California Assembly Bill 45, under consideration by the Assembly Elections and Redistricting Committee, introduces a new reporting regime for donors who contribute $250 or more to newly defined “multipurpose organizations.”  The bill defines a “multipurpose organization” as a “nonprofit organization, a federal or out-of-state political action committee, or a local club focusing on educational or social activities.”

The proposed bill would force nonprofit groups to face disclosure to the government of their donors who have given $250 or more, if the organization has made aggregate contributions or independent expenditures of $2,000 or more during any of the four preceding calendar years, or instead avoid all political speech entirely.

Additional concerns include the likelihood that A.B. 45 could violate the privacy rights of contributors to nonprofit organizations, will result in “junk disclosure” by broadly associating contributors with political communications that they may not support and likely have no knowledge of, and the possibility that this type of regulation could lead to the harassment of individuals from their political opposition.

A copy of the comments can be found here.