The Virginia Association of Counties strongly supports efforts to improve resources for election administration and this bill presents an excellent opportunity to make progress in strengthening the state-local partnership in this area. We submitted a letter via email to Committee members underscoring our support for this bill and related proposals before the Committee. Thank you for your consideration.

The League of Women Voters of Virginia strongly supports this bill to have the state reimburse the localities for the costs of absentee voting. Too often we hear of election expenses as "unfunded mandates," with greater and greater demands made of the localities. In some cases the localities do not have the resources to meet the standards required for efficient and secure early voting both in person and by mail, which accounted for over 50% of votes cast in the general election in 2020 and over 36% of total turnout in the 2021 general election.

Voting is a constitutional right. Any law that restricts rather than expands our constitutional right & DUTY to vote is simply voter suppression. We must not repeal any expansions of absentee ballots. Do not decrease early voting. - extend the number of days allowed. Do not eliminate any ballot box locations- expand. We have no need to re-register absentee ballots every year. No excuse absentee voting is absolutely crucial. The state must provide easy and free access to voter ID if a photo is required. Since the USPS has slowed considerably, we must keep the 3 day rule for receiving ballots after election day. All local elections must be on Election Day (in Nov). Election Day should be a holiday. Until we do a complete overhaul of campaign finance & eliminate dark money/special interests there must be no restrictions on outreach, education & registration or from where a candidate may collect funds. Voter registration up to and including Election Day is absolutely crucial to ensure all citizens vote. I support all bills expanding our rights and abilities to make voting as easy as possible. I oppose all bills attempting to restrict any access to our ballot and our vote. The process is too important for the elected officials to be able to restrict us from our duty to be informed voters. Keep expanding our rights. Do not restrict, suppress or subvert them.

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The League of Women Voters of Virginia supports HB 86. The Department of Elections’ current campaign finance database is inadequate for voters who want to know who is making contributions to a particular candidate, and how much has been contributed. We agree that the privately funded services currently available, including VPAP in particular, are helpful. However, because this is data required to be collected by the government for voters to use in assessing candidates, the government should take on the responsibility to make the data easily accessible to voters. Virginia voters should not have to rely on the largesse of private funders to obtain this access to the campaign finance data required by current law.

Jessica Mott, VA Chapter of American Promise: As a member of the Virginia Chapter of American Promise, I request that you please vote for HB86 and HB 492. Passage of this and other campaign finance reform legislation to improve disclosure and oversight is crucial to making legislators more accountable to voters, and restoring people’s trust in government. A recent poll by Christopher Newport University’s Wason Center found that 88% of Virginians support improved public disclosure of campaign contributions. The enactment of HB86 would strengthen disclosure by upgrading the campaign finance database so that it is publicly accessible, searchable and sortable. By making disaggregated data publicly available, it would complement the analysis and digested data provided by VPAP, and enable resolution of issues such as double-counting and consistency. The upgraded campaign finance reporting standards and software would make report compilation easier and increase completeness and accuracy. Its incremental cost would be relatively small. The enactment of H B492 would address a fundamental gap in oversight by providing the Department of Elections with the authority to review campaign finance reports and records. The use of a “review” rather than an audit, and the proposed sample sizes are cost effective and appropriate. The review system and associated campaign report requirements, together with the use of algorithms for campaigns and reviewers to identify and address shortcomings in reports, should make campaign finance information more complete and accurate, and help ensure compliance. The incremental budget requirement would also be relatively small. Thank you for this opportunity to testify.

Nancy Morgan Coordinator of the VA Chapter of American Promise.Thanks for Del Anderson for this bill which we support.. The Department of Election currently has no system for public access to campaign finance data yet it is the state’s role, as the only entity that has the ability to ensure the accuracy and completeness of this information, to ensure access to the general public. We think that VPAP provides useful analysis but it is not appropriate, nor the responsibility of a non-profit privately managed entity, funded by donors, to be the sole source of data on campaign finance records. One of the recommendations of the Campaign Legal Center to the Joint Sub-Committee of Campaign Finance Reform was to ensure access to this information on the Dept’s website through easy-to-use, online portal where voters can search and access public records related to campaign spending and the sources of contributions. We are one of the few states in the country in which there is no investment in publically managed disclosure of campaign finance records to the general public. This bill responds to that recommendation.

As a member of the Virginia Chapter of American Promise, I ask you to please vote for HB86 andHB 492. Passage of campaign finance reform legislation to improve disclosure and oversight is crucial to holding legislators accountable to voters, and restoring people’s trust in government. A recent poll by Christopher Newport University’s Wason Center found that 88% of Virginians support public disclosure of campaign contributions. HB86 would strengthen disclosure by upgrading the campaign finance database to make it publicly accessible, searchable and sortable. Upgraded campaign finance reporting standards and software would make reporting easier, more accurate and complete. H B492 would provide the Department of Elections with the authority to review campaign finance reports and records. This could make campaign finance information more complete and accurate, and help ensure compliance.

