This haul represents a development in campaign finance strategy that worries election watchdogs: the use of state committees to build early capital in key states.

The advantages of the state-based strategy are simple. As long as the candidates avoid expressly stating they're running for president -- and some stopped just short of that -- their committees are not subject to federal laws that limit the sizes and sources of contributions. The approach has been used before, but not to the extent that it is being employed in the early stages of the 2008 campaign.

This is the first full presidential election cycle conducted under the 2002 McCain-Feingold campaign finance law, which barred "soft money" contributions and tightened limits on donations that can be accepted by declared federal candidates and members of Congress.

"There's no question that we've seen non-federal candidates set up more of these out-of-state, soft-money PACs than we've ever seen," said Michael E. Toner, a federal election commissioner. "And it could be an important growth area for prospective presidential candidates in the future."

Seven politicians who are either officially in the race or have contemplated it have raised $22 million since the 2004 presidential election through 18 committees in nine states, according to an analysis of campaign finance reports filed in those states.

That's a far cry from the $100 million entrance fee Toner said any candidate would need to raise by year's end to be taken seriously for 2008. But early money is significant because it allows campaigns to hire staff, rent offices and build alliances in key states.

The politicians are Republicans Mitt Romney of Massachusetts, George Pataki of New York, Mike Huckabee of Arkansas and Jim Gilmore of Virginia; and Democrats Bill Richardson of New Mexico, Tom Vilsack of Iowa, and Mark Warner of Virginia.

The strategy is open to any politician who has yet to officially declare he or she is running for president and who is not a member of Congress. There are different explanations for the governors' state committees, some of which are holdovers from campaigns for state office. Many of those committees accepted checks from individuals, unions and corporations that were for far more than the federal $4,600 individual contribution limit; the federal law also prohibits unions and corporations from giving money.

Romney and Pataki provide examples of how the state committee strategy can allow small groups of donors to bankroll the early stages of campaigns. Since Election Day 2004, Romney raised $6.3 million through state committees registered in six states before officially registering his presidential exploratory committee with the Federal Election Commission this month and coming under federal election laws.

Pataki raised $3.9 million through six committees set up in five states, though he has yet to announce whether he will set up an FEC exploratory committee.

The Romney and Pataki networks each included committees in states with early nominating events and laws that allow contributions prohibited by federal laws. Both have committees in Iowa, where state law allows unlimited individual contributions, and New Hampshire, which allows corporate contributions.

South Carolina, where Pataki and Warner set up political action committees (PACs), allows both coprporate and union contriibutions, while New Mexico, where Richardson has a PAC, and Virginia, where Pataki, Huckabee, Gilmore and Warner have established PACs, allow unlimited individual, union and corporate contributions.

Spokesmen for the Richardson, Huckabee and Gilmore campaigns did not return calls to comment. Officials for Romney, Pataki, Warner and Vilsack said their state committees were set up to contribute to candidates in those states, though South Carolina is the only state in question where state law bars contributions from out-of-state committees.

Politicians should not be allowed to use state committees to skirt federal fund-raising rules, said Virginia state Del. Brian Moran, D-Alexandria. He has introduced a bill to require political committees established in Virginia to raise and spend a majority of their funds in the state. "Virginia could be the destination for these nationwide PACs, and frankly I don't think it benefits our reputation," he said.

The state-based strategy also concerns critics of the role of money in politics, who contend it violates the intent of federal laws. Plus, the myriad of committee names with no obvious link to the politicians -- such as Romney's Commonwealth PAC -- and divergent state reporting requirements make it difficult to figure out who has raised what, when and in which states.

But the FEC would have to reach to the outer limits of its jurisdiction to rein in the practice. Unless that happens, or unless individual states tighten their laws, state committees could become the way for beyond-the-Beltway presidential hopefuls to offset fund-raising advantages enjoyed by their competitors in Congress.

Paul Ryan, associate legal counsel for the Campaign Legal Center in Washington, said,"If a candidate wants to deny that their repeated trips to Iowa and New Hampshire two and a half years before an election are not for the purpose of exploring a potential 2008 presidential run, there's little that the FEC can do in terms of law enforcement to say 'You are lying, candidate; we know the real purpose of these trips.' "

"But it's obvious to the public that there can be little purpose beyond exploring a presidential run," he said, adding the candidates "would at the very least violate the spirit of the law, if not, in fact violate the letter of the law."

Nonsense, said Benjamin L. Ginsberg, an election lawyer whose firm advised Romney, Pataki and Huckabee on how to set up state committees and is now national counsel to the Romney exploratory committee. "That's a real Washington view of things. The intent and spirit of campaign finance laws exist in each of the 50 states and Commonwealth PACs followed the intent and spirit of those state laws," he said. "To allow people to raise money that's legal under state law for state candidates would seem to me to be one of the fundamental of a democratic -- small 'd' -- form of government."