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FPPC proposes reorganization of termination and reopening rules to align with California's CARS system
Summary
The commission previewed a package to reorganize Regulations 18404 and 18404.1 and to adopt 18404.3, consolidating termination procedures for recipient committees, clarifying reopening procedures, and addressing new campaign-funding rules for security expenditures tied to the rollout of the Secretary of State’s CARS filing system.
The Fair Political Practices Commission’s legal team presented a pre-notice regulatory package on Aug. 21 to reorganize and clarify the termination and reopening rules for recipient campaign committees and to accommodate the Secretary of State’s upcoming CARS campaign-filing system.
Senior Commission Counsel Karen Harrison told commissioners the package would repeal and re-adopt Regulation 18404, revise 18404.1, and add new Regulation 18404.3 to consolidate termination procedures and provide clearer reopening standards for committees that previously terminated but later need to resume activity. The effort is intended to make termination rules consistent with the online forms and records used by CARS and to help the Secretary of State implement the new system.
Key points: Under the proposed structure, most calendar-year committees would terminate automatically once they meet filing obligations; recipient committees would have a clarified voluntary termination procedure based on four factors: no campaign activity, no contributions, no outstanding debts (or inability to pay), no surplus funds, and all required filings submitted. Candidate-controlled committees subject to state contribution limits would remain subject to a mandatory 24-month termination timeline once trigger events occur.
Reopening and refunds: Harrison explained the package also clarifies when terminated committees may reopen for “good cause” (for example, litigation expenses) and creates limited exceptions for accepting vendor or government refunds of $10,000 or less without undertaking a full reopening. The draft also addresses how to handle security-related campaign expenditures created by new legislation (noting a typical $10,000 lifetime cap in current law and pending bills that could change that cap), and sets processes for returning or reimbursing campaign funds used for security items.
Why the change is proposed: The Secretary of State asked the FPPC for clearer rules to fit the new online filing environment and to prevent confusion about which office (FPPC or Secretary of State) handles reopenings. Staff said the package aims to reduce regulatory overlap and to ensure committees close and reopen under predictable rules while preserving investigators’ ability to require disclosures.
What’s next: Commissioners complimented staff and asked for outreach to the regulated community. No action was taken at the pre-notice stage; staff will incorporate feedback and return with formal proposals for notice and comment.
