# Democracy Matters 15.5M to AB PAC and Project 218 Two **pre-general reports** received on e-file receipt date **2026-10-22** itemise receipts from **[[Democracy Matters]]**, an entity filed as an **organization** rather than a political committee, at 996 Maine Ave SW, PMB 21, Washington, DC. Both are dated **2026-10-07**. | Recipient | Committee | Amount | Line | File | Aggregate on filing | |---|---|---|---|---|---| | [[AB PAC]] | C00492140 | $8,450,000.00 | `SA17` — Non-Contribution Account | 2039073 | $14,010,000.00 | | [[Project 218]] | C00871368 | $7,000,000.00 | `SA11AI` | 2039056 | $12,880,000.00 | | **Total** | | **$15,450,000.00** | | | **$26,890,000.00** | ## The line numbers differ, and that is the interesting part The **$8,450,000.00** into [[AB PAC]] is itemised on **`SA17`, Other Federal Receipts**, with purpose text **"Non-Contribution Account"** — money that cannot be spent on federal hard-money activity. The **$7,000,000.00** into [[Project 218]] is itemised on **`SA11AI`**, the ordinary itemised individual-or-organisation contribution line. The same payer, the same date, two different characterisations by the two recipients. ## Why it matters Most large transfers between political committees can at least be followed one step further back, because both ends of the transfer file with the FEC. This one cannot. [[Democracy Matters]] registers nothing with the commission, so the federal record names **no person or entity** that put up the $15,450,000.00 — only the address of a mailbox in southwest Washington. The two aggregates show it is not a one-off: **$26,890,000.00** has moved from this one entity into these two committees across the cycle, which is more than most named megadonors give in total. ## What is not known - **Who funds Democracy Matters.** Not on the federal record, and this page does not guess. - **Its organisational form.** The filings give an address and an entity type of `ORG`. Nothing read for this page establishes whether it is a 501(c)(4), an LLC, or something else. - **Whether the two payments are one decision.** They share a date and a payer, which is evidence, not proof. ## Sources - AB PAC pre-general report, file **2039073** — https://docquery.fec.gov/dcdev/posted/2039073.fec - Project 218 pre-general report, file **2039056** — https://docquery.fec.gov/dcdev/posted/2039056.fec