A super PAC called Our Heritage Matters was registered with the Federal Election Commission on October 15th.
Five days later, he fielded a third-party candidate and began spending to attack Republicans. The group has spent about $1.2 million in 10 House and Senate districts through Oct. 29, according to a CNBC analysis of FEC filings.
What voters still don’t know is who provided the funding.
Because Our Heritage Matters was formed after the key campaign finance reporting deadline of Oct. 15, the first periodic report identifying donors is due by Dec. 3, a month after Election Day.
This group is an extreme example of the broader insurrection that is reshaping the midterm elections. Late-starting super PACs, including recently formed “pop-up PACs,” are pouring money into campaigns before voters know where the money is coming from.
Federal law requires super PACs and political committees to report large independent expenditures within 24 or 48 hours, depending on how close the spending is to Election Day, indicating how much they spent and which candidates they supported or opposed. But their donors are less often revealed through regular campaign finance reports.
And in 2026, the practice of creating new PACs at the last minute exploded. Both parties have used this tactic, with Republican-affiliated PACs spending about twice as much as Democratic-affiliated PACs.
Each of the 22 super PACs registered with the FEC spent at least $1 million on congressional races in the last 10 weeks leading up to Election Day, according to a CNBC analysis. Through Oct. 29, the two parties have reported a combined total of about $637 million in independent spending, about one-sixth of all independent spending reported in House and Senate races this election cycle.
Since 2022, the number of million-dollar generic super PACs has more than quadrupled, and their spending has increased nearly 35 times.
According to a CNBC analysis, at the same point in the 2022 midterm elections, only five comparable groups had spent a combined total of about $18 million. In 2018, the three spent about $12 million. According to a CNBC analysis, this total exceeds even the past two presidential elections, when similar late-start super PACs spent less than $50 million on congressional races in both 2020 and 2024.
“The reason is almost entirely to avoid disclosure, even temporarily,” said Michael Kang, a professor at Northwestern Pritzker Law School who studies campaign finance. “In many cases, if the donor is known, it will hurt the cause.”
CNBC’s analysis includes super PACs that formed in the last 10 weeks before Election Day and spent at least $1 million in House or Senate races through Oct. 29. Expenditures include periodic FEC filings and 24- and 48-hour non-duplicate reports.
Late Formation PAC Expenditures from Zero to Millions
One of the characteristics of late super PACs is speed.
Of the 22 groups analyzed by CNBC, 18 began spending within 30 days of launch, and nearly all began spending before filing their first regular campaign finance reports showing where their money came from.
“These are happening more and more often, and they’re spending more money because it’s working, and they’re trying to get away with it,” said Saurav Ghosh, director of federal campaign finance reform at the Election Legal Center. The organization is a nonpartisan nonprofit organization founded by a former Republican FEC chairman.
Despite the late start, these groups accounted for more than 22% of independent spending in Congressional elections during CNBC’s 2026 period, up from less than 2% during the same period in each of the past two midterm elections.
There are also many new items that are only available on paper. CNBC found financial or organizational ties between nine of the 22 groups and established political networks.
For example, Low Cost Now was formed on September 10 and announced a partnership with Future Forward PAC, a major outside group supporting former Vice President Kamala Harris’ 2024 presidential campaign. Nineteen days later, Lower Costs Now began spending on Senate races.
But voters didn’t learn the full extent of that funding until Oct. 15, when its first regular financial report showed that Senate Majority PAC, the main super PAC working to elect Senate Democrats, had donated $23 million to the group, according to FEC filings.
By Thursday, Low Cost Now had reported about $75.5 million in independent spending in eight Senate races, including Iowa, Texas, Kansas and Ohio, according to a CNBC analysis.
Republicans have used the same strategy.
No Going Back PAC was formed on September 1st and became active three days later. Public press quickly linked it to MAGA Inc., President Donald Trump’s signature super PAC. But the official financial report didn’t arrive until Oct. 20, more than six weeks after the spending began.
By then, No Going Back had already spent about $187.8 million, according to FEC filings, which revealed that MAGA Inc. had supplied the group with $200 million. The super PAC had spent about $242.2 million through Thursday, according to FEC filings.
“They’re instruments designed to come out of nowhere and spend a lot of money on elections,” Ghosh said, before voters know “who’s providing that money and what their motives are.”
PAC built for one race
Many of the new groups are also narrowly focused.
Of the $22 million super PACs identified by CNBC, 14 spent all of their money on a single congressional election.
Consider the Maine standard. It was formed on September 11th and began operations five days later. It has since spent $8.2 million, according to FEC filings, all of which went to running against Democrat Troy Jackson in the Maine Senate race.
The Cornhusker majority followed much the same pattern. The party, which was formed on Sept. 10 and began spending on Sept. 16, has spent about $7.1 million in the Nebraska Senate race, nearly all of it against independent candidate Dan Osborn, according to FEC filings. Osborne is running against incumbent Republican Sen. Pete Ricketts in a close race.
The relationship between the two groups did not appear in periodic financial reports until October 15th. Both groups were funded by the Senate Leadership Fund, the Republican’s main Senate super PAC.
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 about $27.5 million supporting Democratic Texas Senate candidate James Talarico, according to the FEC. But unlike some other pop-up groups, the original FEC filing identified Senate Majority PAC as an affiliated entity.
“Homegrown PACs don’t necessarily hide where their money is coming from, but they do fragment the picture. Instead of seeing one national organization spending tens of millions of dollars across the country, voters are seeing a series of different groups operating by race,” said Hilary Blaseth, executive director of OpenSecrets, a nonpartisan nonprofit that tracks such spending.
But even if we identify the national groups behind pop-up PACs, the trail of money could remain even more hidden.
Texas PAC was formed on August 28 and immediately began spending to support Republican Ken Paxton in the Texas Senate race. The funds flowed through the SLF, but Elon Musk’s role was not made public until October 12, more than a month after the spending began.
On Oct. 15, Mr. Musk donated $158 million in two contributions to SLF, and the group transferred the same amount to the Texas PAC the day after each donation, according to an FEC filing.
The Texas PAC had spent about $181.6 million on the race through Oct. 29, according to FEC filings, making it one of the largest late-starting super PACs identified by CNBC.
Together, Texas PAC and No Going Back accounted for about two-thirds of all spending by the $22 million group. But the surge was much broader than those two giants. Even if you remove these two giants, the remaining group spent nearly 12 times what comparable late-comer super PACs spent at the same point in 2022.
“The growth this year is huge,” Kang said. “Maybe you don’t want to be known in this election. Or maybe you want to stay hidden for a period of time while you might not be as popular as AI is now, but you want to build a reputation for the players in the system.”
