3 Mistakes Hawaii Campaign Treasurers Make on the CSC Form

A Hawaii Campaign Spending Commission (CSC) periodic report — Preliminary, Primary, General, Final — is a straightforward document. Contributions in, expenditures out, loans outstanding, cash-on-hand at the end of the period. Yet across dozens of publicly-posted advisory opinions and enforcement actions, three error patterns show up over and over. They're the errors first-time treasurers make; they're also the errors experienced treasurers make in the last hour before the deadline.

This post walks each of them, why they happen, and how to fix them. It is a companion to our longer Preliminary Report guide. The goal for both is the same: an accepted filing on the first submission.

What a "clean" filing looks like

A clean CSC filing is one the Commission accepts on submission and does not issue a Notice of Additional Information Required against. Three characteristics show up together:

• Every donor over the aggregation threshold has complete information. Name, mailing address, and (for individuals above the disclosure threshold) employer and occupation. No blank cells.
• Expenditures are coded to real purposes. The payee name matches an identifiable business or individual; the purpose code matches what that payee actually did.
• Cash-on-hand reconciles. The end-of-period balance in the CRS equals the bank statement balance adjusted for outstanding checks and deposits in transit. The CRS computes what it should be from your Schedule A + B + C entries — the two numbers agree.

The rest of this post is about the three most common places those characteristics break down.

Mistake 1: Missing donor addresses on aggregated contributions

Why it happens

Individual contributions above a certain aggregate election-period total require donor identifying information — name, mailing address, employer, occupation. The threshold applies to the aggregate for the election period, not to any single contribution. A donor who gave $75 in January and $50 in March has crossed the $100 aggregate threshold, and the $50 March contribution now has to be reported with full donor information — even though $50 by itself is below the threshold.

The mistake happens because the CRS collects donor info per-transaction at entry time. A treasurer who entered the $75 contribution in January without the address (below threshold at that point) has to go back and edit that entry when the March contribution takes the aggregate over the line. Nothing warns them; the aggregation math is the treasurer's to run.

How to fix it

Two-step process:

1. Collect donor info on every contribution, not just above-threshold ones. Your contribution form or online donation page should always capture name, address, employer, and occupation. Then it doesn't matter when the aggregate crosses; the data is already in your records.
2. Before you submit, run an aggregate check. Sort your Schedule A entries by donor and verify: for every donor whose cumulative election-period total is above the address threshold, every one of that donor's contributions carries the full donor information. Anywhere it doesn't, edit and add the details.

Workaround for cash donors

Cash contributions from anonymous donors are limited to a specific per-donor per-election cap — check current CSC guidance for the operative number. If a donor won't provide identifying information and their aggregate would cross a threshold, the contribution has to be refunded or converted to a non-anonymous form (a check or credit card). Do not accept the cash and then omit the donor info; that's the version the Commission finds when it cross-checks the deposit with your bank statement.

Mistake 2: Bank fees and refunds classified as expenditures

Why it happens

A bank fee looks like money leaving the account, so it feels like an expenditure. A refund of a contribution also looks like money leaving the account, so it also feels like an expenditure. Neither is exactly right. Treating them as ordinary Schedule B expenditures produces contribution totals that don't match your deposits and cash-on-hand that doesn't reconcile.

The correct classification

• Bank fees and merchant-processor fees. These are Schedule B expenditures. Report them with the bank / processor as the payee, dated the day the fee posted, in the "Bank Fees" (or equivalent) purpose category. Do not net them against the contribution amount. If a $100 donation comes in with a $3 processor fee, the contribution on Schedule A is $100 and the fee on Schedule B is a $3 expenditure. The net cash change is $97, which is what the bank statement will show.
• Refunded contributions. A refund is not an expenditure — it's a reversal of the original contribution. Report it as a negative entry on Schedule A dated the day the refund was made (or as the CRS-specific offset entry it prompts for). This preserves the audit trail: the original contribution is still visible, and the offset shows the reversal.
• Returned checks (bounced). Same treatment as a refund — reverse the original Schedule A entry with an offset on the date the return posted. Do not treat the returned check as a Schedule B expenditure.

Mistake 3: Cash-on-hand does not reconcile to the bank

Why it happens

The CRS asks for the ending cash-on-hand figure and computes what it should be from your Schedule A + B + C entries and your prior-report cash-on-hand. If the two don't match, the report is rejected. Almost every rejection at this step comes from one of three sources:

• Outstanding checks. An expenditure recorded (correctly) on Schedule B when issued may not have cleared the bank by the end of the period. Your Schedule B says the money is gone; the bank statement still shows the money in the account. This is a normal reconciling item — the ending cash-on-hand you report is your ledger balance (post-Schedule-B), not the bank statement balance.
• Deposits in transit. A contribution received in the last days of the period may have been recorded on Schedule A but hasn't cleared the bank. Same treatment: report the ledger balance, which reflects the contribution.
• Missed entries. A contribution that hit the bank but wasn't entered on Schedule A, or an expenditure that cleared but wasn't entered on Schedule B. This is the one that's actually broken — walk the bank statement line by line and find the missing entry.

How to fix it

Run a bank reconciliation before you open CRS. On a spreadsheet:

1. Start with the bank statement ending balance for the period.
2. Add deposits in transit (contributions on Schedule A that hadn't cleared).
3. Subtract outstanding checks (expenditures on Schedule B that hadn't cleared).
4. The result is your true cash-on-hand — the number that should reconcile to the CRS calculation.

If the two still don't match, the difference is a real error. Walk the bank statement line by line against Schedule A + B until you find it. The most common culprits: a duplicate entry, a fee entered as a negative contribution instead of an expenditure, or a transfer between campaign accounts entered as an expenditure on one side without the matching contribution on the other.

Bonus mistake: waiting until the last day

The CRS accepts filings up to 11:59 pm Hawaii time on the due date. It is under the most load during the last two hours. Rejections and reconciling issues surface exactly when there is no time to fix them.

File 24 hours early. If the Commission or the CRS surfaces a problem, you have business hours to resolve it. The late-filing fine — $50 per business day past the deadline under HRS Chapter 11 — starts accruing the moment the CRS closes.

How OpenBooks catches these before you file

OpenBooks reconciles bank feeds against your recorded contributions and expenditures continuously. By the time you open CRS, three checks are already green:

• Every donor above the aggregation threshold has complete address / employer / occupation information; the aggregate math ran on entry.
• Bank fees and refunds are already classified correctly (bank fees as Schedule B expenditures against the bank as payee, refunds as Schedule A reversals).
• Cash-on-hand ties to the bank statement, with outstanding checks and deposits in transit reconciled.

The Preliminary, Primary, General, and Final reports export from the same running ledger. You review and submit; OpenBooks does not sign for you, and it does not replace your CPA on the year-end tax filings that follow the campaign.