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SGS - ACTION ITEM: Discussion of Potential Culver City Campaign Finance Reforms.
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Meeting Date: December 3, 2025
Contact Person/Dept.: Jeremy Bocchino, City Clerk
T’Ana Allen, Deputy City Clerk
Phone Number: (310) 253-5851
Fiscal Impact: Yes [] No [X] General Fund: Yes [] No [X]
Attachments: Yes [X] No []
Public Notification: (E-Mail) Meetings and Agendas - Standing Governance Subcommittee (11/25/2025)
Department Approval: John Nachbar, City Manager, (11/25/2025) _____________________________________________________________________
RECOMMENDATION
Staff recommends the Standing Governance Subcommittee discuss potential campaign finance reforms and provide direction to staff.
BACKGROUND / DISCUSSION
At the October 8, 2025, Standing Governance Subcommittee meeting, the Subcommittee requested information on certain potential changes to how campaign finance information is disclosed and potential new requirements and/or limitations.
Specifically, the Subcommittee requested information on the following:
1) How campaign advertisements from independent expenditures could be required to disclose top donors
2) Whether an index of all campaign ads registered with Culver City could be created for public awareness
3) Whether a dashboard could be created to publicly display for/against spending per candidate, including contributions and expenses for each candidate
Campaign Disclosure
As a national leader in promoting transparency and fairness in elections, California has regulated campaign disclosure at both the state and local levels. This was achieved by the adoption of the Political Reform Act of 1974 (the “Act”), which requires candidates and committees to disclose campaign contributions received and expenditures made. There are a multitude of campaign disclosure forms that have specific filing deadlines. These documents are all public documents and may be viewed by the public or even audited by agencies such as the Fair Political Practices Commission (FPPC) and the Franchise Tax Board (FTB) to ensure voters are informed and that improper campaign spending is prohibited.
Under the Act, the following types of committees are subject to campaign rules:
• a candidate’s campaign committee,
• a general purpose committee,
• a political party committee,
• a slate mailer organization,
• a major donor, and
• a person or entity making independent expenditures on candidates or ballot measures in California.
A committee could qualify in three different ways:
1. Recipient Committee - This type of committee receives contributions of $2,000 or more per year for political purposes and are generally formed to support or oppose more than one candidate or ballot measure.
2. Independent Expenditure Committee - This type of committee makes independent expenditures of more than $1,000 per year, primarily on California candidates or ballot measures. For an expenditure to be independent, there must not be any consultation, cooperation, or coordination with the affected candidate or committee.
3. Major Donor Committee - This type of committee makes contributions of more than $10,000 per year to (or at the request of) either a California candidate or ballot measure. Generally, this type of committee does not receive contributions.
While the FPPC regulates the majority of campaign disclosure laws, under the Act, local jurisdictions may enact a campaign ordinance that provides for additional or different campaign requirements for committees active exclusively in its jurisdiction, as long as the provisions are stricter than those in the Act.
Chapter 3.06 of the Culver City Municipal Code (Attachment 1) outlines limitations on campaign contributions and campaign ad disclosure. This report discusses potential updates to the municipal code that would align with the city’s goal of improved transparency for the public, especially in the realm of campaign finance disclosure.
Campaign Advertisement Disclosure
The Act defines an advertisement as, “any general or public communication that is authorized and paid for by a committee for the purpose of supporting or opposing a candidate or candidates for elective office or a ballot measure or ballot measures” (GC 84501(a)(1)). An advertisement could include mass mailings, e-mail blasts, paid telephone calls, radio and television ads, billboards, yard signs, and electronic media ads. Under the Act, candidates and political committees must place disclosures on campaign advertisements that identify the committee that paid for or authorized the communication. This is recognized as advertisement disclosure. Typically, the advertisement disclosure states “Paid for by (committee name)” or “Ad paid for by (committee name)” so that the public is properly informed about who the political message is coming from.
The FPPC enforces all rules on political advertising in California, with the bulk of enforcement cases generated by the public. The most common advertisement violations of the Act are the following:
• Failure to include “Paid for by” or “Ad paid for by” in same manner and immediately adjacent to a committee name on mass mailings
• Disclosures in a font type, color, position, or size that does not comply with a requirement
• Committee name does not match the name as stated in the statement of organization (Form 410)
• Failure to disclose top contributor information
• Required size or time length of disclosure on video or radio advertisements is not met
Disclosure of Advertising Top Donors
Under the Act, top contributor disclosure is required by most independent expenditure committees. Disclaimer requirements are based on the type of ad and who has paid for it. In consideration of adopting a regulation of this nature, it is important to identify who would have to adhere to this law and the amount of the contribution that is made. Additionally, the language for which the committee must include should be considered. An example would be the City of Los Angeles which has adopted an ad disclosure of this nature, which is specified in Article 9, Section 49.7.33 of its municipal code (Attachment 2). LA City requires a line on all communications that starts with "Major funding provided by [names of the two contributors who gave the most to the committee in the six months prior to the date of the payment for the independent expenditure communication], in the amount of [the total amount of contributions made by those contributors in the same six-month period].”
Disclosing top donors on political communications would allow for the public to more clearly understand who is paying to generate political ads that could possibly impact their decision-making ability when it comes time to vote.
Development of an Index of all Campaign Advertisements
Registration of campaign ads is another way in which the public could be more informed when it comes to political advertising. With so many ads in circulation and in various forms, having an index available to the public could greatly improve transparency. An example would be the City of Berkeley, who currently keeps an index of all mass mailings for each election going back to 2018. In consideration of establishing a new law that requires campaign ads registration, it would be important to consider exactly what information must be disclosed so that in developing the index, the information is easily accessible to the public.
A Potential Campaign Contributions and Expenses Dashboard
The City currently utilizes NetFile to accept campaign contribution and expenditure disclosure statements. All statements uploaded into the system are made available to the public via the public access portal. The public access portal is available through the ’Citys FPPC webpage <https://www.culvercity.gov/City-Hall/City-Departments/City-Manager/City-Clerk/Fair-Political-Practices-Commission-FPPC-Required-Reporting>. Users can download all data reported by year, by candidate, or by committee. While the information online is helpful, it isn’t the easiest to digest. Implementing a dashboard that could visually breakdown campaign spending could be useful. An example would be the City of San Francisco which has such a dashboard. Users can filter data by committee type and see contributions and expenses using bar charts. The webpage provides users with information on the last time the page was updated, as well as a webpage dedicated to showing the user how to read the data and better utilize the page.
For any of the proposed changes to be included as part of the Municipal Election on November 3, 2026, final City Council approval, design and implementation would need to take place prior to July 1, 2026.
FISCAL ANALYSIS
There is no fiscal impact to discuss this item or any recommendation by the Subcommittee. Depending on the nature of the Subcommittee’s recommendations and subsequent action by the City Council, there may be associated costs.
ATTACHMENTS
1. 2025-12-03_ATT 1 - CCMC Chapter 3.06
2. 2025-12-03_ATT2 - LAMC Article 9, Section 49.7.33
recommended action
MOTION(S)
That the Standing Governance Subcommittee discuss potential campaign finance reforms and provide direction to staff.