But Romney Victory is also spending quite a bit of money on fundraising and outreach, as opposed to merely acting as a pass-through, according to Sunday's report. It shows $13.3 million in campaign-related spending, including $7.2 million for "digital consulting" to Targeted Victory, the consulting firm founded by the Romney campaign's digital director Zac Moffatt, as well as $750,000 for fundraising consulting to a Boston company called VG LLC.

And Romney Victory paid $1.3 million for "facility rental/catering services" to a range of hotels, prestigious clubs and firms - suggestive of costs associated with high-dollar fundraisers. For instance, the Balboa Bay Club in Newport Beach, Calif., was paid $52,000, New York's Waldorf-Astoria hotel was paid $42,000, Las Vegas's Trump International Hotel was paid $14,000, and Barclays, the besieged investment bank, was paid $4,300.