Methodology and Legal Resources

In 2014, the Governor signed legislation addressing top contributor lists in two ways. First, it requires the Fair Political Practices Commission to compile and post lists of the top 10 contributors supporting and opposing each specific state ballot measure. Second, it requires committees formed to support or oppose a state ballot measure or a state candidate that raise $1,000,000 or more to provide the FPPC with a list of the committee’s top 10 contributors of $10,000 or more. This does not include a committee controlled by a state candidate for his or her own election.

In late 2015, an amendment to Regulation 18422.5 required additional reporting of the top two contributors of $50,000 or more to any state recipient committee identified as a top 10 contributor.

These lists summarize the top funders supporting and opposing California’s statewide measures and independent expenditures (IEs) supporting or opposing candidates for state office. FPPC staff will compile the list of top ten contributors supporting or opposing statewide ballot measures or IEs supporting or opposing candidates using information from the contributor lists submitted by primarily formed ballot measure committees and IE committees that have raised $1,000,000 or more (Form T10). In compiling this list, FPPC staff may also consult and use information filed with the Secretary of State through the Cal-Access system. The FPPC will make reasonable efforts to ensure that each list does the following:

• Excludes transfers of funds between two or more primarily formed committees for or against the same statewide ballot measure, in order to prevent counting the funds more than once.

• Treats a contribution that is made to a primarily formed committee that supports or opposes more than one statewide ballot measure as if the contribution was made in connection with each statewide ballot measure the committee supports or opposes by attributing the full amount to each measure.

• Marks the name of a contributor with an asterisk if the contributor made a contribution to a primarily formed committee that supports or opposes more than one statewide ballot measure.

• Includes explanatory notes about the data such as: *A contributor whose name is marked with an asterisk made a contribution to a committee that simultaneously supported or opposed more than one statewide ballot measure on the November 4, 2014 ballot. Because of this it is not possible to determine the amount of the contribution that was spent specifically on the campaign for any particular measure. In these cases the contributions are listed for every ballot measure the committee has been formed to support or oppose. This results in the same contribution appearing multiple times - once for each ballot measure the committee supports or opposes.

Committees submit the Form T10 to the FPPC by specified deadlines outlined below. Committees must follow the Form T10 Instructions when submitting their information to the FPPC.

Committees are required to submit reports to the FPPC:

• Within two business days of meeting or exceeding the $1,000,000 threshold if the threshold is met within the 16-day period before the election, or

• Within three business days of meeting or exceeding the $1,000,000 threshold if the threshold is met at any time other than during the 16-day period before the election.

Committees must provide an updated top 10 contributor list when any of the following occurs:

• A new person qualified as a top 10 contributor
  

• A person who is an existing top 10 contributor made additional contributions of $5,000 or more in the aggregate

• The relative ranking order of the top 10 contributors changed

• The committee changed its name to add or delete a ballot measure or candidate

The top 10 lists reflect the most recently available data. During the 90 days before an election the FPPC makes every attempt to ensure that the lists are updated within one business day of receiving new information. Otherwise, the top contributor lists are updated weekly.

• Senate Bill 27
• Gov. Code § 84223 (Top 10 Contributor Lists)
  
• 2 Cal. Code Regulations Section 18422.5
  
• T10
• T10 Instructions
• Cal-ACCESS