All bills that will reflect a stronger more secure election in the future. Considering both sides, Trump and Biden, have spoken in regards to those concerns, these should be reported on with bipartisan approval. Thank you.

The League of Women Voters of Virginia supports HB 492. Ideally, the Department of Elections would have the resources to audit every campaign committee for each election. We recognize that Virginia currently does not have such resources, but the existing system, which provides no routine audits of campaign committees, gives voters no confidence that submitted reports are accurate. A review of a percentage of campaign committees, with the necessary report, will provide a strong incentive to each campaign committee to prepare accurate reports and give voters a greater assurance that their reports can be relied upon.

The League of Women Voters of Virginia supports HB 86. The Department of Elections’ current campaign finance database is inadequate for voters who want to know who is making contributions to a particular candidate, and how much has been contributed. The private services currently available, including VPAP, which have been developed in lieu of an adequate public site, are not a good substitute for voters who want to access the information that candidates are required by Virginia law to provide.

Our team from Money Out Virginia, the VA affiliate of the nation-wide American Promise campaign finance reform advocacy organization, worked hard this past year with the "Joint Subcommittee to Study Comprehensive Campaign Finance Reform," and produced a "Citizens' Report" for the Subcommittee that articulated principles and priorities for improving transparency, preventing corrupt campaign finance practices and moving towards more equity in campaign financing in Virginia elections. The partnership between the Subcommittee and Money Out Virginia has resulted in a series of important bills that improve the requirements, process and electronic infrastructure for disclosure of campaign donations. We strongly support Delegate Bulova's HB 492, HB495, and HB500, Delegate Helmer's HB489, Delegate Anderson's HB86 and Delegate Davis' HB125, which provides for penalties for violations of disclosure laws. We also support Delegate Bulova's HJ53 to extend the mandate of the Joint Subcommittee so that we can continue our partnership in developing sensible campaign finance reforms for Virginia.

Jessica Mott, VA Chapter of American Promise: HB86 (publicly accessible database): We support this bill. A recent poll indicates that 88% of Virginians support public disclosure of all contributions. This enactment of this bill would strengthen disclosure by requiring that the database containing the information from campaign finance reports be publicly accessible, searchable, and sortable. It also requires that the Board of Elections set standards that should help ensure that the data is complete, accurate, and helps verify compliance with campaign finance legal requirements. Its adoption should help facilitate the efficient use of algorithms and electronic cross-checking to promote compliance by reporting entities and the reliability of the information in the database. It compliments the other proposed disclosure bills, HB495, HB500 and HB489, as well as the proposed oversight bill HB492. HB489 (electioneering): We support this bill, Its passage would help reduce one significant form of dark money support by making this support transparent. It adopts a definition of electioneering that is already utilized in other jurisdictions. It would help ensure that campaign finance disclosure includes not only ads that directly advocate support or opposition to candidates, but also ads close to election dates that imply support or opposition in ways that are likely intended to influence election outcomes. It also requires public disclosure within ads of top 3 donors. SB318, its counterpart, was approved by the Senate with bipartisan support on January 24th. HB 492 (record retention, guidance and review): We support this bill. It deals with a number of issues discussed by the Joint Subcommittee on Campaign Finance. It requires improved instructions for report forms, along with assistance to campaign offices, and clearly defines the campaign office responsibilities for record retention for expenditures above $500. It addresses a fundamental gap in oversight by providing the Department of Elections with the authority to review campaign finance reports and records. The proposed sample sizes are cost effective and appropriate (100% of state-wide candidates, 10% of state legislature candidates and 1% of other offices for campaigns costing more than $25,000). These and other provisions should help enable cross-checking of data, and the use of algorithms for campaigns and reviewers to identify and address report shortcomings related to completeness, accuracy and compliance. We note that it would help ensure meaningful implementation of proposed HB973, restricting personal use of campaign funds. HB495 (electronic filing): We support this bill. We commend the inclusion of electronic filing of independent expenditures, as well as by all candidates except for candidates running for local office who raise less than $25,000. It addresses measures that were discussed and agreed in principle by the Joint Subcommittee on Campaign Finance Reform. The parts of it pertaining to candidates are largely comparable to SB222 which has been approved by the Senate P&E Committee and was approved by unanimous vote by the Senate on January 24. HB500 (electioneering): We support this bill. We appreciate that it enhances disclosure by expanding advertisement provisions to include more forms of electioneering communications. Thank you for the opportunity to comment. Thank you for this opportunity to testify.

