Q. When must direct corporate political contributions be disclosed?

A. At least 15 states require some sort of corporate contribution disclosure, whether it be on a campaign finance statement or lobbyist/employer disclosure report.

Campaign finance reports typically require an annual aggregate threshold be exceeded before a report is triggered.  For example, in Utah, direct corporate contributions must exceed $750 in the aggregate per calendar year before a report is required.  In Georgia, the threshold is $25,000.  In Nebraska, a corporation making more than $250 in direct corporate contributions must file a report within 10 days after the end of the calendar month in which the contribution is made.

Conversely, lobbying reports typically start at “dollar one.” In New Mexico, lobbyists are required to report all political contributions made by the employer, regardless of amount.  The same holds true in South Carolina and New Hampshire.

And then there’s California—a hybrid of both campaign finance and lobbying disclosure.  Direct corporate contributions must exceed $10,000 in the aggregate per calendar year before a campaign finance report is due.  However, until this threshold is exceeded, corporate political contributions must be disclosed on the lobbyist employer’s quarterly report.

As always, the best practice is to track all corporate political contributions in the event disclosure is required.   Likewise, you need to familiarize yourself with the reporting requirements in those jurisdictions where your company is making contributions.

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(We are always available to answer questions from clients that are specific to your needs, and we encourage you to continue to call or e-mail us with questions about your particular company or organization. As always, we will confidentially and directly provide answers or information you need.) Our replies to your questions are not legal advice. Instead, these replies represent our analysis of laws, rules, and regulations.