Trump is fundraising off Georgia runoffs, but his PAC is spending none of it on the candidates

Over the past few weeks, President Donald Trump has been imploring his supporters to donate to the "Georgia Election Fund" to support Republicans in the two upcoming Georgia Senate runoffs. The plea has been part of Trump's massive post-election fundraising effort, much of which has been going to Trump's new political action committee, Save America.

But none of the funds the president has brought into his new PAC appear to have gone to actually help the Republican Senate runoff campaigns, ad placement data and campaign disclosure records show.

"The Georgia Runoff Election is right around the corner and the fate of the Nation hangs in the balance," Trump's team wrote in a fundraising email sent to supporters this week. "So much is at stake and I need to know that you are on our team and ready to FIGHT for America."

"It is CRITICALLY important we have your support to secure the resources we need to deliver the Democrats a CRUSHING defeat," they wrote in another recent email.

In the fine print, the letter breaks down the distribution of funds as follows: 25% of each contribution goes to the RNC, and 75% of each contribution first goes to Save America, up to $5,000, with the rest of the 75% going to the Trump campaign, up to $2,800 for an individual donor and $5,000 for a PAC donor.

The RNC so far has spent roughly $3 million in independent expenditures supporting the Georgia GOP candidates, and has committed to spend more than $20 million in the runoffs overall.

"We currently have the largest team ever in Georgia, which includes 500 paid staffers and thousands of volunteers," RNC spokesperson Mike Reed told ABC News. "Our teams have knocked on millions of doors over the past few weeks."

Reed added that the RNC's focus is on the ground game and get out the vote efforts as they typically leave the ad buys and other electioneering activities to the campaigns and outside groups.

Indeed, since Election Day in November, hundreds of outside groups on both sides of the aisle have spent, or committed to spend, in support of the Georgia candidates. The television and radio ad spending alone is quickly approaching the $500 million mark, powered by the funds raised by the campaigns and political interest groups.

But Trump's new leadership PAC is not one of them. The PAC has not placed any television or radio buys in the race, according to media research company CMAG's analysis of ad-buy records, and it has not reported making any independent expenditures in support of Republican Sens. David Perdue or Kelly Loeffler, as required by the Federal Election Commission rules.

The full extent of the committee's fundraising and spending has yet to be disclosed, so it's unclear if any of the funds have been used to support Trump's recent political travels to Georgia or if the PAC has made any direct contribution to the campaigns. But even if it has, the maximum contribution a PAC can make is $5,000 -- which would appear to be a small fraction of the money coming in.

Officials with Save America did not respond to ABC News' request for comment.

A super PAC set up by Donald Trump Jr.'s advisers, which doesn't raise money with the Trump committees, did report spending more than $1 million on the races.

Michael Beckel, research director at the campaign transparency advocacy group Issue One, told ABC News that while it's common for candidates in a contentious race to try to leverage the celebrity appeal of higher-profile politicians, it is highly unusual for a sitting president to be using a contentious election as a hook to raise money for their own political operation.

"It is extremely uncommon for an outgoing president to be so aggressively soliciting contributions for a leadership PAC, let alone using high-profile races as a hook to entice donors to give without investing much of the money raised into said races," Beckel told ABC News. "President Trump's Save America PAC has, to date, raised an extraordinary amount of money, and President Trump faces few restrictions on how to spend the money he raises for his leadership PAC."

Some Republicans who are actively raising money to support the GOP candidates say Trump's leadership PAC is problematic.

"I think it's problematic if they're raising money and the implication is you are going to help Kelly Loeffler and David Perdue win, because really that is the most important thing right now," Martha Zoller, a former Georgia congressional candidate who now runs Georgia United Victory, a super PAC spending millions in support of the Republicans in the runoffs.

"The president is going to do what the president is going to do, but my goal is to win these races," Zoller said. "And if he's raising money based on that, then he should be spending the money to help get the vote out."

"2022 doesn't matter, 2024 doesn't matter," Zoller added, referring to the possibility of Trump seeking reelection in 2024. "If we don't win on Jan. 5, Republicans are going to have a very different landscape for the next two and four years. I think it's time for the president to think about the country as a whole and not just the folks that voted for him."

"Everyone in our ecosystem could be operating in the best way they see fit,” said one GOP strategist, who spoke to ABC News on the condition of anonymity. The strategist added, "it’s imperative that everyone on the Republican side work together to effectively pull resources and make sure that any dollar that can be spent in Georgia is deployed for Jan. 5."

While Save America has not yet spent any money on the runoffs, the new super PAC launched by Donald Trump Jr.'s advisers, called Save the US Senate PAC, has reported spending more than $1.2 million on the contests, with more than half a million dollars of that going to television ads and the rest to digital ads and other efforts, ad placement data and FEC disclosure reports show.

But that's a small fraction of what some of the bigger and more committed groups are spending. The Karl Rove-led super PAC American Crossroads has aired and booked nearly $48 million on ads in Georgia, while the super PAC Senate Leadership Fund and its local affiliate, Peachtree PAC, have together spent $87 million on ads so far, ad buy records show.

Overall, GOP outside groups have been vastly outspending Democratic groups on ads, with Republicans scheduled to spend $162 million on television and radio ads through the first week of January, with Democratic groups only spending $46 million.

"This is an absolutely all hands on deck effort," Senate Leadership Fund spokesperson Jack Pandol told ABC News. "We're taking a leadership role with the amount of money that we're spending, but we welcome all the help we can get. This is an extremely important election that's going to decide a lot about our country's future."