Committee reviews updated campaign finance rules, including electronic filing and fine schedule

The Guam Legislature’s committee on Sept. 26, 2025 took testimony on Bill 189-38 COR, which would repeal and reenact chapter 3, title 6, Guam Administrative Rules and Regulations to adopt updated campaign contributions and expenditures rules and related report forms.

Maria Pangolinan, executive director of the Guam Election Commission, told the committee the updates modernize campaign finance reporting by requiring electronic submission of reports, provide clear deadlines and procedures for depositing and returning contributions, and establish a structured schedule of fines with cure periods. The changes follow Public Law 38-18, which moved some campaign reporting to a quarterly schedule, and the GEC said the proposed rules are intended to implement that statute in practice.

The Bureau of Budget and Management Research noted in a fiscal note that fines collected for contribution violations could create revenue, but BBMR could not estimate the fiscal impact without historical data from the GEC. The Office of the Attorney General and the governor approved the GEC’s administrative-adjudication filings; OAG review flagged technical posting and preliminary-cost-assessment documentation that, if strictly applied, could prompt a supplemental public hearing, though committee staff concluded the GEC had substantially complied with the process.

Committee members raised concerns about the compliance burden on grassroots or first-time candidates. Senator Gumatata, who identified himself as chairman of the Republican Party of Guam, told the committee that administrative burdens and a structured fine schedule could disproportionately affect volunteer-run campaigns. In response, Pangolinan said the GEC plans candidate seminars, has three staff dedicated to campaign finance review, will issue advisory opinions that clarify recurring questions, and will hire temporary staff closer to election season to handle workload spikes.

The hearing included questions about political action committees, in-kind contributions and enforcement. Pangolinan explained that in-kind contributions count toward individual contribution limits; corporations are restricted to cash contributions for fundraisers and ticket purchases under current Guam law, and PACs report separately and are subject to complaints and investigation if violations are alleged. Under current practice the maximum individual contribution per candidate per election is $1,000; the GAR updates add a more detailed fine schedule tied to particular filing or reporting infractions.

The committee considered the bill "duly heard" and invited written testimony for five business days. No committee vote was taken at the hearing; the GEC and invited parties will have an opportunity to provide additional information, including historical data on past violations and on how many in-person registrations were handled by volunteer clerks.