The grassroots
lobbying section of U.S. House Bill
984 (H.R. 984) contains onerous reporting requirements (on a quarterly
basis), and civil fines of up to $100,000 for failing to comply. The effect by
AFA and other grassroots groups to get you information on any bill before
Congress will be profound.
Under H.R. 984, AFA
would have to report the issues, employees, contractors and dollars spent in
what is called "paid efforts to stimulate grassroots lobbying" (that phrase is
not defined). This reporting requirement is triggered by two actions: (1)
a lobbying "contact" – a personal or written communication with an individual in
the executive or legislative branch of the federal government concerning public
policy issues, from legislation to nominations; and (2) communications with
grassroots (that’s you) that "influence" them to contact the executive or
legislative branches ("influence" is not defined, but it apparently doesn't even
have to include a specific "call to action.") There is no minimum dollar
spending requirement that triggers the reporting requirement by AFA for our
efforts to stimulate grassroots lobbying.
Once AFA identifies
a "lobbying contact" that it has had (e.g., We talk with a representative about
a Supreme Court nomination), then AFA will have to track all internal
expenditures on that issue: AFA Journal articles, printing costs, payments to
authors, etc.; AFA Online e-mailing costs; special website creations; broadcast
expenses; and issue advertising (creative costs, ad buys, etc.). Cost of
trips, speeches, and fundraising letters will have to be allocated to the
correct "issue." (We could be dealing with a half-dozen issues, and we will have
to keep tract and expense of every issue we deal with.) The compliance
costs alone will be heavy, with the hiring of perhaps as many as 8-10 new
employees to track both accounting and legal oversight involved and all the
paperwork required.
AFA’s involvement
in coalitions or alliances (Arlington Group, judicial confirmation groups; right
to life coalitions) will also trigger reporting requirements by those
coalitions, and any donations by AFA will have to be reported by that coalition.
All these reports
will be available to the public. Because of the timing of the quarterly reports
and the fact that spending usually precedes action, it is entirely likely that
we will have to report what we are going to do in advance of actually doing it.
For example, our opponents may be alerted in advance that we intend to purchase
air time for ads targeting a specific issue.
The bill makes
exemptions for larger, organized groups who employ paid lobbyists, who don’t
dominantly rely on public communication (to people like you) to get their
messages out.
The bill defines
“grassroots lobbying firms” as any organization that encourages 500 or more
members of the general public to contact Congress.
AFA would be forced
to file a report to the government on a quarterly basis that contains detailed
information about our organization. The required report must include
identification of the organization’s expenditures, the issues focused on and the
members of Congress and other federal officials who are the subject of the
advocacy efforts. A separate report would be required for each policy
issue the group is active on.
Basically these new
rules were written to isolate pro-family and conservative Christian
organizations. Large corporations (which spend millions in lobbying
expenses) would be exempt. Communications aimed at an organization’s
“members, employees, officers or shareholders” would be exempt. That means
that groups such as the AFL-CIO, MoveOn.org, National Education Association and
other organized groups would be exempt.
Click Here to
take action on this issue.