Any LLC which makes a contribution to a candidate, ballot measure, PAC or political party is now required to identify the individual (or one of the individuals) primarily responsible for its political contribution decisions, whether one of the LLC’s members, a project manager or other employee. Under the new rules, this “Responsible Officer” must now sign and be listed on the LLC’s Major Donor reports. In addition, any campaign or committee which receives a contribution from an LLC must now list both the name of the LLC and the name of the company’s Responsible Officer on its reports. To date, the FPPC has not yet provided any guidance on how this disclosure must look.
While committees and LLCs filing their reports on next week’s July 31st deadline will not need to follow these new rules, political committees must follow these rules for 24-hour reporting period beginning on August 5th. LLCs should get into the habit of sending a cover letter with all political contributions, or sending an email when it makes a credit card contribution through a campaign’s website, letting the campaign or committee know the name of its Responsible Officer – or else be ready when the campaign treasurer seeks this information. Campaigns and committees will need to closely monitor all incoming contributions and – as of August 21st – be ready to disclose Responsible Officers within a day of receiving an LLC’s contributions.