Four years after Supreme Court ruling, more candidates repay campaign loans with post-election cash

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Four years after Supreme Court ruling, more candidates repay campaign loans with post-election cash

When Bernie Moreno ran for Senate in 2024, he loaned his campaign $4.5 million. Just over a year after taking office, the Ohio Republican’s campaign paid him back $1.25 million using money it received well after the election — a transaction that only a few years earlier would have been prohibited.

In the four years since the Supreme Court struck down the cap on loan repayments and the 20-day post-election window tied to it, federal candidates have increasingly used money raised after Election Day to reimburse themselves long after voters cast their ballots.

Before the court’s 2022 ruling in Federal Election Commission v. Ted Cruz for Senate, candidates could repay no more than $250,000 in personal loans with post-election contributions, and only within 20 days of the election. The court’s conservative majority eliminated those restrictions, a shift experts say has encouraged larger and more frequent self‑loans. In this article, OpenSecrets examines the impact to date of this change.

“It hasn’t been a case without consequence,” John Martin, an election law scholar and assistant professor of law at Quinnipiac University who studies candidate self-loans, told OpenSecrets.

While federal contribution limits strictly cap how much outside individuals can give to a campaign, there is no federal limit on how much of their own personal wealth candidates can pour into their own runs for office.

So far, candidates seeking House and Senate seats in the 2026 midterm elections have poured at least $203 million of their own money into their campaigns, according to an OpenSecrets analysis of FEC campaign finance reports through the first quarter of the year. Personal loans account for at least $182 million — nearly 90%, a level experts say would have been far less likely when repayment was capped and time‑limited. Seven such loans were worth at least $5 million apiece, FEC records show.

Martin said his analysis found the average self-loaning candidate loaned the campaign nearly 40% more money during the 2024 election cycle than in 2020, before the Cruz decision. The inflation-adjusted 2020 average of nearly $354,000 climbed to nearly $495,000, he said. Similarly, median self-loans grew from an inflation-adjusted $22,000 in 2020 to about $25,000 four years later.

The practice is likely to become even more widespread, said Dan Backer, the lead attorney for the plaintiff in a separate Supreme Court campaign finance case. In the 2014 case McCutcheon v. FEC, the court struck down federal aggregate limits on individual contributions per election cycle, allowing donors to give to an unlimited number of candidates, party committees and political action committees as long as they adhere to base per-candidate limits.

“Loaning yourself money doesn’t annoy donors and voters, and no one has experienced political pain from repaying them, either,” Backer told OpenSecrets in an email. “It’s legal, donors and voters don’t care, and it’ll keep happening.”

Proponents of self-funding argue it makes candidates less beholden to donors. Critics say the opposite, noting that donations made after an election may wind up in the candidate’s own bank account.

“What many candidates decide to do is actually loan that money to their campaign committee, and then that opens up the opportunity to use third-party donations to pay that money back,” Martin said. “So, donors have remained a part of even self-funded candidates’ campaigns — an integral part, especially if those candidates are self-loaning.”

That dynamic creates ethical concerns, said Ciara Torres-Spelliscy, a Stetson University law professor who studies election law.

“This type of financial rescue is likely to curry favor with the impacted elected official,” Torres-Spelliscy told OpenSecrets in an email. “And unlike most campaign money, this repays personal loans that the candidate lent their campaign, so the money goes back into the official’s pockets.”

To illustrate that point, Martin described a hypothetical example of a donor contributing $2,000 to a self-loaning candidate’s campaign.

“That candidate can take that $2,000, and they’re not going to put it towards traditional campaign expenses, like funding their staff or paying for advertising,” he said. “Instead, they could take that $2,000 and directly funnel it back into their bank account, potentially with an interest rate attached to it. So they could actually make money off of their self-loaning.

“So the relationship that forms between the donor and a self-loaning candidate has the potential to actually create a heightened risk of corruption because that money, I could just take it and funnel it into my personal bank account,” he added.

While most candidates don’t charge their campaigns interest on those loans, Backer cautioned that could change, “and that might be something donors/voters dislike as much as candidate salaries.”

The Cruz case centered on a provision of the Bipartisan Campaign Reform Act of 2002 requiring that any amount above $250,000 not repaid within 20 days be treated as a contribution. A day before the 2018 general election, Cruz loaned $260,000 to his Senate campaign, Ted Cruz for Senate. The campaign repaid him $250,000 after the 20-day window closed, leaving $10,000 that converted into a contribution. The committee sued the FEC, arguing the limit deterred candidates from loaning money to their campaigns and violated the First Amendment. In a 6-3 ruling in May 2022, the Supreme Court agreed.

