He speaks like a candidate, participates in events involving White House hopefuls and even has traveled to Iowa, but Al Sharpton is the only one of the nine Democratic candidates who hasn't filed a presidential campaign finance report.

The New Yorker says he doesn't have to, arguing that he is merely testing the presidential waters and until he officially announces, he doesn't have to disclose who is financing his effort or how much he has raised.

Not so, say some campaign finance watchdogs.

"From all outward appearances, in my view, he looks like a candidate," Larry Noble, head of the nonpartisan Center for Responsive Politics and former Federal Election Commission general counsel, said Friday. "If he is a candidate he should file all the reports a candidate is required to file. I don't think it serves anyone very well for him to be acting like a candidate and refusing to disclose the political contributions."

Sharpton stepped into the presidential race in January, and since then has traveled to early election tests such as Iowa and South Carolina. He has participated at several forums as part of the field of Democratic candidates, including an address to the Democratic National Committee meeting.

And when Sharpton speaks, it's as if he's a full-fledged candidate.

In Des Moines, Iowa, in February, he said: "It is time for Democrats to be Democrats ... And that's one of the reasons I am embarking on this race."

Last month in Washington, he said: "I'm in the Democratic primaries. I'm not running in any other primaries until after I'm the nominee."

But in an appearance Thursday before George Washington University Democrats, Sharpton said he still considers his effort "exploratory" and doesn't believe he has to disclose his financing.

"When I will make an official announcement will probably be later this spring and we will at that point be an official campaign," Sharpton said. "I consider this to be in the very late stages of exploration, waiting on a formal announcement."

Under FEC rules, presidential hopefuls must file campaign finance reports once they spend at least $5,000 on campaign activity. They do not have to report as long as they are simply exploring whether it would be worthwhile to run.

Sharpton's new campaign manager, Frank Watkins, said Friday that though it can be a bit of a "gray area," Sharpton and his attorney do not believe he had to file a first-quarter campaign finance report as others Democrats did this past week.

Watkins said Sharpton has raised more than $5,000 and will file a report if the FEC says he must. He declined to say how much Sharpton has raised or spent.

The FEC rules allow people to conduct campaign-like activities, such as travel, polling and phone calls, without having to file a campaign finance report as long as they are just trying to determine whether they should run.

Hopefuls must report once they cross the line into campaigning, which includes running ads to publicize a campaign, making statements referring to oneself as a candidate, conducting activities close to an election or over a long period of time or raising more than an exploratory effort could reasonably be expected to cost. At that point, they must disclose what they've raised and spent, dating to the beginning of the testing-the-waters stage.

FEC spokesman Bob Biersack declined to comment on Sharpton specifically, beyond noting that he informed the commission in January that he was forming a committee, a step usually followed by the filing of regular campaign finance reports. In Sharpton's filing, the word "campaign" is crossed out in the phrase "principle campaign committee" on the FEC form and replaced by the word "exploratory."

The term "exploratory" has no meaning in FEC rules, Biersack said. Those "testing the waters" usually do not register committees until they're ready to start filing campaign finance reports, he said.