While Dr. Ben Carson delivers remarks about his latest book at the National Press Club, an unaffiliated super PAC is working furiously, raising funds to bolster the neurosurgeon as a 2016 candidate for the White House. The National Draft Ben Carson for President Committee has raised money at a blistering pace — the $2.39 million it pulled in during the first quarter of 2014 made it one of the highest grossing super PACs in the country. But, as Sunlight and others have pointed out, almost all of this cash is invested back into fundraising, spent on costly direct mail services and donor list rentals.

From January through March of this year, the group spent more that $2.43 million on overhead and fundraising costs, most of which went to a handful of northern Virginia-based companies that specialize in fundraising for conservative causes. All of the postage, printing and mailings have been successful in pulling in grassroots donations — a Sunlight analysis finds 76 percent of the organization’s first quarter receipts came from small donors who chipped in less than $200 to support the effort to draft Carson.

That’s allowed the super PAC claiming to do that to build a list of conservative donors, which in turn can be rented out to future campaigns that want to tap a national fundraising network.

The list of donors to the National Committee to Draft Ben Carson is, in fact, already available for rental via Omega List, inc., the donor rental service to which the committee has paid $582,739 since its founding last August. The company’s website calls the list “A MUST TEST for your next conservative appeal!! (sic),” telling potential customers that “This list is growing fast with an average gift of $42!”

In fact, some donors give much, much more. Per the committee’s most recent report to the Federal Election Commission, twelve men and women have written checks of $5,000 or more. Dr. Ruth Buck, an elderly retired doctor from Lower Gwynedd, Penn. contributed $50,000 in February.

Vernon Robinson III, a former congressional candidate in North Carolina and the committee’s treasurer, told Sunlight that money earned through list rental went back into the committee’s coffers, after administrative fees were paid to Omega.

Grassroots mailings and donor list rentals are tactics that Philip Sousa IV, the committee’s co-founder, has used in the past. Sousa also spearheaded the super PAC to reelect Joe Arpaio, the outspoken Arizona Sheriff who rose to national prominence for his unbending views on illegal immigration. Arpaio’s donor list is also available for rent through Omega List.

Some in Carson’s inner circle are not over-enthused by the support.

The Washington Times reported in December of last year that Carson did not endorse the organization nor had he “authorized the solicitation of funds in [his] name or likeness.” Armstrong Williams, identified by the Times as Carson’s business associate, told the publication that outside groups using his image to raise political money were “supporting someone else’s agenda and lining their pockets.”

It doesn’t seem likely that the super PAC is going away any time soon. Should Carson or his associates choose to complain to the FEC about the committee, recent enforcement matters make it appear unlikely they will make much headway.

In a decision from April 7, commissioners found no reason to believe that so-called Allen West “scam PACs” — which West’s campaign alleged were using the former congressman’s likeness to “profit from the name and reputation” of the Florida politician — had violated the Federal Election Campaign Act, as the group’s using West’s name were independent and had included proper disclaimers to that effect.