Reached by NBC this week, she said the paperwork "will be filed with the next regularly scheduled FEC report," and declined to provide any documentation.
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The delay could matter, because until Trump formally forgives the loans, he maintains the legal option to use new donations to reimburse himself. (He can do so until August, under federal law.)
In his most recent FEC filing, which posted June 20, Trump treated all his spending on the campaign as loans.
An FEC staff member tells NBC News there is no new filing changing Trump's loans. The FEC's candidate tracking page, which posts filings, does not show new paperwork from Trump changing his loans.
Even the remote possibility that Trump could tap new donations to pay himself fed skepticism among GOP donors, who wanted assurances that money intended for the election would not end up in Trump's own pockets.
The Trump Campaign has struggled to pivot to fundraising after the primaries, posting only $1.2 million cash on hand. Trump's loan announcement also comes as political fundraising experts have questioned whether he has taken to exaggerating his online fundraising, with claims that his first foray into email fundraising broke every record ever.
There is nothing new about a candidate loaning money to his own campaign, and Trump has long argued that his personal wealth makes more independent than most politicians, even if he raises money in the general election.
Ultimately, if Trump declines to release any proof for claiming he forgave the loans, the rubber will hit the road on July 20, the next FEC filing deadline.
"It would be disclosed on the campaign's next FEC report," says Michael Toner, former FEC Chairman.
That disclosure is pretty simple. The FEC requires the candidate file a signed a statement, and note the change in the accounting in the monthly report.
For Trump, that would mean re-categorizing the $45.7 million in loans from his most recent report, plus any more of his spending, as candidate donations. Mitt Romney made a similar revision when forgiving some of his loans in 2011.
It's perfectly legal for Trump to make the change in his next monthly filing, instead of using the stand-alone statement his campaign asserted he was filing last week.
Given Trump's repeated insistence that this is a done deal, it is not clear why his campaign won't release the paperwork yet.