FPPC: Greater Transparency with Behested Payments

On Thursday, April 20, the California Fair Political Practices Commission (“FPPC”) unveiled a new online disclosure system that improves the way users can search and view behested payments.  Up until recently, the FPPC only utilized a spreadsheet for tracking down behested payment information, which made it hard to extract data.

Generally, a payment is considered “behested” in California and subject to reporting if: (1) it is made at the request, suggestion, or solicitation of, or made in cooperation, consultation, coordination or concert with the public official; (2) it is made for a legislative, governmental or charitable purpose; and (3) it does not qualify as a gift or a campaign contribution to the elected official.

The FPPC’s new system has a visualization and a word search component.  The public can now view which public officials are requesting money for charities and causes.  The customized word search reveals who is giving money, how much money they are giving and where the money is going.  The search function also allows users to see the amount requested by elected officials, the payment date, the payor, the payee and the stated cause for requesting the money.

Donations behested by California state and local officials may be lobby reportable by the donating organization.  If you or your organization would like more information on this topic, please feel free to contact us.

Politicom Law assists large companies with lobbyists who are active throughout the country.  Based in California, the Politicom Law team delivers “empowered compliance” solutions to assist filers with the patchwork of federal, state and local political law mandates, including behested payment permissibility and reportability.