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FPPC adopts rewritten termination rules to align with Secretary of State CARS and add reopening guidance
Summary
The commission voted unanimously to adopt reorganized and substantive changes to regulations governing committee termination and reopening, including new handling of security reimbursements and clearer procedures for reopening terminated committees; staff said the changes reflect CARS transition and recent statute updates.
Senior Commission Counsel Karen Harrison summarized a package of amendments to regulation 18404 and related sections that reorganizes termination rules, removes form‑specific references, and adds clarified reopening and refund procedures to coordinate with the Secretary of State’s CARS system.
Harrison said the package is mainly a consolidation and modernization: “These regulations also reflect a change in law. So there has been recent legislative updates in the use of campaign funds for security expenses,” and the revised rules explain how committees can terminate while preserving obligations to reimburse security expenses when an ongoing threat prevents immediate repayment.
Why it matters: the package changes how committees terminate filing obligations and how terminated committees may accept unexpected refunds or reopen. Staff told the commission the revisions are intended to reduce confusion created by form‑dependent language and to align FPPC practice with the Secretary of State’s upcoming CARS online filings.
Substantive changes highlighted to commissioners - Form independence and statutory references: the rules remove dependence on specific form numbers and instead reference the statutes and filing obligations, which staff said will remain compatible during the Secretary of State’s transition to the CARS electronic filing system. - Security reimbursements and refunds: committees that terminate may accept certain refunds (government refunds or vendor refunds under $10,000) without reopening; the regulation package adds that security reimbursements can be handled by that refund procedure in limited circumstances and clarifies when reopening is required for larger or unusual refunds. - Reopening procedures: the package creates 18.404.3 to clarify when terminated committees may reopen, who may request reopening (the terminated committee’s controlling candidate or principal officer), and that the executive director may reopen a mandatorily‑terminated candidate committee for good cause for a limited purpose. The rules require reopening requests and responses to be posted on the commission website and allow the full commission to hear the matter at the chair’s discretion.
Commission discussion and education plans: Commissioners asked detailed questions about how small or inexperienced treasurers should navigate the new rules. Harrison said the revisions codify existing advice and will be paired with updated manuals, fact sheets, and training; she also noted the Secretary of State and the California Political Attorneys Association provided input during drafting.
Vote: The commission approved the package by roll call. The motion to adopt the amendments to regulation 18 404, the repeal and adoption of regulation 18 404.1, and adoption of regulation 18 404.3 passed unanimously.
Ending: Staff said it will update education materials, post guidance tied to the CARS transition, and coordinate joint training with the Secretary of State’s office ahead of the 2026 filing cycle.
