While you're sifting through the quarterly campaign finance reports today, you may be wondering where Fred Dalton Thompson's filings are, since, obviously, he's running for President too. Here's his disclosures in their entirety:

In other words, no filings from Thompson as to who he's raising money from, or how he's spending it -- and also, unlike everyone else in the field, no financial disclosure statement yet as to his personal riches. [And, also, as long as he's not a "candidate," the equal time rules regarding his Law & Order episodes don't apply, and he can receive that free advertising.]

See, Thompson claims he's not really a candidate for President yet; he's just "testing the waters". Now, friends, that's not a made-up term -- under the FEC rules, you can delay your initial campaign filings if you're truly not sure if you want to run, and want to raise and spend a little money to determine if your candidacy would be viable. But the ability to use this loophole ceases if it's clear that you've decided to become a candidate, and there are extrinsic factors are used by the FEC to determine if that's the case. I'll focus on three:

If you raise funds in excess of amounts reasonably required for exploratory activity or amass funds for use after candidacy is established;

If you conduct activities over a protracted period of time (or shortly before an election); and

If you make or authorize statements that refer to yourself as a candidate.

Raising Funds Beyond What You Need To "Explore"

Well, Thompson claims to have "taken in at least several million dollars", and the New York Post confirms that the campaign had "made significant strides toward the nearly $5 million that Thompson's 'First Day Founders' have committed to raising as seed money for a full-fledged presidential campaign." Indeed, almost a month ago, the WaPo reported the campaign's acknowledgement that it "seems on track to reach his goal of raising about $5 million in just one month, according to advisers."

Long-Term Planning

When your campaign "signed a long-term lease on a building in Nashville that will serve as its national headquarters", you're engaging in protracted campaign activity.

Calling Yourself A "Candidate"

Here's some of what Thompson has said already:

June 26, 2007: "You're either running or not running. I think the steps we're taking are pretty obvious."

June 4, 2007: Thompson referred in the past tense to having decided "I’m going to do this," and then again talks about "when I did" decide to run for President. Also in that interview, Thompson claims his Internet presence "has allowed me to be in the hunt, so to speak, without spending a dime." [Query -- does blogging on a site with only 23K visits/day count as a "presence"?]

June 6, 2007: Thompson tells CNBC's Kudlow and Cramer that his campaign is a foregone conclusion, saying "Well, I don't want to get into a lot of details in terms of a plan before I even announce my candidacy."

July 12, 2007: Thompson advisor Mary Matalin tells the WaPo, "He has made up his mind. And one can appreciate that planning the announcement of what's on his mind needs to take place in a deliberative fashion."

As one campaign finance attorney put it today, Thompson is "playing footsie" with the campaign rules. Thompson allegedly believes in "more disclosure" in the campaign finance realm. Let's see him prove it. What could he possibly be hiding?