[EL] Technology to facilitate compliance
Smith, Brad
BSmith at law.capital.edu
Mon Aug 15 10:14:30 PDT 2011
I would agree, that would be a big improvement, and I have always wondered at the way reform advocates have tended to fight such initiatives tooth and nail.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault
Designated Professor of Law
Capital University Law School
303 East Broad Street
Columbus, OH 43215
(614) 236-6317
bsmith at law.capital.edu <mailto:bsmith at law.capital.edu>
http://www.law.capital.edu/faculty/bios/bsmith.asp <http://www.law.capital.edu/faculty/bios/bsmith.asp>
From: John White [mailto:white at lfa-law.com]
Sent: Monday, August 15, 2011 1:12 PM
To: Smith, Brad; Trevor Potter; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: Technology to facilitate compliance
Could not disclosure rules be reformed to exempt, or greatly reduce reporting requirements for committees that do not (1) accept contributions over a threshold amount and/or (2) spend more than a ceiling amount, on the grounds that the risk of corruption or the appearance of corruption is absent or reduced for small, grassroots committees? There is less disclosure already for small-dollar contributors to committees. PAC status is a recognized burden, of constitutional dimensions, given the record-keeping and reporting obligations. We can debate at what dollar level a contribution begins to pose a risk of corruption, or at what spending level "full disclosure" becomes important to electoral integrity.
The anti-trust analogy that has been used is an interesting example. However, someone opening a shop can, without consulting an attorney, be confident that their activity does not have anti-trust implications. The business lacks an essential element - market power. Similarly, if a group of activists want to get together to run advertisements criticizing Senator X's vote on a matter close to an election or if they want to band together to give money to a candidate, they ought to be able to do so without onerous reporting.
Washington permits very small campaigns to opt for "mini-reporting." WAC 390-16-105. For a candidate, only the first filing identifying the committee, its treasurer and other basic organization issues is required (along with the candidate's financial report). This relieves most of the filing requirements if the committee will not be raising or spending $5,000. Unfortunately, the legislature has dropped the threshold for reporting "electioneering communications" to $1,000.
John J. White, Jr.
white at lfa-law.com <mailto:white at lfa-law.com>
(425) 822-9281 ext. 321
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From: law-election-bounces at department-lists.uci.edu [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Smith, Brad
Sent: Monday, August 15, 2011 7:34 AM
To: Trevor Potter; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: Re: [EL] Technology to facilitate compliance
Your position, as I understand it, has been that citizens are represented through large organizations, such as the NRA, NARAL Pro-Choice, unions, and large professional organizations. (We will not unduly harp on the fact that for years many members of the reform community has demanded more restrictions on PACs, at different times expressing a desire to abolish them). Similarly, you have suggested that large corporations can afford large PACs. And you have suggested that small corporations that have a PAC do so solely for lobbying, ignoring the real point that a) virtually no such companies have PACs because the combination of compliance and the restrictions on fundraising make them impractical, and b) to the extent they are practicable, they are only such if used for the limited purpose of supplementing lobbying, rather than having a serious impact on political debate.
The point that Jim, Larry, I and others have been raising is that the rules are a real hardship on small, often-spontaneous, grassroots activity. Your response, and Doug's has been that this type of activity really isn't very important. People who can't afford to hire Caplan-Drysdale aren't likely to raise much money or have much influence anyway. As Doug suggested, maybe if they can't handle the compliance, they should find other ways to participate. This does have some truth to it, but it is not a normative position I find inspiring and it is a position that reinforces the pull of large entities and discourages, indeed is even dismissive of, the political activities of citizens in everyday life.
The presence of large organizations exercising political influence simply does not do away with the question of the effect of these laws on small organizations, local party committees, small, volunteer-based campaigns, and spontaneous citizen-directed and organized activites. Indeed, the dominance of large organizations may reflect in some respects the difficulty of organic, grassroots participation under the law.
Challenged to come forth with "proof" that more activity that might be going on if there weren't these laws in place (not an easy task, to be sure, since no one can no for sure) and the cost of compliance, we have presented evidence of the cost of the compliance and evidence from our own experiences that many people are discouraged from participation by these laws. Your response, which amounts to "hey, stop complaining, they've got the NRA" is, I take it, a concession of the point we originally raised, by you who have insisted on calling us "plutocrats."
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: Trevor Potter [mailto:tpotter at capdale.com]
Sent: Mon 8/15/2011 9:43 AM
To: Smith, Brad; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
Brad:
I have said expressly the opposite. I assume others can read, and am ending this thread.
