On Sept. 30, Save America, President Trump's leadership PAC, had $32,256 in cash and $1.9 million in unpaid bills. It got there by doing what it has done for most of its existence: paying lawyers.
Since January 2025, Save America has spent $31.0 million. About $20.4 million of that, or two-thirds, went to items its own filings describe as legal, according to our review of its FEC reports. In the most recent quarter, July through September 2026, the legal share reached 94%.
Watchdogs have criticized this arrangement for years. Donors give to a political committee, often through small-dollar online appeals, and the committee then pays legal bills for the politician it is named for. This post covers how Save America became Trump's main source of money for lawyers, why the arrangement has held up legally, and what the PAC's latest reports show.
What a leadership PAC is
A leadership PAC is a committee a politician sets up apart from their campaign. It is often used to donate to other candidates and to build influence within a party. Unlike a super PAC, a leadership PAC is subject to contribution limits: individuals can give up to $5,000 a year. (Our explainer covers how super PACs differ.)
The key legal difference concerns personal use. Federal law bars campaign committees from spending donor money on a candidate's personal expenses, meaning costs that would exist "irrespective" of the campaign or the office. Legal fees for defending against an investigation of official conduct, or for election litigation, generally qualify as permissible campaign spending. Fees for private lawsuits generally do not.
That rule clearly applies to campaign committees. Its application to leadership PACs is less clear. A campaign finance scholar writing in The Conversation explained that the FEC treats a leadership PAC as a separate "third party," and a third party may pay a candidate's personal expenses. The Brennan Center has noted that FEC deadlocks over the question have left leadership PACs in a "gray area."
How it got here: 2021–2024
Trump formed Save America after the 2020 election, and it raised more than $100 million in its first year and a half. Its spending on lawyers grew as the investigations into Trump grew:
| Period | Save America legal spending | Source |
|---|---|---|
| 2021–2022 | About $16M | CBS News |
| First half of 2023 | About $21.6M of $25M total spending | CBS News |
| All of 2023 | More than $50M | The Conversation, citing OpenSecrets |
| Through early 2024 | Roughly $70M (more than $100M across all Trump committees) | Brennan Center |
The money covered the 2023 indictments in New York, Washington, Florida and Georgia, the New York civil fraud case and the E. Jean Carroll lawsuits. The PAC also paid legal bills for aides and associates caught up in the investigations.
To keep the money flowing, Save America turned to MAGA Inc. During the 2022 midterms, Save America had given $60 million to the pro-Trump super PAC. In July 2023, as legal bills piled up, it asked for that money back (CNN via ABC17). MAGA Inc. returned $12.25 million in the first half of 2023 alone, and the rest followed in monthly payments. The Brennan Center called the arrangement unusual and said it "tests the limits of the law." A super PAC normally cannot give more than $5,000 to a leadership PAC. Calling the payments a refund of an earlier donation avoided that limit.
The Trump campaign also raised the share of joint-fundraising money sent to Save America, from 1% to 10%, according to the New York Times, as reported by CBS News.
What watchdogs flagged
Critics have raised three main concerns:
- Donor intent. Many donors to Save America responded to appeals about elections and "election integrity," not about legal defense. Critics argue few of them understood their donations would pay Trump's personal lawyers.
- The MAGA Inc. refund. The refund moved unlimited super PAC money, which had been raised on the promise of independent political spending, into a committee paying a candidate's legal bills.
- Disclosure. The Campaign Legal Center filed an FEC complaint alleging that an outside firm fronted millions in Trump legal costs that his committees later reimbursed. If true, that could be an illegal corporate contribution. The FEC has not acted on the complaint (Brennan Center).
These are criticisms and allegations, not findings. The FEC has not found that Save America's legal spending broke the law. As The Conversation's analysis notes, much of it may be allowed under the third-party rule. Trump's team has generally described the cases as politically motivated, which, if accepted, would also make the legal fees political expenses.
The PAC since 2025
Trump returned to the White House in January 2025, but Save America kept paying for lawyers. Here is what its FEC reports show:
| Period | Total spending | Described as legal | Share | Cash at end | Debts at end |
|---|---|---|---|---|---|
| Jan.–June 2025 | $7.48M | $4.00M | 53% | $2.71M | $1.17M |
| July–Dec. 2025 | $9.53M | $5.93M | 62% | $1.19M | $0.98M |
| Jan.–Mar. 2026 | $4.06M | $2.30M | 57% | $1.16M | $1.65M |
| Apr.–June 2026 | $4.50M | $3.00M | 67% | $0.67M | $3.70M |
| July–Sept. 2026 | $5.46M | $5.16M | 94% | $0.03M | $1.91M |
| Total | $31.03M | $20.39M | 66% |
Source: Save America's FEC reports. "Described as legal" totals the itemized disbursements whose stated purpose includes the word "legal" (for example "legal consulting" or "reimbursement for legal fees"). FEC filings do not say which case or which person each payment covered.
In the third quarter of 2026, the largest legal payees were Sullivan & Cromwell ($1.49 million), DLA Piper ($667,000), Red Curve Solutions ($566,000, listed as reimbursement for legal fees) and Brito PLLC ($417,000).
Where the money comes from. Very little now comes from donors directly. In 2026, Save America received $5,046 in direct contributions and $12.9 million in transfers from affiliated committees. In the third quarter, the transfers came from Never Surrender, Inc., which FEC records show is Trump's former 2024 campaign committee, since converted into a leadership PAC. In effect, money raised for Trump's last presidential campaign is now paying his lawyers through a second PAC.
How it connects to MAGA Inc.
The 2023 refund showed that money raised under one label can end up paying for something quite different. The same question is now being raised about MAGA Inc. Trump has publicly said he "control[s]" the super PAC and "could spend it on pretty much anything I want." Watchdog groups have filed FEC complaints arguing that such control is itself illegal (see 'I Control It': The Complaint Over Trump's Super PAC). MAGA Inc. calls those complaints frivolous. MAGA Inc. reported $164 million on hand as of Oct. 14, while Save America is nearly out of cash. Watch where money moves between the two after Election Day.
What to watch
- Save America's year-end report, due Jan. 31, 2027. It will show whether the PAC paid down its $1.9 million in debts and how much it kept spending on lawyers.
- Transfers from Never Surrender. Save America now depends on them to cover its bills.
- Any money from MAGA Inc. Transfers between the two, or a repeat of the 2023 refund maneuver, would be the most direct sign that super PAC money is reaching Trump's legal bills.
- The FEC. Without a quorum since May 2025, the commission cannot act on pending complaints, including those about Trump's committees.
The term "leadership PAC" and other campaign finance terms are defined in our glossary.
Sources
- Save America FEC filings (committee C00762591), including the Oct. 2026 quarterly report
- FEC: Never Surrender, Inc. (C00828541)
- Brennan Center: Trump's Use of Campaign Funds to Pay Legal Bills (May 2024)
- The Conversation: Yes, Trump's PACs really can pay his legal fees
- CBS News: What Save America has spent on Trump's legal bills (Aug. 2023)
- CNN via ABC17: Save America requests $60 million refund (July 2023)
- Forbes: Save America has paid nearly $50 million to Trump's lawyers since first indictment (March 2024)