PIERRE, S.D. (KELO) — A joint fundraising committee that South Dakota Governor Kristi Noem started in 2021 to collect financial contributions from donors during her appearances at the national level has already transferred more than $1.8 million to other political committees she controls, including her re-election campaign.

The governor registered the Noem Victory Fund with the Federal Election Commission on May 17, 2021. Through June 30 of this year, receipts totaled $2,533,667.96, mostly from individual contributions by people living in other states where Noem speaks.

The largest amount of transfers from Noem Victory Fund went to her Kristi For Governor candidate committee at the state level, chaired by former Lieutenant Governor Steve Kirby. According to a KELOLAND News analysis, her re-election account received transfers totaling $1,139,810.86 from Noem Victory Fund.

Noem’s Kristi For Governor account reported $3,038,876.00 of income and $1,912,774.82 of expenses, with an ending balance of $7,762,901.57, for the pre-primary period of January 1 through May 18, 2022. Much of that money has come from individuals outside South Dakota. She defeated Representative Steve Haugaard 91,661 to 28,315 in the June 7 primary.

Her Democrat opponent, state Representative Jamie Smith, reported an income of $137,424.97 and expenses of $27,156.84, with a balance of $110,268.13, for the same period. He didn’t have a primary opponent.

According to Abby Wood, a professor of law, political science, and public policy at the University of Southern California school of law, the U.S. Supreme Court in a 2014 decision struck down aggregate limits on political contributions and opened the way for a joint fundraising committee to legally operate.

Wood pointed to FEC rules that now specifically regulate transfers between a candidate’s various committees.

The second largest amount of transfers from Noem Victory Fund went to the campaign committee of her running mate, Lieutenant Governor Larry Rhoden. His state-level re-election account received transfers totaling $314,210.89 from Noem Victory Fund.

Several other committees also received substantial transfers from Noem Victory Fund.

SD Strong Leadership PAC, a state-level political action committee chaired by Kirby that provided funds to Republicans favored by Noem in June legislative primary elections, was solely funded through transfers totaling $191,570.06 from Noem Victory Fund.

A federal committee known as Keeping Republican Ideas Strong Timely & Inventive — aka KRISTI — was formed for Noem in 2011, the first year that she served in the U.S. House of Representatives. It has received $165,053.22 from Noem Victory Fund.

The South Dakota Republican Party has also benefited from Noem Victory Fund transfers totaling $39,700.61.

A spokesman for the Washington, D.C. based watchdog group Campaign Legal Center said the joint fundraising that Noem has been doing appears to be rare.

“While we can’t offer a strong opinion on how common this practice is, we didn’t find any other joint fundraising committees like it that are currently active,” said Brendan Quinn, senior communications manager on campaign finance and ethics. “Florida Governor Ron DeSantis had a similar JFC when he was in the (U.S.) House but he terminated it after he became governor. So, it appears this move by Governor Noem is unusual.

“That said, it is legal for a federal joint fundraising committee to raise funds distributed to nonfederal committees, provided the funds raised are not spent on ‘federal election activity,’ which includes any public communications that refer to a federal candidate unless they are subject to the Federal Election Campaign Act’s amount limits, source prohibitions, and reporting requirements,” he explained.

Noem used a similar joint-fundraising approach for the 2018 election. The Noem-Rhoden Victory Committee raised $704,955.00, spent $145,921.18, refunded $12,500 and transferred $546,533.82 to other committees.

Among those transfers were $253,018.13 to Kristi For Governor; $137,587.99 to Rhoden For Lieutenant Governor; and $92,427.11 to the KRISTI committee.

The next campaign finance reporting deadlines are October 15 at the federal level for transactions through September 30; and October 24 at the state level for transactions through October 19.