Trevor
________________________________
From: Smith, Brad [mailto:BSmith at law.capital.edu]
Sent: Mon 8/15/2011 9:25 AM
To: Trevor Potter; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
It appears to me that you are conceding that the rules have largely stomped out small scale grassroots political activity.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: Trevor Potter [mailto:tpotter at capdale.com]
Sent: Mon 8/15/2011 9:24 AM
To: Smith, Brad; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
All of the examples I gave were of non-connected, non business PACS. That is because "average citizens" have historically organized around causes and issues, such as guns, life/choice, ERA, retirement, etc. one could extend this to professions--lawyers, doctors, bankers, nurses, and the traditionally big one--laborers, usually represented for economic purposes by unions. And Brad and others were claiming that these "average citizens" were somehow advantaged by Citizens United license to corporations.
None of that has anything to do with Brad's example: a small company employing 65 people, of whom maybe 10 or 20 are in the "restricted class" and thus solicitable. In my experience, such companies have a PAC for only one reason--as a lobbying tool. Their lobbyist has told them he/she needs to take a PAC check to Washington events to spend time with Members of Congress. I know of companies that do this--and the compliance costs are minimal, as the PAC by definition has only a handful of donors and does not make many contributions. An administrative assistant fills out the reports. For a small company, of that is needed if for an executive to walk around the halls and personally solicit the handful of people, with virtually no overhead.
To re-state my earlier point, the larger the operation, the more complicated compliance becomes. Payroll deduction, professional fundraisers, four-color solicitation materials, an expensive "charitable match" program --they all add to the cost. Of course, those are not truly COMPLIANCE expenditures--those are business expenses voluntarily incurred by the company because they want a larger PAC to have more political clout--read lobbying power. That may well be a rational business decision, but only by bootstrapping does it become a regulatory burden.
________________________________
From: Smith, Brad [mailto:BSmith at law.capital.edu]
Sent: Mon 8/15/2011 8:37 AM
To: Trevor Potter; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
The point is, a small PAC of ordinary citizens, or a small business, a) can't pay those admin costs from the corporate treasury, and can't afford them if they can, and b) still has to incur substantial costs in raising funds in accordance with the rules - costs that are made much higher by the rules (this is part of what SpeechNow.org v. FEC was about).
Realistically, for example, there is no way a small business employing, say, 65 people, can afford to operate a PAC given the compliance and administrative costs (remembering that the administrative costs are almost all "compliance costs" in that they are substantially the result of the regulations), and that such a company is likely to have a small number of people it can even solicit. So the vaunted PAC option becomes a big money game. And the regulations cut off alternatives for more ordinary citizens and more grassroots activity.
I'm not quite sure why you seem to think that the operation of big money PACs mean that PACs are a viable alternative for people without big money.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: Trevor Potter [mailto:tpotter at capdale.com]
Sent: Sun 8/14/2011 10:21 PM
To: Smith, Brad; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
That's what I expected. And solicitation costs include outside fundraising consultants, PLUS for most Fortune 500 companies the costs of the amazing "matching gift" program, in which the FEC has allowed companies to offer their PAC donors a dollar for dollar match of contributions to their favorite charities. I don't dispute it is possible to spend a million dollars a year on a corporate Pac--but that is a cadillac of a PAC...and every penny of that million dollars is from the corporate treasury, not from PAC funds.
Trevor
________________________________
From: Smith, Brad [mailto:BSmith at law.capital.edu]
Sent: Sun 8/14/2011 10:10 PM
To: Trevor Potter; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
That's the total administrative costs, for example, including solicitation costs, which are increased by the rules and regulations, of course, including the limits on the size of contributions.
Ansolabehere, de Figueiredo & Snyder, Why is there so little money in U.S. politics?, 17 J. Econ. Perspectives 105, 109.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: Trevor Potter [mailto:tpotter at capdale.com]
Sent: Sun 8/14/2011 9:56 PM
To: Smith, Brad; Volokh, Eugene; law-election at department-lists.uci.edu
Subject: RE: [EL] Technology to facilitate compliance
Brad:
Is there a citeation to that figure? And does it include solicitation costs (or matching giving)? Based on my experience, that is farb more than an accountant and occasional legal questions...
