In this July 24, 2021 file photo, Former President Donald Trump speaks on a variety of topics to supporters at a Turning Point Action gathering in Phoenix. Credit: Ross D. Franklin / BDN

WASHINGTON — Former President Donald Trump frequently teases another presidential bid without actually announcing, a strategy that leaves him with access to a $102 million war chest, an unrivaled haul that could scare off donors to other candidates and freeze the Republican 2024 race.

By not formally declaring, Trump is free to use money from his political action committees to act very much like a candidate without the restrictions that come with an announcement. His coyness keeps the focus on him and maintains his fundraising advantage over would-be rivals.

While he has spent a tiny fraction of that money on rallies and is planning travel to early voting states like Iowa, he has reported donating to very few of the Republican congressional candidates he has endorsed. Instead, the nine-figure bank account serves as a warning to would-be challengers of what they would have to raise to best him.

Even if his Save America political action committee, which holds most of the funds, gave to a Republican candidate in every Senate and House race in 2022, it would still have more than $85 million.

“His leadership PAC is a really powerful weapon that’s heavily armed right now but it‘s not clear what he’s going to use it for,” said Larry Noble, a former general counsel at the Federal Election Commission.

Politicians use leadership PACs to raise money for other candidates and to pay for political expenses unrelated to their own campaigns. Like other political action committees, leadership PACs face a $5,000 limit on the size of contributions they can raise from individuals and the donations they can make to candidates.

Formally declaring a run would put that PAC money essentially off-limits and trigger tighter rules and reporting requirements. An announced presidential candidate must register with the Federal Election Commission within 15 days of raising or spending $5,000 on his or her campaign.

“Making a formal announcement of his intentions to run as a candidate turns him from a U.S. citizen into a highly regulated individual,” said Craig Engle, leader of Arent Fox’s political law practice.

Trump has stepped up campaign-style activity after the chaotic U.S. withdrawal from Afghanistan, doing more interviews with friendly news organizations, issuing multiple statements a day and posting digital ads attacking President Joe Biden. And a spokesman confirmed an ESPN report that on Saturday, Trump and his son Don Jr., will provide commentary on the telecast of boxing matches including Evander Holyfield vs. Vitor Belfort.

In one of the clearest signs that he’s interested in running again, Trump has begun to hire operatives familiar with campaigning in Iowa. On Tuesday night he announced that he would hold a rally in Des Moines on Oct. 9.

Yet when pressed on his plans, he demurs, saying he isn’t “allowed” to answer but that his supporters will be “very happy” with his decision.

“Because the campaign finance laws are extremely complicated and unbelievably stupid, I’m actually not allowed to answer that question,” Trump told Fox News on Aug. 17 when asked about a 2024 bid. “People, you’re going to be happy because I love this country and I hate to see what’s happening to it.”

Since it was created shortly after the 2020 election, Trump’s Save America PAC has raised more than $94 million, but had spent only about $4 million as of June 30.

Once he’s a candidate, Save America and his other leadership PAC, Make America Great Again PAC, would be limited to giving his campaign $5,000 per election. Unable to use the PACs’ millions to pay its expenses, a new Trump presidential campaign would have to start raising money from scratch.

The same fundraising limits apply to other potential candidates, including rival Republicans as well as Biden and Vice President Kamala Harris. Biden doesn’t have a similar leadership PAC but has $13.8 million left over in his joint fundraising committee and $4.7 million in his campaign committee, all of which he would be able to use for a reelection effort. Harris is expected to run for president only if Biden doesn’t seek a second term.

For Republicans, Trump’s sizable war chest could shut down fundraising if donors feel their contribution to a rival can’t chip away at his advantage, making it a significant threat to anyone who steps into the race.

Trump has endorsed candidates in 2022 midterm election races, especially challengers to House incumbents who voted to impeach or convict him for his role in the Jan. 6 attack on the U.S. Capitol. But his PACs reported no contributions to candidates as of June 30, when the last FEC reporting period ended.

Since then, both Rep. Mo Brooks, his endorsed candidate for the U.S. Senate in Alabama, and Max Miller, a congressional candidate in Ohio, said they had received donations from him.

Taylor Budowich, a spokesman for Trump and his Save America PAC, said the former president is focused on using his PAC to help Republicans retake control of the House and Senate in 2022.

“President Trump is mobilizing his MAGA political movement, the most influential force in politics, behind candidates and causes that will advance his America First agenda,” Budowich said in a statement.

At the same time, other would-be 2024 Republican contenders are running “shadow campaigns,” traveling to Iowa and other early voting states to stump for candidates in 2022 but not hiring staff or raising money with an exploratory committee, said Doug Heye, a former Republican National Committee communications director and Trump critic.

“They know the first person to do so would be target No. 1 for Trump,” Heye said. “The will he/won’t he game keeps Trump’s name front and center.”

Potential candidates for a 2024 run include Florida Gov. Ron DeSantis, former U.S. Secretary of State Mike Pompeo, former U.S. Ambassador Nikki Haley, former Vice President Mike Pence and South Dakota Gov. Kristi Noem. Haley has already said she won’t run if Trump enters the race.

Story by Bill Allison and Mark Niquette.