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Urgent Compliance Update: Unions That Employ Lobbyists Need to Report Their In-Kind and Monetary Contributions to Their Own PAC


In light of recent compliance actions taken by the Attorney General’s office, this update outlines important reporting guidance for unions with PACs, as well as unions with lobbyist employees.

Washington State law requires unions that employ lobbyists to file a monthly political contribution report with the PDC when they make one or more contributions to candidates or PACs, including to their own PAC, for any calendar month where the value of those contributions exceeds $110. This report must include the value of not only the union’s monetary contributions, but also the value of the union’s staff time and other union resources that were devoted to assisting its PAC’s operations. This report is called the “Employer of Lobbyist Monthly Political Contribution Report,” otherwise known as an L-3c. In lieu of this filing, a lobbyist may report these contributions on behalf of the union in the lobbyist’s report, known as form L-2.

State law also requires PACs to report contributions received, and expenditures made, by the committee. The PAC must include the value of services furnished to the committee for less than fair market value as an “in-kind” contribution. This includes reporting things the union provides to its PAC, such as staff time, office space, postal and web services, and telephones.

This application of Washington law has been underscored in recent investigations and enforcement actions by the PDC and the AG, driving home just how important it is to ensure these reports are filed with complete and accurate information.

What does this mean for unions?

  • Unions that employ lobbyists need to be sure they file reports on the expenditures made to their PACs, relating to both in-kind and monetary contributions—which includes the value of the services your staff provided on the PAC’s behalf. These expenditures should be reported in either your lobbyist’s L-2 reports or your own monthly L-3c reports, if the total value of the expenditures (money plus the services provided) exceeds $110 in a month.
  • Likewise, PACs need to report the flip-side of this situation—reporting the in-kind value of the union’s staff time and/or other resources expended in support of PAC activities (regardless of whether or not the union employs a lobbyist). The PAC must report (on its C-3 and C-4 forms) the value of the work done for the PAC by employees on the union’s payroll as an in-kind contribution received,

If you need more specific information regarding your own union’s (or PAC’s) compliance on this or any other issue, don’t go it alone. Be sure to give us a call so we can get you the answers you need.