** | | Aggregate on the rows | **$10,835,000.00** cycle-to-date (filer-dependent; see the Rule 4c note) | | Shared treasurer | **Adam Rozansky signs both committees** | | Shared address | **Both committees file from 2001 L St NW Ste 600, Washington DC** | | Disclosed | FEC **Form 3X**, October monthly, **file 2020535** | ### The recipient's September, reconciled | Line | Figure | |---|---| | Total receipts, 2026-09-01 to 2026-09-30 | **$6,350,001.17** | | Line 11(c), other political committees | **$6,300,000.00** — all of it Club for Growth Action | | Line 11(a), individuals | $50,000.00 (one itemised donor) | | Other receipts | $1.17 | | Total disbursements | **$6,395,108.63** | | Independent expenditure this period (summary line) | **$6,375,472.70** | | Cash on hand, 2026-09-30 | **$126,792.10** | | Cycle receipts to date | **$15,799,831.21** | | Cycle disbursements to date | **$16,211,797.23** | **Club for Growth Action is 99.21% of the month.** The committee took in $6.35M, spent $6.40M, and closed September with **$126,792.10** — it is a pass-through operated at near-zero float. ### Where the money went The month's Schedule E payees, from the same document: | Payee | Amount | |---|---| | Vaulter LLC | $2,177,424.72 | | Medium Buying LLC | $1,997,508.91 | | Google Ads | $1,105,053.55 | | The Trade Desk Inc. | $978,575.98 | | ColdSpark | $64,739.32 | | Darby House LLC | $47,490.00 | | Club for Growth (memo-coded) | $4,680.22 | > [!note] Rule 4h — the Schedule E on this document is a restatement > All 23 Schedule E rows restate notices already filed. The $6,375,472.70 is **not new spending** and is > excluded from the 2026-10-13 tranche's new-money total per Rule 4h. The payee stack above is published > as the composition of money already disclosed, not as a new buy. The Club for Growth rows carry the > memo code; per **Rule 4d** they restate dollars itemised elsewhere in the same document. > [!warning] Rule 4c — the $10,835,000.00 aggregate is not a total > The itemised rows carry a running cycle aggregate of **$10,835,000.00**. Per Rule 4c that column's > meaning is filer-dependent and it is **not** publishable as a committee or relationship total. It > indicates roughly **$4.5 million** of earlier Club for Growth Action money into this committee that has > not been read into this vault from a filed document. ## Why it matters **The donor and the recipient are the same operation.** Adam Rozansky is treasurer of record for both committees and both file from **Suite 600 at 2001 L Street NW**. This is not an arm's-length contribution between independent actors; it is [[Club for Growth]]'s money moved into a separately named vehicle that then buys the advertising. The vault already records **Win It Back PAC** spending in [[KS-Sen-2026]] against [[Adam Hamilton]] — $519,950.85 on receipt date 2026-10-09 — without any page explaining whose money it was. **The naming is the point.** A reader of a Schedule E sees *Win It Back PAC*. The organisation behind it appears nowhere on the expenditure, and the link is visible only on a monthly receipt report filed six weeks later. The same structural pattern this vault has recorded for the state-branded IE vehicles applies to a national one. **It compounds the donor-concentration problem already on the Club for Growth page.** Club for Growth Action's own funding is heavily concentrated in [[Jeff Yass]] — the vault records roughly $19 million from him in the 2024 cycle, making him that organisation's largest individual funder. Where Club for Growth Action's 2026 money comes from is not on this document; its own Q3 report is due **2026-10-15**. ## Open questions - **Club for Growth Action's own Q3 receipts**, due 2026-10-15 — whether the Yass concentration holds in this cycle. - The **$4.5 million** of earlier transfers implied by the aggregate column and not yet read. - **Vaulter LLC** and **Medium Buying LLC**, which placed $4.17M of one month's buying between them and have no page in this vault. - Which races the September buying was in — the restated rows are not resolved to races on this page. ## See Also - [[Win It Back PAC]] · [[Club for Growth]] · [[Jeff Yass]] - [[KS-Sen-2026]] · [[Independent Expenditure]] · [[Super PACs]] - [[Deals Hub]]