Staff: Zachary Norton, Senior Commission Counsel. Staff proposes adoption of Regulation 18430.1 to add prohibitions and limitations on contributions and expenditures using prepaid cards, as well as amendments to Regulation 18421.3 to prohibit candidates or committees from contracting with payment processors that do not utilize more stringent verification measures and Regulation 18401 to add additional recordkeeping requirements relating to contributions received through payment processors. Staff presented this proposal for pre-notice discussion in June and presented it for adoption in August. In response to public comment, and at the Commission’s direction, this proposal now includes an exception to the prohibition in Regulation 18430.1 on expenditures made with prepaid cards, to permit the use of prepaid cards linked to a prepaid expense account and management system that maintains detailed, itemized records of all expenditures. Staff now presents it for adoption.
Staff Memo
Memorandum to the Commission, Adoption of Proposed Amendments to Regulations 18401, 18421.3, and 18430.1, dated August 11, 2025
Proposed Amendment to Regulation 18401
Proposed Amendment to Regulation 18421.3
Proposed Adoption of Regulation 18430.1
Public Comment, CPAA
Public Comment, Proposed CPAA Amendments 18401
Public Comment, Proposed CPAA Amendments 18421.9
Public Comment, Proposed CPAA Amendments 18430.1
Public Comment, Proposed CPAA Amendments 18431