About Our Support for Local Ballot Measures

Q: Can the Central Valley Community Foundation sponsor a local ballot measure?

A: Yes. Under federal law, support for ballot measures is considered a form of “direct lobbying,” and such support may take many forms. This perspective sees the voting public as a “legislative body” deliberating on “specific legislation” in the form of the measure. Within the applicable limit (see below), federal law allows CVCF — or any 501(c)(3) public charity — to fund and/or conduct lobbying activities.

Q: What rules and limits apply to ballot measure activity?

A: Federal law applies a cap on lobbying, and requires reporting of expenditures, paid or incurred, for lobbying purposes. State law requires campaign disclosures. CVCF’s federal cap depends on the magnitude of its overall charitable expenditures because CVCF elected the expenditure test under Internal Revenue Code section 501(h). The cap equals $225,000 plus 5% of the exempt purpose expenditures over $1.5 million (up to $1 million maximum). In 2017 CVCF’s exempt purpose expenditures totaled approximately $18 million.

California law applies no cap but imposes campaign reporting requirements once the initiative becomes a measure.

Q: How does CVCF report its ballot measure-related expenditures?

A: Through its annual federal IRS Form 990, and through local filings as a major donor. With its federal Form 990, CVCF will file Schedule C, a statement of its lobbying expenditures.

Under the State’s disclosure laws, CVCF discloses its expenditures as a “major donor committee” via the City of Fresno. Click here to visit the City’s public portal.


Internal Revenue Service, “Measuring Lobbying Activity: Expenditure Test.”

California Fair Political Practices Commission, Campaign Disclosure Manual 3 – Information for Ballot Measure Committees.
See in particular Chapter 1, “What is a Ballot Measure Committee?” and Chapter 13, “Multipurpose Organizations.”

Alliance for Justice/Bolder Advocacy, “Ballot Measures and Public Charities.”