# Per Apsera Policy 2M to Buckeyes PAC **[[Buckeyes PAC]]**, FEC committee **C00961060**, disclosed **$2,000,000.00** from an entity called **[[Per Apsera Policy]]** on its **Q3 2026 Form 3X** — file **2021633**, `F3XN`, received **2026-10-14**, coverage **2026-09-08 to 2026-09-30**, signed by treasurer **Chris Marston**. 🔴 **The contributor's address of record is the committee's own post-office box.** Both give **PO Box 26141, Alexandria VA 22313**. ## Terms | Item | Detail | |---|---| | Grantor | **Per Apsera Policy** — entity type `ORG`, **PO Box 26141, Alexandria VA 22313**, no FEC committee ID | | Recipient | **Buckeyes PAC**, FEC **C00961060**, **PO Box 26141, Alexandria VA 22313** | | Amount | **$2,000,000.00**, one row | | Receipt date | **2026-09-16** | | FEC line | **SA11AI** — Line 11(a)(i). ⚠️ The filer coded an organisational grantor on the *individual* contribution line, not Line 17 other receipts | | Row aggregate | **$2,000,000.00** — first and only contribution on this record | | Share of itemised receipts | **100.00%** | | Disclosed | **Form 3X (`F3XN`)**, Q3 2026, file **2021633**, received **2026-10-14** | | Amendment / memo status | **original** form code, **no** memo flag — live money, not an amendment or a restatement | ## What the money bought, on the same document The committee's Schedule E on this report is a **single line**: **$2,000,000.00 opposing [[Sherrod Brown]]**, expenditure date **2026-09-17**, election code `G2026`, payee **[[Flexpoint Media]]** at **100.00%**. | | Date | Amount | |---|---|---| | Money in, from Per Apsera Policy | 2026-09-16 | **$2,000,000.00** | | Money out, against Sherrod Brown | 2026-09-17 | **$2,000,000.00** (first reported on Form 24 file **2012294**) | **One day apart, to the dollar.** The committee's coverage period opens 2026-09-08, so the whole life of this vehicle — registration, funding, a single buy against a Senate candidate in a Toss Up race, and first disclosure five weeks later — is on one document. > [!note] Restated money — the expenditure side is a confirmed restatement, the receipt side is new > The Schedule E line is carried by a **periodic report** with an expenditure date predating the receipt date. A > line-by-line comparison confirms **100.00% restatement of Form 24 file 2012294**, > so it is **not** counted in the 2026-10-14 tranche's new-money headline. This Deal's **$2,000,000.00 value > is the receipt**, which is first disclosure. ## Why it matters - **It is a complete pass-through with a single purpose.** An entity with no FEC identity and no disclosure obligation of its own supplied 100% of a committee that existed to place one $2M advertisement against one candidate. - **The shared mailbox is the harder fact.** Yesterday's sweep built [[Club for Growth Action 6.3M to Win It Back PAC]] on a shared treasurer and suite number between donor and recipient. This is the same shape with the donor outside the FEC system entirely, so the only disclosure of the arrangement is the recipient's own report. **The honest caveat: a shared mailbox is a shared compliance arrangement, and is not by itself evidence of common control.** - **[[Flexpoint Media]] again.** The buyer took 100% here, 85.1% of [[Texas PAC]]'s $133.6M, and the majority of [[Fight On Iowa]]'s notices. Three state-branded committees in three states, one buyer. ## Open questions - What **Per Apsera Policy** is, and who funds it. Corporate or tax records this task cannot reach. - Whether **Chris Marston** signs for other committees at the same mailbox. ## Sources - FEC Form 3X, Q3 2026, file **2021633** — `https://docquery.fec.gov/dcdev/posted/2021633.fec` ## See Also - [[Buckeyes PAC]] · [[Per Apsera Policy]] · [[OH-Sen-2026-Special]] · [[Sherrod Brown]] - [[Flexpoint Media]] · [[Texas PAC]] · [[Fight On Iowa]] - [[Dark Money]] · [[Super PACs]] · [[State-Branded Super PAC Template]] · [[Deals Hub]]