It's also unclear how the 28-day deadline applies to multiple donations – could someone donate $99,999 one day, and then $99,999 the next day without triggering the 28-day requirement?
One of the biggest problems in the midst of this year's billion-dollar campaign is the failure of the Federal Election Commission to write the rules for what was supposed to be another breakthrough reform: full disclosure of the multiple donations bundled by lobbyists to court candidates.
In most cases, they received multiple donations, which collectively amounted to more than $290,000.
I've also received multiple donations from people who live paycheck-to-paycheck, some of whom have only a cat or dog as their family, willing to give, even in dire times, to make the world a better place for animals and humans they'll never meet or know.
It requires presidential and Congressional candidates to report to the public on their lucrative bundled contributions — the large packages of multiple donations that lobbyists and other favor-seekers amass to secure out-size gratitude from candidates.
Others like the fact that they don't have to keep track of receipts for multiple donations.
Electoral Commission rules mean any single donation to a political party of more than £7,500 must be declared, and multiple donations from an individual that exceed that amount within a year must also be reported.
With multiple donations donors are saying – I am really interested in your cause – but we do nothing about it".
Sir Hayden calls for much greater policing powers for the current Electoral Commission, acknowledging that ensuring there are not multiple donations tallying more than £50k from one benefactor will prove difficult.
The main feature of a donor-advised fund is that it provides one-stop giving, taking much of the paperwork out of multiple donations.
