While President Trump faces bruising poll numbers amid the ongoing coronavirus pandemic and ensuing financial crisis, his family business continues making money off his reelection bid. 

On March 31 and April 1, Trump Victory – a joint fundraising committee between the Trump campaign and Republican National Committee – made a series of 43 separate payments to Trump Hotel Collection totaling more than $380,000 according to the joint fundraising committee’s latest quarterly filing with the Federal Election Commission. The records describe the payments as “facility rentals” and range from more than $2,600 to $10,000 each. The same filing reveals another payment of more than $19,000 to the Trump Hotel Collection at the beginning of March, bringing the total spent by the committee at Trump properties to more than $400,000 in the second quarter of the year. 

According to Trump Victory, the 43 payments made over those two dates were for events that had “already happened.” An official declined to give more specific detail when asked further questions by CBS News.

The Republicans’ joint spending at Trump properties has become routine for both the GOP and Trump campaign. Records show since the start of 2019 through the first quarter of 2020, the committee spent more than $1.3 million at Trump properties. Some of the biggest payments over the past two years include a $75,000 payment to Trump National Golf Club in Bedminster, New Jersey in the third quarter of last year and a $126,090 payment to the Trump Hotel Collection in the first quarter of 2020. In 2019, nine payments totaling more than $105,000 also went to the Trump International Hotel in Washington, DC between April and June.

Apart from its joint fundraising committee, the Trump campaign committee has also been making payments to Trump properties since the president began his first presidential bid in 2015. Over the past two years, the Trump campaign has spent about $940,000 at Trump businesses.  One of its larger payments is a recurring monthly payment of $37,541 to Trump Tower for rent of campaign facilities.  The campaign has also made several payments amounting to more than $86,000 to the Trump Corporation for “legal & IT consulting.”

The Trump campaign declined to comment on the rental fees.

“There’s two big legal restrictions on candidates spending campaign money at their own businesses. The basic rule is, they can’t pay too much and they can’t pay too little,” said Adav Noti from the Campaign Legal Center. “If the campaign buys a service or goods from the candidate’s business and it underpays for them, then the business is essentially subsidizing the campaign and that’s an illegal corporate contribution and now that would be a very serious violation. On the other hand, the campaign can’t pay too much because then the money is going into the candidate’s pocket directly or indirectly.”

The ban on personal use relates to the law in 52 U.S.C. 30114, whereas the ban on corporate contributions relates to  52 U.S.C. 30118. Campaign legal experts tell CBS News in theory the campaign could be asked by the Federal Election Commission to prove that it didn’t pay too much or it didn’t pay too little for anything, noting there are other vendors who could provide the same services without the hassle. 

“Usually, candidates don’t bother,” said Noti. “But this particular candidate has been intentionally profiting off his campaign spending as long as he’s been a candidate, so not only is it not a concern to him but it’s something he seems to be doing intentionally to make money.”

FEC filings from the 2016 campaign show the Trump presidential committee alone paid Trump businesses more than $12.2 million over two years and at least another $1.4 million in 2017 and 2018. 

In 2016, the biggest share of the $12 million paid to the Trump Organization was for air travel. The New York Times noted that Mr. Trump paid his company $8.7 million to reimburse it for his air travel on his own plane. Now, he travels on Air Force One, and there is always an official White House visit paired with any campaign events. 

While it does not raise the same legal questions, Mr. Trump’s businesses have also been getting a boost from the Republican National Committee amid re-election efforts. Since the beginning of 2019, the RNC has spent at least $911,000 at Trump hotels federal filings show. One of its largest payments was for $491,702 at Trump National Doral Miami near the beginning of the year. 

On July 1, the RNC announced that it — along with the Trump campaign and joint committees — raised more than $947 million over the past two years for its re-election effort, but announced at the beginning of July that their entities boasted just $295 million cash on hand. 

Advertising appears to be the biggest individual cost for the 2020 campaign. According to Kantar/Campaign Media Analysis Group tracking, Mr. Trump has already spent more than $150 million on TV, radio and digital advertising with future plans to spend nearly $150 million more on TV alone before the election. The campaign has also spent millions on payroll; travel expenses; communications, digital, event and legal consulting, as well as campaign merchandise.

In the wake of a campaign shake-up demoting campaign manager Brad Parscale, Republican sources confirm to CBS News that the new campaign manager, Bill Stepien, will oversee an ongoing audit of campaign spending and infrastructure.

Jeff DeWit, former CFO of NASA and longtime Trump supporter recently joined the president’s re-election campaign to serve as chief operating officer, and said Friday that he is conducting an audit of campaign contracts. “We want an effective and efficient organization, and we’re certainly not targeting anybody,” DeWit told Business Insider. “We don’t like to see a single dollar fly out of the campaign without knowing where it’s going.” 

There is no indication that this review relates directly to the campaign’s use of Trump properties.