He does so mostly through his 527 group, American Solutions for Winning the Future, a political organization that does not report to the Federal Election Commission and is not subject to FEC contribution restrictions.
Possibly due to its unrestricted status, in fundraising Gingrich's group has crushed the federal political organizations of other potential 2012 contenders. American Solutions raised and spent more than twice the combined total of Sarah Palin's and Mitt Romney's federal PACs, which are limited by FEC fundraising restrictions, over the past two years.
In 2009 and 2010, American Solutions raised a total of $28,234,197 and spent $29,200,048--$13,739,415 raised and $13,813,441 spent in 2010, $14,494,782 raised and $15,386,607 spent in 2009.
In 2009 and 2010, Sarah Palin's Sarah PAC raised $5,654,759 and spent $4,356,362; Mitt Romney's Free and Strong America PAC raised $7,580,620 and spent $8,675,545. Those totals do not count fundraising for state-level PACs, of which Romney has several.
If Gingrich runs for president, he can't use any of that 527 money--"He can't touch it," Paul S. Ryan, FEC program director and associate counsel with the Campaign Legal Center, told me--but the group could, conceivably, run ads on his behalf (though probably not encouraging people to vote for him--legal and regulatory applications are a bit hazy).
But if his activity over the past two years is any indication, despite its unrestricted nature, Gingrich shouldn't have much trouble raising money for a 2012 presidential campaign
Here are the incremental fundraising and spending totals for American Solutions, which reports its finances to the IRS:
2010 raised spent 4th Quarter $3,816,519 $3,955,127 3rd Quarter $3,840,912 $3,734,179 2nd Quarter $3,408,680 $3,215,854 1st Quarter $2,673,304 $2,908,281 2009 2nd half $6,360,032 $6,729,833 1st half $8,134,750 $8,656,774
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