Nancy Morga,n Coordinator of the VA Chapter of American Promise. We support Delegate Anderson's bill. The Department of Election currently has no system for public access to campaign finance data; yet, it is the state’s role, as the only entity that has the ability to ensure the accuracy and completeness of this information, to ensure access to the general public. One of the recommendations of the Campaign Legal Center to the Joint Sub-Committee of Campaign Finance Reform was to ensure access to this information on the Dept’s website through easy-to-use, online portal where voters can search and access public records related to campaign spending and the sources of contributions. This bill responds to that recommendation.

Nancy Morga,n Coordinator of the VA Chapter of American Promise. We support Delegate Anderson's bill. The Department of Election currently has no system for public access to campaign finance data; yet, it is the state’s role, as the only entity that has the ability to ensure the accuracy and completeness of this information, to ensure access to the general public. One of the recommendations of the Campaign Legal Center to the Joint Sub-Committee of Campaign Finance Reform was to ensure access to this information on the Dept’s website through easy-to-use, online portal where voters can search and access public records related to campaign spending and the sources of contributions. This bill responds to that recommendation.

I strongly support HB86. It would greatly enhance full public disclosure of campaign contributions, something that is desired by the vast majority of citizens of the commonwealth. The bill specifically requires the State Board of Elections create a computerized campaign finance database, standards for electronic submission of campaign finance, and portal or interface that allows users to easily search for and sort campaign finance information. I strongly support HB495. A vast majority of Virginians want full disclosure, including of independent expenditures. This bill introduces reporting requirements on all independent expenditures as well as improving reporting by candidates and committees. all reports must be filed electronically. It also closes a loophole which forces out-of-state monies, such as through out-of-state PACs, to be reported to the Dept of Elections. Public access to reports, including independent expenditures is also ensured by a web based, user friendly portal. Thank you for the opportunity to provide comments, Bill MIllhouser

I am writing in support of Del. Tim Anderson HB86 Elections; campaign finance; disclosure reports; searchable electronic database. Requires the Department of Elections to provide an interface to the campaign finance database maintained by the Department that allows users to easily search for and sort information by individual candidates and types of elections, offices, committees, and donors; donations, expenditures, loans, and other categories of information included in campaign finance reports; and late filings, incomplete filings, and other violations. The interface shall also provide users tools for manipulating and exporting data. The bill has a delayed effective date of July 1, 2023. • Public access to campaign finance data by state agencies is a best practice implemented by most states • This type of access and public availability of campaign finance data is appreciated by 88 percent of Virginians who support full disclosure. • It was recommended by the Campaign Legal Center to the Joint Sub-committee on campaign finance reform which met last year over the Aug-Oct period. • Can only improve Virginia’s standing nationally on transparency. Right now we rank 46 out of 50 on the SWAMP Index, a national scorecard for state specific regulations which promote transparency and accountability. • This needs funding and staff allocated. Mindy Mitchell 3601 5th St S Arlington VA 22204

Voting is a constitutional right. Any law that restricts rather than expands our constitutional right & DUTY to vote is simply voter suppression. We must not repeal any expansions of absentee ballots. Do not decrease early voting. - extend the number of days allowed. Do not eliminate any ballot box locations- expand. We have no need to re-register absentee ballots every year. No excuse absentee voting is absolutely crucial. The state must provide easy and free access to voter ID if a photo is required. Since the USPS has slowed considerably, we must keep the 3 day rule for receiving ballots after election day. All local elections must be on Election Day (in Nov). Election Day should be a holiday. Until we do a complete overhaul of campaign finance & eliminate dark money/special interests there must be no restrictions on outreach, education & registration or from where a candidate may collect funds. Voter registration up to and including Election Day is absolutely crucial to ensure all citizens vote. I support all bills expanding our rights and abilities to make voting as easy as possible. I oppose all bills attempting to restrict any access to our ballot and our vote. The process is too important for the elected officials to be able to restrict us from our duty to be informed voters. Keep expanding our rights. Do not restrict, suppress or subvert them.

The League of Women Voters of Virginia supports HB 492. Ideally, the Department of Elections would have the resources to audit every campaign committee for each election. We recognize that Virginia currently does not have such resources, but the existing system, which provides no routine audits of campaign committees, gives voters no confidence that submitted reports are accurate. A review of a percentage of campaign committees, with the necessary report, will provide a strong incentive to each campaign committee to prepare accurate reports and give voters a greater assurance that their reports can be relied upon.

