What explanation is needed?
Super PACs are legally allowed to give money to other super PACs - they are only prohibited from donating directly to any political campaign.
There’s no “there” there.
The FEC required an explanation.
This letter is prompted by the Commission's preliminary review of the report referenced above. This notice requests information essential to full public disclosure of your federal election campaign finances. Failure to adequately respond by the response date noted above could result in an audit or enforcement action. Additional information is needed for the following 1 item(s): - Itemized disbursements must include a brief statement or description of why each disbursement was made. Please amend Schedule B supporting Line 21(b) of your report to clarify the following description(s): "OTHER DISBURSEMENT." For further guidance regarding acceptable purposes of disbursement, please refer to 11 CFR 104.3(b)(3)(i).