The AFA is an organization that monitors legislation/current events and alerts Christians/Families as to legislation/events that could limit rights, take away rights, or promote immorality. When I signed up, it seemed like a good way to keep up with stuff… They recently published an email alerting readers to Senate Bill 1, Section 220, and implied that this was designed to shut down organizations like the AFA. (U.S. Code (“USC”)).
It gave this explanation why the bill would shut them down. Then it gave a link to their take on what the bill was saying. Click Here.
This is what Senate Bill 1, Section 220 says. It’s at the bottom of the page. Click Here.
In paragraph 1 the AFA says it is a grassroots organization. The title of Section 220 is “Disclosure of paid efforts to stimulate grassroots lobbying.”(emphasis added). The tone of the article implies that AFA doesn’t think it’s a grassroots organization, and later paragraphs talk about “paid efforts to stimulate grassroots lobbying.” S.1Sec.220(a)(7) says “Lobbying activities include paid efforts to stimulate grassroots lobbying, but do not include grassroots lobbying.” Grassroots lobbying means “voluntary efforts of members of the general public to communicate their own views on an issue to Federal officials.” S.1Sec. 220(a)(17).
In paragraph 2 the AFA says that Senate Bill 1, Section 220 doesn’t define “paid efforts to stimulate grassroots lobbying.” S.1Sec.220(a)(18)(A) says “IN GENERAL – The Term ‘paid efforts to stimulate grassroots lobbying’ means…” I’m confused, if the bill says ‘means’, isn’t that defining? Also, in this paragraph, it notes that this “term does not include any communications by an entity directed to its members, employees, officers, or shareholders.” Those who subscribe to the AFA aren’t members of the AFA. See also S.1Sec.220(a)(18)(C) regarding registrants.
In paragraph 3 the AFA says that when they identify a “lobbying contact” then it has to track all internal expenditures. “Lobbying contact” isn’t defined in the bill. It it defined in 2 USC 1602 (8) as “any oral or written communication (including an electronic communication) to a covered executive branch official or a covered legislative branch official that is made on behalf of a client…” S.1Sec.220(c)(3)(A) talks about what expenses they have to track. The rest of the expenses are defined in the actual code. 2 USC 1603 (c)(3)(A). They also talk about reporting in paragraphs 4 – 5. They say they deal with dozens of issues and now they’ll have to keep track of every expense of every issues. There are rules defining how to split and track expenses. Also, why shouldn’t they have to track expenses if they’re lobbying, and if other lobbying groups have to do this? What’s wrong with reporting? Granted it’s tedious. I think the reason they don’t want to track expenses is that they state they’ll have to hire 8-10 new employees.
In paragraph 6, they say the bill makes exemptions for larger, organized groups who employ paid lobbyists, who don’t dominantly rely on public communication to get their messages out. Lobbying firms have to report. The bill deals specifically with having ‘paid efforts to stimulate grassroots lobbying’ reported.
In paragraph 7 the AFA mis-states the definition of “grassroots lobbying firms” as any organization that encourages 500 or members of the general public to contact Congress. I don’t know where they got their definition. In the proposed bill, it’s defined differently. See S.1Sec.220(a)(19)(A) and (B).
Basically, I think the AFA is taking this amendment too personally. If they aren’t grassroots, then they report like every other non-grassroots” lobbying firm.
I’ve contacted the AFA and asked for an explanation, because what I read and what they say seem to be two different things.