Trevor Potter
________________________________
From: law-election-bounces at department-lists.uci.edu on behalf of Smith, Brad
Sent: Sun 8/14/2011 8:29 PM
To: Volokh, Eugene; law-election at department-lists.uci.edu
Subject: Re: [EL] Technology to facilitate compliance
By the way, to give some sense of things, in recent years the typical Fortune 500 company PAC has spent approximately $1 million per year on administration, or roughly half of its total take. I think we can safely assume that for smaller PACs, the administrative costs are an even higher percentage of the amount raised and spent.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: law-election-bounces at department-lists.uci.edu on behalf of Smith, Brad
Sent: Sun 8/14/2011 8:24 PM
To: Volokh, Eugene; law-election at department-lists.uci.edu
Subject: Re: [EL] Technology to facilitate compliance
Well, first it is the forms. It's not that they are computerized or not - it's that they exist. Filling in the data is not that hard - that's not the problem. Rather, it is figuring out where the data go, and keeping track of the underlying numbers. The forms are typically quite complex, and we forget that most people are not used to dealing with forms and legaleze instructions. (Some might recall the John Stoessel episode in which he asked "reform" spokespersons to fill out forms, which most couldn't do; a couple studies, one, I believe, by Jeffrey Milyo, found that people couldn't complete the forms correctly even with direct monetary incentives to do so. If you want to try, go to the FEC website, pull up some basic forms, and see how you do). It is very difficult for an amatuer to know how to classify various expenditures and income, for example, and especially what to do with even minor asset sales and the like. The laws also make the book-keeping for routine old time fundraising - selling ice cream at the county fair, passing the hat at a rally, speech, or gathering; selling some t-shirts, etc - virtually impossible. This points up the second problem, knowing and complying with the underlying rules. Third, it is the formal accounting systems that must be established to comply with the law. Fourth, it is the threat of legal liability and fines for mistakes. The more heavily reliant a campaign is on volunteers, the more likely it is that one or more of those volunteers will make mistakes subjecting the campaign to liability. Thus volunteers are in some cases outright discouraged, and in others kept on a tight leash - they can lick envelopes, for example, but are discouraged or prohibited from asking for funds or arranging events.
I estimate overall that a very small, ongoing campaign that wants to be relieved of these duties should budget $3000 to $5000 a month for professional fees. For many small campaigns, even that amount will be far too low. Add in the fear of violations, and that stomps out a lot of activity. Of course, a single complaint can raise that cost dramatically, even if the complaint ultimately fails to even meet the relatively low "reason to believe" standard. An initial response to a complaint is typically $5000 to $10,000. Having seen the operations from inside, I would not advise a campaign to responde without counsel. Obviously, a complaint that leads to a full investigation can cost tens or even hundreds of thousands of dollars, even if the complaint is dismissed before trial.
Potential fines for violations are typically substantial for small violators. For example, a campaign with $2500 in expenses that fails to file a report faces a $250 fine for a first time violation. If that is an "election sensitive report," however, they are looking at a $550 fine for a first time offense. These are fines that go through the FEC's "administrative fines" system. The minimum fine for anything that must go through regular enforcement is historically $1000. The statute generally authorizes fines for unintentional violations of up to $5000 or the amount in question, whichever is larger. The FEC calculates the amount in question so as to raise liability: e.g., before Citizens United, if a small business spent $1.32 to mail three solicitations from the company CEO, and because of that raised $6000, the FEC views the amount of the violation as $6000, not the $1.32 actually spent. PAC treasurers are personally liable for fines if the PAC cannot (or will not) pay it.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: law-election-bounces at department-lists.uci.edu on behalf of Volokh, Eugene
Sent: Sun 8/14/2011 7:41 PM
To: law-election at department-lists.uci.edu
Subject: Re: [EL] Technology to facilitate compliance
So - and again a naïve question - what, practically is the burden of compliance (especially as to disclosure) for small campaigns? I'm not doubting that there is such a burden; I just want a better sense of what it is, and whether it can be mitigated.
Eugene
From: law-election-bounces at department-lists.uci.edu [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Smith, Brad
Sent: Sunday, August 14, 2011 4:15 PM
To: law-election at department-lists.uci.edu
Subject: Re: [EL] Technology to facilitate compliance
The automation rule is the norm at the FEC, which provides free software, and in many if not most states. Many small campaigns, however, still have difficulties with using the software.
The technical filling of data, however, is not the real problem, though it does add to the costs and fears that people have. And believe me, people do have fears.
Bradley A. Smith
Josiah H. Blackmore II/Shirley M. Nault Designated Professor of Law
Capital University Law School
303 E. Broad St.
Columbus, OH 43215
(614) 236-6317
http://www.law.capital.edu/Faculty/Bios/bsmith.asp
________________________________
From: law-election-bounces at department-lists.uci.edu on behalf of Volokh, Eugene
Sent: Sun 8/14/2011 5:52 PM
To: law-election at department-lists.uci.edu
Subject: Re: [EL] Technology to facilitate compliance
I agree entirely that the government should provide the software -- which will often be as simple as a Web page (with supporting software) hosted on the jurisdiction's election commission Web site, or perhaps a spreadsheet template that people could fill in and that the Web page could accept for batch uploads, plus perhaps some software to provide automatic schedule reminder e-mails to everyone who signs up. But this is not rocket science; this would be a simple application of well-understood, routinely used technology.
