Our Heritage Matters registered with the Federal Election Commission on Oct. 15. Within two weeks it had spent about $1.2 million in 10 House and Senate races, according to a CNBC analysis of FEC filings. Voters won't learn who paid for that spending until Dec. 3, a month after the election.
Our Heritage Matters is one of many super PACs formed late in this election season, spending heavily before anyone has to disclose where the money came from. CNBC counted 22 super PACs that formed in the final 10 weeks before Election Day and have each spent at least $1 million on congressional races. As of Oct. 29, they had spent about $637 million combined, roughly one-sixth of all independent spending in House and Senate races this cycle.
Both parties are doing this. Here's how it works, who is behind the biggest groups, and what will come out on Dec. 3.
How a pop-up PAC works
Super PACs report their spending and their donors on different schedules:
- Spending is reported almost immediately. Close to an election, any independent expenditure above certain thresholds must be reported within 24 or 48 hours. The report shows how much was spent and which candidate it supported or opposed.
- Donors are reported on a fixed calendar. Contributors appear only in periodic reports. The last report before the election was the pre-general, which covered activity only through Oct. 14. The next report is the post-general, due Dec. 3.
A super PAC formed in September can therefore spend for weeks before its first donor report. A super PAC formed after mid-October may not have to name any donors until after the votes are counted.
"The reason for this is almost entirely to avoid disclosure, even if just temporarily," Northwestern law professor Michael Kang told CNBC.
How fast it has grown
CNBC compared late-forming super PACs that spent at least $1 million on congressional races at the same point in each election:
| Election | Late-forming groups | Combined spending |
|---|---|---|
| 2018 | 3 | About $12M |
| 2022 | 5 | About $18M |
| 2026 | 22 | About $637M |
Source: CNBC. Groups formed in the final 10 weeks that spent at least $1 million on House or Senate races by the comparable date.
According to CNBC, these groups account for more than 22% of independent spending in congressional races during its comparison window, up from under 2% at the same point in the past two midterms. Eighteen of the 22 started spending within 30 days of forming. Fourteen spent all their money in a single race. CNBC found that Republican-linked groups have spent about twice as much as Democratic-linked ones.
New names, familiar backers
Many of these groups are new only on paper. CNBC found ties between nine of the 22 and established party-aligned networks. In several cases, the connection became public only weeks after the spending began.
| Pop-up PAC | Formed | Spending reported | Backer, per FEC filings | Side |
|---|---|---|---|---|
| No Going Back PAC | Sept. 1 | About $242M | MAGA Inc. ($200M) | Republican |
| Texas PAC | Aug. 28 | About $182M (Texas Senate) | Senate Leadership Fund, matching $158M from Elon Musk | Republican |
| Lower Costs Now | Sept. 10 | About $76M (8 Senate races) | Senate Majority PAC ($23M); affiliated with Future Forward | Democratic |
| Texas Forever | Sept. 24 | About $28M (Texas Senate) | Senate Majority PAC (disclosed as affiliate at filing) | Democratic |
| The Maine Standard | Sept. 11 | $8.2M (vs. Troy Jackson, Maine Senate) | Senate Leadership Fund | Republican |
| The Cornhusker Majority | Sept. 10 | About $7.1M (mostly vs. Dan Osborn, Nebraska Senate) | Senate Leadership Fund | Republican |
| Our Heritage Matters | Oct. 15 | About $1.2M (10 races) | Not disclosed until Dec. 3 | Unknown |
Spending as of Oct. 29, per CNBC.
According to CNBC, No Going Back and Texas PAC together account for about two-thirds of all the pop-up spending. But the trend doesn't depend on those two. Excluding them, the other late-forming groups still spent nearly 12 times what comparable groups had spent at this point in 2022.
We've covered No Going Back before. Its first report, filed Oct. 20, came more than six weeks after it began spending and showed that MAGA Inc. had supplied $200 million. See MAGA Inc.'s October Blitz.
The Texas PAC case shows that naming the backer may not tell voters who the real donor is. Its money came through Senate Leadership Fund. Elon Musk's role didn't become public until Oct. 12. Filings on Oct. 15 showed he had given SLF $158 million in two contributions, and SLF had moved matching amounts to Texas PAC the day after each one.
Why it matters, and the other side of the argument
Campaign finance watchdogs say the tactic defeats the purpose of disclosure. "It's happening more often, and they're spending more money doing it because it works, and they're getting away with it," said Saurav Ghosh of the Campaign Legal Center. OpenSecrets executive director Hilary Braseth told CNBC that locally branded groups "fragment" the picture: voters see many small groups instead of one national organization spending across the country.
There is a defense. Nothing here appears to break current law. The reporting schedule is set by statute and FEC rules, and the groups that publicly listed an affiliate, such as Texas Forever and Lower Costs Now, disclosed more than the law requires. Strategists in both parties also argue that a local name and message are simply more effective in a given race. Kang suggested a further reason: some donors, for example in industries that are unpopular right now, may prefer to wait until after the election to be identified.
Changing this would take an act of Congress or new FEC rules. The FEC has not had a quorum since May 2025, so it cannot write rules or enforce existing ones (see 'I Control It').
What to watch
- 24- and 48-hour reports through Nov. 3. These show what pop-up PACs are spending, but not who is funding them.
- Dec. 3. Post-general reports cover Oct. 15 through Nov. 23. Groups like Our Heritage Matters will name their donors for the first time. We'll report what they show.
- Ties not yet disclosed. Watch for transfers from the major national super PACs, such as MAGA Inc., Senate Leadership Fund, Senate Majority PAC, Congressional Leadership Fund and House Majority PAC, showing up in pop-ups' reports.
Current balances for the major national groups are on our 2026 Super PAC Tracker. Terms like "independent expenditure" are defined in our glossary.