While new Members have rushed to start PACs, some long-serving Members have declined to do so. For instance, neither 20-term Rep. Pete Stark (D-Calif.) nor Rep. Barney Frank, ranking member on the House Financial Services Committee, has a leadership PAC.
Stark is one of the most senior Members without a leadership PAC after being first elected to Congress in 1972, before the FEC was created. Frank, meanwhile, described leadership PACs as an unnecessary burden.
"I wish I didn't have to do any fundraising at all," said the 16-term Massachusetts Democrat, explaining why he does not have a leadership PAC. "But I do attend fundraisers to help raise money for the [Democratic Congressional Campaign Committee] and many of my colleagues."
For more than a decade, it was unknown how many Members had leadership PACs because the FEC did not require federal lawmakers to disclosure their connections to PACs until 2009. Even then, some Members of Congress were slow to send in the required forms detailing those connections.
As of the end of September, several Members of Congress failed to file new statements of organization linking themselves to their leadership PACs as required under FEC rules. Many of the campaigns and Congressional offices contacted by Roll Call explained that the missing forms were an oversight that they planned to fix.
"The PAC was started before the related paperwork included an option to declare it as a leadership PAC," said Jonathon Dworkin, spokesman for Rep. James Langevin (D-R.I.), who operates a leadership PAC called Ocean State PAC. "The Congressman has reported all of its activity as required since it began and is also updating the original paperwork with a new form to show it is a leadership PAC."
While the new filing is just an amendment, some Washington watchdog groups say it is critical that Members identify their PACs.
"I think it is more than a trivial matter," said Paul S. Ryan, a lawyer at the Campaign Legal Center who works on election law issues. "The public has no way of knowing that a Member of Congress has a second pot of money because that Member of Congress failed to fill out the paperwork."