Who Is Already Testing the Waters for 2024?

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A $100 bill with a wave of water flowing over the top

Although the 2022 midterm elections are still weeks away, many prospective candidates have already begun planning and laying the groundwork to campaign for office in the 2024 presidential election. Even though no one has formally declared their candidacy, the informal preparatory phase is already well underway.  

While potential Democratic presidential contenders wait to see whether President Biden will seek reelection, several Republican party hopefuls have already begun the fundraising and campaigning process — even as former President Trump has all but acknowledged his own candidacy to return to the White House. 

The field of potential 2024 presidential hopefuls includes former Secretary of State Mike Pompeo, South Carolina Sen. Tim Scott, Florida Gov. Ron DeSantis and former Ambassador to the United Nations Nikki Haley, each of whom appear to be “testing-the-waters” of candidacy — if not already campaigning for office.  

As we explored in the previous chapters of this series, if any of these individuals have decided to run but are delaying a formal declaration of candidacy to evade campaign finance rules for candidates — including federal reporting requirements and regulations prohibiting coordination with allied super PACs — they would be violating the law. 

This would deprive voters of crucial information about money raised and spent to win the White House. 

Let’s take a closer look at some of the tactics we’re seeing. 

Mike Pompeo spurred speculation regarding his presidential ambitions when he launched Champion American Values PAC (CAVPAC) in June 2021.  

CAVPAC is a hybrid PAC, which means that it can fundraise directly for candidates (with individual contributions subject to federal limits), but has a separate account that, like a super PAC, can raise and spend unlimited sums, including money from corporate funds.  

As of July 31, 2022, CAVPAC has raised roughly $6.1 million and spent approximately $4.8 million, the majority of which (63%) has been spent on fundraising, consulting and advertising. Earlier in 2022, the committee ran a digital ad touting religious freedom in two states that hold early and influential presidential nominating contests – Iowa and South Carolina.  

Pompeo has also traveled to Iowa at least three times since the end of his service in the Trump administration, speaking at public events and networking with state party officials there – all strong indications of his intent to stake out ground in the Iowa caucuses.  

Like Pompeo, Haley has been spending a lot of time in the Hawkeye state at prominent party fundraisers and other events. 

Speaking at an event in July, Haley hinted at her intention to run: “And if this president signs any sort of [Iran nuclear deal], I’ll make you a promise. The next president will shred it on her first day in office … Just saying, sometimes it takes a woman.” 

Haley again fueled speculation of her plans to mount a campaign for president in an August interview on Fox News: “. . . if there's a place for me, I've never lost a race.” 

In Scott’s recently-published memoir, America: A Redemption Story, includes a prefatory passage describing the book as “a political memoir that includes [Scott’s] core messages as he prepares to make a presidential bid in 2022.” (Scott has denied approving that language, and his publisher issued a statement accepting responsibility.)

This inadvertent campaign announcement aside, Scott has already drawn the support of Republican megadonors, including tech billionaire Larry Ellison and Silicon Valley businessman William Oberndorf. Sen. Scott has also spent time in Iowa headlining events for the Iowa Republican party, potentially a sign of efforts to curry favor in the early nominating contest. 

Gov. DeSantis, while purportedly preparing for his 2022 reelection bid, has raised over $170 million through a state PAC, “Friends of Ron DeSantis.” This is a record breaking sum for a gubernatorial race, which strongly suggests that DeSantis is, in fact, trying to build a war chest for the 2024 presidential election. 

Friends of Ron DeSantis has received contributions from key Republican donors around the country, including the hedge fund managers Ken Griffin and Paul Tudor Jones, as well as Bernie Marcus, William Buckley and Richard Uihlein.  

The governor has become a prominent national figure in recent years, particularly after his opposition to mask mandates during the height of the COVID-19 pandemic and his support of the controversial “Parental Rights in Education” law (also known as the “Don’t Say Gay” bill).

Most recently, DeSantis made national headlines for his decision to send 50 Venezuelan migrants to Martha’s Vineyard. 

Trump, of course, leads the pack in terms of both fundraising and public events, where he has frequently hinted at his plans to run for president again. Indeed, some have suggested that his actions demonstrate that he has already decided to run and is violating the law by not officially acknowledging his candidacy and complying with federal laws governing candidates.  

American Bridge, a super PAC, filed a complaint with the Federal Election Commission (FEC) in March 2022 accusing Trump of using campaign funds to advance a future reelection bid. Trump’s committees have amassed more than $115 million. 

It is too soon to be certain about who will ultimately run for president in 2024. However, as we can all see, several hopefuls have already begun preparing.  

The key thing to watch for is whether the potential contenders acknowledge their candidacy when they have decided to run, as the law requires. Those that don’t, in order to travel, speak, network, fundraise and campaign without abiding by campaign finance limits for candidates and transparently reporting the financing of their activities, are breaking the law. 

Following the path laid out by candidates in past election cycles, like Jeb Bush and Scott Walker, those that defer declarations of their candidacy to evade campaign finance laws are breaking the law and rigging the system in their favor, hurting voters and the democratic process. 

Testing the Waters Blog Series

Part 1 - Testing the Waters, Explained

Part 2 - How Have Candidates Taken Advantage of the Testing the Waters Rules?

Part 3 - How Candidates Use Election Spending Vehicles to Test the Waters

Part 4 - Who Is Already Testing the Waters for 2024? (You are here.)

Sophia is a Researcher/Investigator on CLC's Campaign Finance/Ethics team.
What Is Testing the Waters?