Former President Donald Trump's Save America group has quickly become one of the top Republican fundraising organizations ahead of the Nov. 8 congressional elections.

But so far it has been stingy with its spending on Republican efforts to win in November compared to the expenditures of other groups, according to a Reuters analysis of financial disclosures made to the Federal Election Commission.

Trump has already drawn attention for giving only small amounts to Republican candidates, but the findings of the Reuters analysis showing the sharp contrast in spending have not been previously reported.

Since Trump founded Save America in November 2020, the group has raised $124 million -- the largest war chest ever built by an ex-president -- but spent only about $14 million, or around 11%. Much of that has gone to funding rallies and ads that ostensibly promote Republicans running for Congress but focus more on Trump himself.

By comparison, his party's main fund for supporting Senate candidates has spent about 80% of the $135 million it raised since the start of 2021, while its main fund for House of Representatives candidates spent more than half of the $162 million it raised in the same period, FEC filings show.

Save America's limited spending has raised questions among campaign finance experts and political observers, who say it might signal that he is reserving cash for a presidential run.

Taylor Budowich, the director of communications for both Save America and Trump, said the former president was supporting candidates through direct contributions, rallies, and joint fundraisers.

"Save America will not be telegraphing specific tactics or expenditures through the press," Budowich said in a statement to Reuters. "Every dollar raised will go to ensuring President Trump's America First agenda is advanced through his endorsed candidates and causes."

Trump registered Save America as a leadership PAC, or political action committee. Under election laws, it can only spend on election campaigns of people other than Trump but campaign finance experts said there may be ways of tapping into the PAC's war chest if Trump makes another bid for the White House.

Trump has not announced his candidacy for 2024, which would require him to set up a separate fundraising account for his campaign, but he regularly hints at his political rallies that he intends to run for president again.

ODD SPENDING PATTERN

It is still early in the election cycle and Trump could ramp up his spending between now and November to support his Republican Party, which hopes to win control of Congress.

But at this point in a midterm election year, leadership PACs are typically already spending generously on candidates, said Michael Beckel, research director at Issue One, a nonpartisan group that advocates for campaign finance reform.

"It's atypical for someone to amass such a large political war chest in their leadership PAC and not be spending very much directly on elections," Beckel said.

Justin Sayfie of Ballard Partners, a Florida-based lobbying firm with ties to Trump, said it was smart to hold off on spending now so Trump could have a bigger impact closer to election day.

"I would determine which 30 seats are the best pickup opportunities for Republicans once the primaries are over," said Sayfie. "And then pour all my money into those races from August to Election Day."

CONSULTING, ADS AND HOTELS

Trump's biggest outlays have been to pay for his rallies, which many political observers see as potential preparation for 2024 as he connects with crowds and collects data about attendees.

Save America spent more than $3 million on events through February, according to FEC financial disclosures filed ahead of a March 20 reporting deadline.

Save America also spent more than $2 million on consulting services, close to $300,000 on ads and about $200,000 in contributions to Republican congressional candidates. At least $170,000 has been spent at hotels owned by Trump, covering Save America expenses on lodging, meals and the renting of hotel facilities.

The Republican Party's main congressional funds gave about $300,000 to congressional candidates but they spent massive sums elsewhere, including more than $20 million on ads and more than $25 million on text messaging and access to voter lists, which they use to target voters for political mailings and door-knocking campaigns.

"TWO WORDS"

Trump has used his rallies to urge supporters to vote for Republican congressional candidates but they mainly focus on him.

At a frigid gathering in a South Carolina airport on March 12, Trump paused his remarks so that Russell Fry, a state representative endorsed by Trump to challenge incumbent Republican U.S. Representative Tom Rice, could speak.

"Why don't you just say two words and we'll then get the hell out of here because it's cold," Trump said.

After Fry spoke briefly, Trump continued for about 20 minutes, describing how his agenda would transform the country after the next presidential election. "In 2024 we are going to take back that beautiful White House," he said. "I wonder who will do that. I wonder, I wonder."

A Democratic fundraising group filed a complaint last week with the Federal Election Commission alleging Save America's spending on rallies amounted to presidential campaigning, a violation of election laws.

The FEC is unlikely to crack down on Trump, even if he announces a presidential run and tries to channel Save America money to his campaign, according to Beckel and other campaign finance experts.

The FEC's leadership is split evenly between commissioners aligned with Republicans and Democrats and has deadlocked on most contentious issues in recent years.

"It's a free for all," said Ann Ravel, a Democrat who was a commissioner at the FEC from 2013 to 2017.

Trump spokesperson Budowich said complaints raised by Democrats were "frivolous" and had "zero merit."

One legal strategy Trump could employ to use Save America money on a presidential campaign would be to sever his formal ties with the group, Ravel and other experts said. Trump could also transfer Save America funds to an allied group.