[EL] Disclose Act Pro-Union?

[Justin Levitt]

Doesn't the provision in question cover several different types of 
affiliated groups?

It's my understanding that if [insert vilified bugaboo] gave $49,000 to 
10 local Chambers of Commerce, each of which then gave $49,000 to the 
national Chamber of Commerce ... or if [insert vilified bugaboo] gave 
$49,000 to 10 local wholly-owned subsidiaries of ExampleCorp, each of 
which then gave $49,000 to the ExampleCorp treasury, they'd be treated 
exactly the same as Jim's hypothetical union -- which is to say that the 
body that conducts the ad buy would disclose its own information, but 
not the contributors to the subsidiary affiliate, as long as the 
affiliate wasn't created for the purpose of making campaign disbursements.

The bill text is here 
<http://thomas.loc.gov/cgi-bin/query/F?c112:1:./temp/%7Ec112X9jHp4:e4971:>, 
and I think the provision that Jim's mentioning is (f)(3), and 
particularly (f)(3)(C):

"(C) DETERMINATION OF AFFILIATE STATUS- For purposes of this paragraph, 
the following organizations shall be considered to be affiliated with 
each other:
                 `(i) A membership organization, including a trade or 
professional association, and the related State and local entities of 
that organization.
                 `(ii) A national or international labor organization 
and its State or local unions, or an organization of national or 
international unions and its State and local entities.
                 `(iii) A corporation and its wholly owned subsidiaries..

Justin

On 7/16/2012 8:05 AM, JBoppjr at aol.com wrote:
> Click here: Not-So-Full Disclosure | Washington Free Beacon 
> <http://freebeacon.com/not-so-full-disclosure/>
> I am wondering about this provision:
> /The remaining provisions leave unions and other labor groups largely 
> unaffected, since union member dues don't trigger the disclosure 
> threshold. Furthermore, affiliate groups, such as local union 
> chapters, are exempted from disclosure when transferring below $50,000 
> dollars to parent groups./
> //
> So George Soros gives $49,000 to 10 locals unions who then give 
> $49,000 to their national union to do an ad buy for $490,000 -- all 
> Soros money.  How is this lack of disclosure justified by the 
> supporters of DISCLOSURE?  Jim Bopp
>
>
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-- 
Justin Levitt
Associate Professor of Law
Loyola Law School | Los Angeles
919 Albany St.
Los Angeles, CA  90015
213-736-7417
justin.levitt at lls.edu
ssrn.com/author=698321



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