A super PAC named Our Heritage Matters registered with the U.S. Federal Election Commission (FEC) on October 15.
Five days later, it began spending money to support third-party candidates and attack Republicans. According to CNBC’s analysis of FEC filings, as of October 29, the organization had spent approximately $1.2 million in 10 House and Senate races.
What voters still cannot see is who provided this money.
Since Our Heritage Matters was established after the key campaign finance filing deadline of October 15, its first regular disclosure of donors is not due until December 3—one month after Election Day.
This organization is merely an extreme example of a broader trend: an increasing number of super PACs, including the newest phenomenon of “flash PACs,” are pouring money into campaigns before voters even know where the funding is coming from.
Federal law requires super PACs and political committees to report large independent expenditures within 24 or 48 hours as the election approaches, disclosing how much they spent and which candidates they supported or opposed. However, donor information is disclosed less frequently through periodic campaign finance reports.
In 2026, there was a surge in newly created and temporary PACs. Both parties have adopted this strategy, with PACs affiliated with the Republican Party spending approximately twice as much as those affiliated with the Democratic Party.
According to CNBC’s analysis, the 22 super PACs registered with the FEC in the final 10 weeks before Election Day have each spent at least $1 million in congressional races. By October 29, these organizations collectively disclosed approximately $6.37 billion in independent expenditures, accounting for about one-sixth of all independent spending in this election cycle’s House and Senate races.
The number of super PACs with million-dollar funding levels that were established shortly before elections has more than quadrupled since 2022, while their spending has nearly tripled 35-fold.
At the same time as the 2022 midterm elections, only five similar organizations collectively spent approximately $18 million. In 2018, there were three, collectively spending about $12 million. This total even exceeds spending in the two previous presidential elections: according to CNBC’s analysis, similar recently formed Super PACs spent less than $50 million combined in congressional races in both 2020 and 2024.
“The primary reason for doing this is almost entirely to avoid disclosure, even if only temporarily,” says Professor Michael Kang of Northwestern University Pritzker School of Law, who studies campaign finance. “In many cases, if the identity of donors is made public, it undermines the causes they support.”
CNBC’s analysis included super PACs formed in the final 10 weeks before Election Day that spent at least $1 million in House or Senate races by October 29. Spending data includes regular FEC filings as well as 24-hour and 48-hour reports, with duplicates removed.
From zero to millions of dollars: The spending rate of a late-established PAC
A notable feature of a late-formed Super PAC is its speed.
Of the 22 organizations analyzed by CNBC, 18 began spending within 30 days of formation, and nearly all began spending before filing their first regular campaign finance report disclosing sources of funds.
Saurav Ghosh, Director of Federal Campaign Finance Reform at the Campaign Legal Center, said: “This is happening more and more often, and they’re spending more money because it works, and they can get away with it.” The organization is a nonpartisan nonprofit founded by a former Republican FEC chair.
Despite being established late, these organizations accounted for more than 22% of independent spending in congressional races during CNBC’s reporting period, compared to less than 2% at the same point in the two previous midterm elections.
Many of these organizations are newly formed in name only. CNBC found that nine of the 22 organizations have financial or organizational ties to existing political networks.
For example, Lower Costs Now was established on September 10 and disclosed an affiliation with Future Forward PAC, an organization that provided major external support during former Vice President Kamala Harris’s 2024 presidential campaign. Nineteen days later, Lower Costs Now began spending in Senate races.
However, voters did not see a more complete picture of its funding until October 15, when its first regular financial report revealed that the Senate Majority PAC, the leading super PAC supporting Democratic Senate candidates, contributed $23 million to the organization, according to FEC filings.
As of Thursday, Lower Costs Now has disclosed approximately $75.5 million in independent expenditures across eight Senate races, including in Iowa, Texas, Kansas, and Ohio, according to CNBC’s analysis.
Republicans have also used the same approach.
No Going Back PAC was established on September 1 and began spending three days later. Public reports quickly linked it to MAGA Inc., the flagship Super PAC of U.S. President Donald Trump. However, its official financial filings did not arrive until October 20—more than six weeks after spending began.
By then, No Going Back had spent approximately $187.8 million, FEC filings show, revealing that MAGA Inc. had provided $200 million to the organization. By Thursday, the super PAC had spent approximately $242.2 million, according to FEC filings.
“They are tools designed to appear out of nowhere and pour large sums of money into elections before voters have a chance to know who is funding them or what their motivations might be,” Ghosh said.
PAC established for a single campaign
Many new organizations also have very focused goals.
Of the 22 million-dollar super PACs identified by CNBC, 14 spent all their funds on a single congressional race.
Take The Maine Standard as an example. It was established on September 11 and began spending five days later. Since then, it has spent $8.2 million, all directed against Democratic candidate Troy Jackson in the Maine Senate race, according to FEC filings.
The Cornhusker Majority’s pattern is nearly identical. It was formed on September 10, began spending on September 16, and has spent approximately $7.1 million in the Nebraska Senate race, almost entirely opposing independent candidate Dan Osborn, according to FEC filings. Osborn is competing against Republican incumbent Senator Pete Ricketts in a tightly contested race.
The connection between these two organizations did not appear until October 15 in their regular financial reports: both were funded by the Republican Senate super PAC, Senate Leadership Fund.
On the Democratic side, Texas Forever launched on September 24 and began spending five days later, according to FEC filings. As of Thursday, it had spent approximately $27.5 million to support Democratic Texas Senate nominee James Talar, the FEC shows. Unlike some other rapid-response groups, it identified Senate Majority PAC as its affiliated organization in its initial filings with the FEC.
Hilary Braseth, Executive Director of OpenSecrets, said: “A PAC with a local brand doesn’t necessarily hide the source of funds, but it fragments the overall picture. Voters see not a single national organization spending tens of millions of dollars across the country, but a series of different organizations operating on a race-by-race basis.” OpenSecrets is a nonpartisan nonprofit organization that tracks such spending.
Even if the national organization behind the flash PAC is identified, there may still be another layer hidden within the funding chain.
The Texas PAC was established on August 28 and quickly began spending to support Republican Ken Paxton’s campaign for the Texas Senate. Funds flowed through the Senate Leadership Fund, but Elon Musk’s involvement was not disclosed until October 12—more than a month after spending began.
On October 15, FEC filings showed that Musk donated $158 million to the Senate Leadership Fund through two contributions, and the organization transferred the same amount to the Texas PAC the following day.
As of October 29, Texas PAC has spent approximately $181.6 million in this campaign, according to FEC filings, making it one of the largest late-formed Super PACs identified by CNBC.
Texas PAC and No Going Back together account for approximately two-thirds of the total spending by these 22 million-dollar organizations. But this wave extends far beyond just these two giants: even excluding them, the remaining organizations’ spending is nearly 12 times that of comparable, later-established Super PACs at the same point in 2022.
"This year's growth has been enormous," Kang said. "Maybe you don't want to be known during this election, or you want to lie low for a while—like how AI isn't very popular right now—but you still want to build some reputation among participants in this system."