Indeed, I would think there should be a general principle, whether enacted in statute or just as a strongly accepted guideline -- let's call it the Automation Rule: Every disclosure and reporting regulation imposed by election law must be accompanied with government-provided software, and that proper use of such software would fully discharge the user's legal obligations under the jurisdiction's election law. Naturally, the software also has to be made easy to use, and it's hard to come up with a purely legal rule to make sure that it is easy enough to use. But it seems to me that if the Automation Rule isn't an existing norm already, it should be.
Eugene
> -----Original Message-----
> From: law-election-bounces at department-lists.uci.edu [mailto:law-election-
> bounces at department-lists.uci.edu] On Behalf Of Larry Levine
> Sent: Sunday, August 14, 2011 12:23 PM
> To: 'Kathay Feng'; Volokh, Eugene; law-election-bounces at department-
> lists.uci.edu; law-election at department-lists.uci.edu
> Subject: Re: [EL] Check out Study shows who breaks campaign laws-
> ThePuebloChieftai...
>
> Transaction costs are just a very small part of the matter. It is the rules
> about what needs to be reported and upon what schedule that creates the
> traps. These rules often differ from jurisdiction to jurisdiction and change
> from election cycle to election cycle within the same jurisdiction. If the
> government is going to require automated (electronic) filing of
> contributions and expenditures, then the government should either provide
> the software and hardware needed to comply free of charge, or allow those
> costs to fall beyond the limits of spending on a campaign.
> The difficulty with so much of what we enact in the way of reporting reforms
> is that they may apply well to big statewide races or even to legislative
> races. But when you come down to a city council campaign in a town of just a
> few thousand people, or in a very small school district those requirements
> become burdensome.
> Larry
>
> -----Original Message-----
> From: law-election-bounces at department-lists.uci.edu
> [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Kathay
> Feng
> Sent: Sunday, August 14, 2011 11:58 AM
> To: Volokh, Eugene; law-election-bounces at department-lists.uci.edu;
> law-election at department-lists.uci.edu
> Subject: Re: [EL] Check out Study shows who breaks campaign laws-
> ThePuebloChieftai...
>
> Automation is certainly a practical solution that would help. In California,
> we had a bi- and non-partisan group of reformers, the regulated community,
> citizen groups and others that all agreed that greater automation would help
> with disclosure, and significantly lower transaction costs for both
> campaigns and the government. The idea is still stuck in the mud, though.
> Sent via BlackBerry by AT&T
>
> -----Original Message-----
> From: "Volokh, Eugene" <VOLOKH at law.ucla.edu>
> Sender: law-election-bounces at department-lists.uci.edu
> Date: Sun, 14 Aug 2011 10:41:53
> To:
> law-election at department-lists.uci.edu<law-election at department-lists.uci.edu <mailto:law-election at department-lists.uci.edu%3claw-election at department-lists.uci.edu> >
> Subject: Re: [EL] Check out Study shows who breaks campaign laws
> - ThePuebloChieftai...
>
> A naïve question: Could some of these problems -- at least to
> filing -- be relieved with automation (and might they already be so
> relieved), especially with automation that the jurisdiction is willing to
> certify as sufficient? For instance, I certainly sympathize with concerns
> about the burden of reporting contributions and expenditures, but what if
> State X, when it enacts some such disclosure restrictions, provides that the
> obligation is discharged if a campaign worker goes to a particular Web site
> and accurately enters all the data he's asked to enter? Likewise, I take it
> that whatever software is used to gather credit card donations via the Web
> presumably already creates a data file that can just be sent to the election
> authorities to discharge the disclosure obligations. Or am I missing
> something big here?
>
> Eugene
>
> > On Sun, Aug 14, 2011 at 1:05 PM, Larry Levine <larrylevine at earthlink.net>
> wrote:
> > > You've touched a nerve. We have "reformed" our way into a time when
> > > one cannot run an election campaign of any size, or a PAC, or
> > > conduct activities of a state or local political party or club
> > > without the cost of a professional treasurer and an attorney on
> > > retainer. At the same time we are placing limits on the amounts of
> > > contributions and the permissible expenditures in campaign without
> > > allowing for these "overhead" items to come from a separate account.
> > > Gone is the day when a volunteer can be the treasurer of a campaign
> > > for a friend if the campaign is of any consequential size. On top of
> > > that, we have created a thicket of regulations and requirements that
> > > differ from state to state and from jurisdiction to jurisdiction
> > > within a state, thus making it virtually impossible for a campaign
> > > and/or a candidate to avoid violations without the services of an
> > > elections attorney who is watching over every facet of the campaign.
> > > And all in aide of stamping out the perception of corruption. Tell
> > > me, is the perception any less now than when we started the "reforms"
> some 40 years ago?
> > >
> > > Larry
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