Jeb Bush’s super PAC expects to raise $100 million by the end of this month.  According to Politico:

Jeb Bush is putting in motion an ambitious plan to develop a super PAC that would be unprecedented in its size and scope — a blueprint growing in scale and intensity as he nears the formal launch of his presidential campaign.

The group, called Right to Rise, is said to be on track for raising an historic $100 million by the end of May, and its budget is expected to dwarf that of Bush’s official campaign many times over. In interviews, more than half a dozen sources familiar with the Right to Rise plans described a juggernaut that was rapidly taking shape — from its likely headquarters in Los Angeles, 2,700 miles from the Miami office where Bush was basing his campaign, to a new fundraising push aimed at expanding its ballooning coffers.

It turns out that his delay in announcing his candidacy is likely tied to campaign finance laws:

Bush’s decision to put off a formal announcement is rooted in the complex nature of campaign-finance laws. As a non-federal officeholder who hasn’t yet become a candidate, he’s allowed to travel the country and solicit large contributions of unlimited amounts for Right to Rise. Once he becomes a declared candidate, though, Bush won’t be able to ask for donations of more than a few thousand dollars for the super PAC. At that time, he’ll also be prohibited from discussing strategy with the consultants and operatives who will be running the group.

One person who’d been briefed on Bush’s timeline said he was eying a June announcement, tied to his return from a trip to Poland, Germany and Estonia. Under that scenario, the former governor would have about another month to, without restriction, raise funds for Right to Rise and to communicate with the strategists who are likely to guide it.

In January, Jeb announced his Right to Rise PAC. Here’s the smart phone clip he posted to Facebook:

While it seems likely that Bush’s fundraising will rival only Clinton’s, there is some doubt about whether he can “spend his way to the win”:

Certainly, money will still be essential in 2016, and it remains an advantage to have more of it than anyone else. In an extended primary, when the race moves on to larger states for votes held on the same day, an outsized bank account could yet play an important role.

But diminishing returns on cash investments undoubtedly shift the burden of securing the win back on to the candidate and his or her skills: These contenders will need to demonstrate an ability to click, in real time, with voters and offer a compelling message rather than simply relying on slick strategy to sell them digitally. In effect, the Republican presidential primary could become like the general election for the presidency, where the massive amounts of money spent by each party cancels itself out and rarely leads to substantial returns with voters.

That’s bad news for the candidates who are struggling to connect—namely Jeb Bush, whose current front-runner status hinges mostly on the expectation that he will outraise, not outperform, his rivals.

It seems questionable whether Jeb can outperform his more conservative GOP rivals in areas that will secure him wins in  Republican primaries.  As CBS puts it, Jeb “clings to unpopular views on immigration and Common Core,” and even if he does decide at some point to shift right on these points, the base is unlikely to believe him.  As it stands now, he’s already lagging in polls in both Florida and Iowa, in the latter he was in 7th place in Quinnipiac‘s most recent poll.

Will his incredibly flush war chest make the difference?  Will it push him over the top and into the GOP nomination and even on to the White House?