Why can't I choose any disbursement schedule when I enable Donate by Bank (ACH)?

In this article:

1. Who does this apply to?

2. What rule requires more frequent disbursements?

3. Why does Donate by Bank change anything?
4. What are my schedule options when I enable Donate by Bank?
5. Why can't I pick any two days I want?

6. Does the schedule apply only to my ACH contributions?

7. Can I still receive disbursements by check when Donate by Bank is enabled?

8. Why isn't Donate by Bank available to my Missouri committee?

9. What does ActBlue do if a contribution gets close to the deadline?

10. Can I go back to a less frequent schedule later?

11. How does this affect my reporting?

Who does this apply to?

This requirement applies to campaigns and organizations that use an ActBlue conduit account. With a conduit account, ActBlue receives your contributions, holds them briefly, and forwards them to the intended recipient on a disbursement schedule.

It does not apply to:

• Campaigns and organizations that use merchant accounts. If you have a merchant account through Stripe, your contributions settle directly from the payment processor to your bank account. ActBlue never holds or forwards the funds, so there is no ActBlue disbursement schedule to change.
• 501(c)(3) and 501(c)(4) nonprofit organizations. Nonprofits are not subject to the campaign finance forwarding rule described below and can enable Donate by Bank without changing their disbursement schedule.

If you are not sure which type of account you have, you can find that information in the Financial Settings page of your Dashboard.

What rule requires more frequent disbursements?

Federal campaign finance rules require that when an organization like ActBlue receives a contribution on behalf of a candidate or committee, it must forward that contribution to the committee within 10 days of receiving it (11 CFR §102.8). Many states have a similar rule.

The important detail is when the 10-day clock starts. For an electronic contribution, the contribution is considered received when the donor authorizes it, meaning the moment they submit the contribution form. The clock does not wait for the money to move between banks.

Why does Donate by Bank change anything?

Credit card contributions settle almost immediately. When a donor gives by card, ActBlue has the funds within about a day and can include them in the next scheduled disbursement. On a weekly disbursement schedule, a card contribution is forwarded well inside the 10-day window every time.

Donate by Bank (ACH) works differently. When a donor authorizes an ACH contribution, the bank transfer can take up to 4 business days to settle, and when there are bank holidays, this can further extend the settlement time. ActBlue cannot forward a contribution before it settles, because until then the funds are not final and the transfer can still fail or be returned.

That creates a gap that does not exist for cards:

• The compliance clock starts the moment the donor clicks submit.
• The money arrives 1 to 4 business days later.
• The contribution can only go out in a disbursement that runs after settlement.

With a once-a-week schedule, a slow-settling contribution can miss its scheduled disbursement and wait a full week for the next one.

Example. A donor gives by ACH on a Friday. Their bank transfer settles the following Wednesday or Thursday. If your account disburses once a week on Fridays, the contribution goes out that Friday, on day 7. If a bank holiday falls in that week, settlement can slip to Friday and miss the cutoff. The contribution then waits for the next Friday, day 14, which is past the deadline.

More frequent disbursements close that gap. When a disbursement runs at least twice a week, a settled contribution never waits more than a few days for the next one, and the forwarding deadline is met in every normal settlement scenario.

What are my schedule options when I enable Donate by Bank?

When you enable Donate by Bank on a conduit account, you choose a disbursement schedule from a set of options:

• Monday and Thursday
• Tuesday and Friday
• Monday, Wednesday, and Friday
• Every business day (Monday through Friday)

Two disbursements per week is the minimum. You can choose more if that works better for your treasurer or compliance team.

If your account is already on a schedule that meets the requirement, you will not be asked to choose a new one.

Why can't I pick any two days I want?

The requirement is about spacing as well as frequency. Two disbursements on back-to-back days, such as Monday and Tuesday, leave a five-day stretch with no disbursement at all. A contribution that settles on Tuesday afternoon would wait until the following Monday, and a slow settlement over a holiday weekend can push it up against the 10-day deadline.

Spreading the two days apart, as in Monday and Thursday or Tuesday and Friday, keeps every gap between disbursements to a few days. That is why ActBlue offers spaced options rather than an open calendar.

Does the schedule apply only to my ACH contributions?

No. Your disbursement schedule applies to all funds in your ActBlue account, including credit card, PayPal, and every other payment type. ActBlue does not run separate disbursement schedules for different payment methods. When you enable Donate by Bank, your whole account moves to the schedule you select.

For most committees this means money arrives more often, in smaller amounts, and your treasurer will see more disbursement records. Your total disbursed amount does not change.

Can I still receive disbursements by check when Donate by Bank is enabled?

No. Conduit accounts must receive disbursements by direct deposit (ACH) or wire to enable Donate by Bank. If your account is set up for checks, you will need to add bank information for direct deposit before you can enable Donate by Bank.

Why isn't Donate by Bank available to my Missouri committee?

Missouri law requires forwarding within 5 days of receipt. Because an ACH transfer can take up to 4 business days to settle, and longer over a weekend or holiday, no disbursement schedule can guarantee a 5-day turnaround. Donate by Bank is therefore not available for conduit accounts in Missouri. This is a legal limitation, not an account setting, and it cannot be changed on request.

What does ActBlue do if a contribution gets close to the deadline?

ActBlue monitors ACH contributions that have not yet been disbursed. If a contribution is approaching the forwarding deadline because of a slow settlement or a holiday, ActBlue may send an additional disbursement outside your regular schedule so it arrives on time. You do not need to request this.

Can I go back to a less frequent schedule later?

For as long as Donate by Bank is enabled on your account, your schedule needs to stay at two or more properly spaced disbursements per week. If you want to switch to a different qualifying schedule, such as moving from Monday/Thursday to every business day, contact our support team.

If you’d like to turn Donate by Bank off and adjust your disbursement schedule, contact our support team and we’d be happy to help. Keep in mind that ACH contributions authorized before you turned it off still need to settle and be forwarded within the deadline.

How does this affect my reporting?

ACH contributions do not appear in your reports until they have settled. A contribution authorized in the last days of a reporting period may settle, and be disbursed, in the next period. The more frequent disbursement schedule does not change that settlement timing. For details on how Donate by Bank affects reporting cutoffs, see "Can donors contribute to my campaign or organization using Donate by Bank (ACH)?"

Still have questions?

Our support team can walk through how a schedule change would look for your specific account before you enable Donate by Bank. Contact us through the Help link in your Dashboard.