Last May Rep. Dave Reichert, R-Wash., raised campaign cash at a reception at the offices of the National Association of Realtors and around the same time, the group's PAC sent his campaign a check for $4,000.

Four months later, in September, the PAC started spending big, but this time on independent expenditures. Three hundred thousand dollars for a campaign ad. Forty-six thousand dollars on Internet ads. By mid-October, the group had spent more than $576,000 in support of Reichert.

When groups make independent expenditures to support or oppose a candidacy, they are not supposed to coordinate in any way with a candidate. The Federal Election Commission defines this as any communication “that is not made in cooperation, consultation, or concert with, or at the request or suggestion of, a candidate, a candidate’s authorized committee, or their agents, or a political party or its agents.”

Reichert's campaign spokesman told Party Time that there was no discussion of independent expenditures at the May fundraiser.

However, a review of Party Time records show that, in the cozy world that exists, inside-the-beltway groups and individuals involved with making decisions about independent expenditures have had ample opportunities to rub shoulders with candidates at fundraising events—opportunities where discussions about campaigns could occur.

This does not mean any of these groups broke the law, or even if they did, the FEC will take action. The agency rarely investigates charges of coordination unless a complaint is filed by an outside party. Absent a witness, there is no way of knowing what is discussed at such gatherings. And candidates and outside groups mentioned in this report either deny any such discussions or are not talking—most did not return calls for comment.

The National Association of Realtors is one of the biggest forces in independent expenditures this election cycle, spending more than $7 million so far. The group's PAC also contributes liberally to candidates, and its office is the site of numerous fundraisers for Republicans and Democrats alike.

The National Rifle Association (NRA), which has long been a major player making independent expenditures, is also the site for fundraising parties. In late August, the NRA was the location for a "meet and greet" for Kevin Yoder, who is running on the GOP ticket in an open race to represent Kansas' third district. The same day he was scheduled to attend a fundraising luncheon at Carmine's, a restaurant downtown. Several weeks later, the NRA reported the first of several independent expenditures in favor of Yoder's candidacy, currently totaling more than $14,000. Yoder has also collected $4,950 in direct contributions for his campaign from the NRA's PAC.

Rep. Charlie Dent, R., Penn. was the beneficiary, according to this invitation, for a "great shootout" fundraiser at the gun group's offices in March. Since then the NRA has spent more than $7,800 on independent expenditures favoring his campaign. He's also gotten $5,100 in direct contributions from the group's PAC.

Some other examples:

Ellen Malcolm, who founded and now serves as chair of the board for EMILY’s List, the PAC devoted to electing Democratic women to office, is also listed as treasurer of Women Vote!, an “independent expenditure only” committee created earlier this year. This invitation from last December shows her headlining a reception for the “Democratic Women 2010.” Among the beneficiaries of the event was Rep. Diane Titus, D-Nev. Women Vote! has reported spending more than $347,000 opposing Titus’ challenger, Joe Heck. Titus has also benefited from independent expenditures by SEIU and Working America, both labor unions. Last year, according to this invitation, she collected campaign cash at a “labor breakfast.” With no public record of who attended, we do not know who attended the breakfast.

Rep. Betsy Markey, D., Colo., was scheduled to raise money at this labor reception in May whose hosts included a long list of labor groups; SEIU has reported spending nearly $195,000 on independent expenditures in her campaign.

Also, people helping to raise funds for these independent groups in the run up to the mid-terms have been listed as hosts for fundraisers in the past.

GOP heavyweights Ed Gillespie and Karl Rove, who are involved in fundraising for American Crossroads and Crossroads GPS, titans in this year’s GOP barrage of outside spending, are listed as hosts on several invitations collected at Party Time this year. There is also this invitation from 2009 listing Margee Clancy as a contact; Clancy is also a treasurer for American Crossroads. However, none of the candidates benefiting from these events have yet been the focus of from independent expenditures in their races.

Fred Malek, a founder of American Action Network, another new group active in outside spending this election, who is reportedly coordinating with Rove, has been listed as a host for several fundraising events in the Party Time database, including this one in September benefitting Colorado Senate candidate Ken Buck. American Crossroads has spent heavily in the Colorado Senate race both supporting Buck and hitting his opponent, Sen. Michael Bennet.