The essence of the ruling, Martin said, is that “if you limit the amount of money that they could use to pay back their self loans, then suddenly, they might not loan themselves as much money as they’d like to, and therefore they won’t be able to engage in as much advocacy as they might like.”

The repayment road map

In the immediate aftermath of the ruling, OpenSecrets found that some candidates reinstated previously converted loans so they could use post-election contributions to repay them. Martin referred to an analysis that found that in 2020, roughly 12.6% of self-loaning candidates loaned their campaigns above the $250,000 limit. In 2024, that rate climbed to 18.6%.

Now, four years after the court’s ruling, Moreno provides a clear example of how the post-Cruz landscape works.

Moreno loaned his 2024 Senate campaign $4.5 million in four installments, starting with an interest-free $3 million on Sept. 30, 2023. That was followed by three six-figure checks in early 2024 totaling $1.5 million — loans backed by personal bank loans at a 7% interest rate that would be due in early 2025. While FEC records list the source of the funds as his terminated 2022 committee, Bernie Moreno for Ohio, the agency officially classifies the transactions as personal candidate loans. Moreno previously loaned that earlier committee $3.8 million, starting with $3 million on Sept. 30, 2021, before dropping out of the race.

In March 2024, Moreno won the Republican primary and then unseated Democratic incumbent Sherrod Brown in November. On Jan. 20, 2026 — a year and 17 days after he was sworn in — the Bernie Moreno for Senate campaign repaid Moreno $1.25 million for those primary loans.

That repayment money could not have come entirely from the campaign’s leftover election funds because it ended 2024 with just under $380,000 in cash on hand — far short of the amount it ultimately repaid. Since the start of 2025, however, FEC records show nearly $2.3 million has flowed into the campaign’s account. OpenSecrets data align with that figure, showing net receipts of roughly $1 million that reflect the loan repayment and other offsets.

Since January 2025, the campaign’s largest 23 receipts were transfers of amounts ranging from $15,000 to nearly $184,000 from Team Moreno, his joint fundraising committee. Between May 7 and Dec. 31 of that year, the campaign received 33 transfers totaling more than $1.3 million from that committee. The campaign’s FEC records show 18 of those transfers, which total more than $960,000, include memo lines referencing “debt retirement” — either for the 2024 campaign or for his 2022 Senate bid.

A bipartisan trend

Moreno is far from alone. The Cruz ruling has reshaped candidate behavior across the country.

Rep. Brandon Gill (R-Texas) loaned his House campaign $505,000 interest-free between December 2023 and February 2024. The campaign ended 2024 with less than $128,000 in cash on hand. After the election cycle reset, the campaign took in nearly $3.1 million and repaid him the full amount for those primary loans across three payments between July and October 2025.

Before he stepped down in March to serve as Trump’s secretary of homeland security, former Sen. Markwayne Mullin (R-Okla.) won a special election in 2022 to succeed Sen. James Inhofe (R) after his mid-term retirement. Mullin loaned his campaign an interest-free $1 million on March 29, 2022. He won the special election that November, and the campaign ended the year with $55,000 in cash on hand.

The following spring, he began repaying himself. FEC records show the Mullin For America campaign — which reported nearly $1.7 million in receipts during the 2024 cycle and another $3.2 million through the first quarter of 2026 — reimbursed him the full $1 million for those 2022 primary loans in six payments between April 2023 and Dec. 31, 2025. Of that total, $595,149.21 was repaid during the 2024 cycle with the remaining $404,850.79 coming during the 2026 cycle.

Democrats have used the mechanism as well. Former Rep. Wiley Nickel (D-N.C.) loaned his House campaign $1 million in four interest-free installments between June 2021 and October 2022, then won the election that November. After ending 2022 with $37,000 in cash on hand, the campaign took in $2.4 million during the 2024 cycle while repaying Nickel $790,000 for those primary and general loans across seven payments in 2023.

After his district was redrawn, he did not seek re-election. Instead, he launched a brief Senate campaign and loaned that committee another $765,000, also without interest, during the 2024 cycle. His Senate campaign reported about $690,000 in cash on hand at the end of that year and brought in nearly $590,000 more during the 2026 cycle. Nickel dropped out of the Senate race in July 2025 and pursued local office. Weeks later, the campaign made the first of seven reimbursement payments for those 2022 and 2026 primary loans, totaling $539,000.

OpenSecrets reached out to the candidates, either directly or through their campaigns or offices, for comment but did not immediately receive any responses.

This story was produced by OpenSecrets and reviewed and distributed by Stacker.