Jessica Mott, VA Chapter of American Promise: As a member of the Virginia Chapter of American Promise, I request that you please vote for HB86 and HB 492. Passage of this and other campaign finance reform legislation to improve disclosure and oversight is crucial to making legislators more accountable to voters, and restoring people’s trust in government. A recent poll by Christopher Newport University’s Wason Center found that 88% of Virginians support improved public disclosure of campaign contributions. The enactment of HB86 would strengthen disclosure by upgrading the campaign finance database so that it is publicly accessible, searchable and sortable. By making disaggregated data publicly available, it would complement the analysis and digested data provided by VPAP, and enable resolution of issues such as double-counting and consistency. The upgraded campaign finance reporting standards and software would make report compilation easier and increase completeness and accuracy. Its incremental cost would be relatively small. The enactment of H B492 would address a fundamental gap in oversight by providing the Department of Elections with the authority to review campaign finance reports and records. The use of a “review” rather than an audit, and the proposed sample sizes are cost effective and appropriate. The review system and associated campaign report requirements, together with the use of algorithms for campaigns and reviewers to identify and address shortcomings in reports, should make campaign finance information more complete and accurate, and help ensure compliance. The incremental budget requirement would also be relatively small. Thank you for this opportunity to testify.

Nancy Morgan, Coordinator of the VA Chapter of American Promise. We support this bill because it contributes towards building a solid structure of campaign finance monitoring and enforcement. Virginia, as mentioned in last year's Joint Subcommittee on Campaign Finance which met last year over the August-October period, currently doesn’t have the ability to provide oversight of existing regulation, such as the “Stand-by-your ad” nor does it have the regulatory oversight capacity to undertake basic monitoring of campaign finance reports. Part of the reason, VA ranks 46 out 50 in the SWAMP index, a ranking of states based on criteria related to transparency and accountability is deficiencies in enforcing its own regulations. This bill moves to address key deficiencies within the Department of Elections, including lack of ability/authority to monitor and audit campaign finance reports, require retention of records and identify inconsistencies in filing. This is considered national best practice as testimony to the Joint Subcommittee by the Campaign Legal Center, a national institution with an expertise on campaign finance systems.

As a member of the Virginia Chapter of American Promise, I ask you to please vote for HB86 andHB 492. Passage of campaign finance reform legislation to improve disclosure and oversight is crucial to holding legislators accountable to voters, and restoring people’s trust in government. A recent poll by Christopher Newport University’s Wason Center found that 88% of Virginians support public disclosure of campaign contributions. HB86 would strengthen disclosure by upgrading the campaign finance database to make it publicly accessible, searchable and sortable. Upgraded campaign finance reporting standards and software would make reporting easier, more accurate and complete. H B492 would provide the Department of Elections with the authority to review campaign finance reports and records. This could make campaign finance information more complete and accurate, and help ensure compliance.

The League of Women Voters of Virginia supports HB 492. Ideally, the Department of Elections would have the resources to audit every campaign committee for each election. We recognize that Virginia currently does not have such resources, but the existing system, which provides no routine audits of campaign committees, gives voters no confidence that submitted reports are accurate. A review of a percentage of campaign committees, with the necessary report, will provide a strong incentive to each campaign committee to prepare accurate reports and give voters a greater assurance that their reports can be relied upon.

Our team from Money Out Virginia, the VA affiliate of the nation-wide American Promise campaign finance reform advocacy organization, worked hard this past year with the "Joint Subcommittee to Study Comprehensive Campaign Finance Reform," and produced a "Citizens' Report" for the Subcommittee that articulated principles and priorities for improving transparency, preventing corrupt campaign finance practices and moving towards more equity in campaign financing in Virginia elections. The partnership between the Subcommittee and Money Out Virginia has resulted in a series of important bills that improve the requirements, process and electronic infrastructure for disclosure of campaign donations. We strongly support Delegate Bulova's HB 492, HB495, and HB500, Delegate Helmer's HB489, Delegate Anderson's HB86 and Delegate Davis' HB125, which provides for penalties for violations of disclosure laws. We also support Delegate Bulova's HJ53 to extend the mandate of the Joint Subcommittee so that we can continue our partnership in developing sensible campaign finance reforms for Virginia.

Jessica Mott, VA Chapter of American Promise: HB86 (publicly accessible database): We support this bill. A recent poll indicates that 88% of Virginians support public disclosure of all contributions. This enactment of this bill would strengthen disclosure by requiring that the database containing the information from campaign finance reports be publicly accessible, searchable, and sortable. It also requires that the Board of Elections set standards that should help ensure that the data is complete, accurate, and helps verify compliance with campaign finance legal requirements. Its adoption should help facilitate the efficient use of algorithms and electronic cross-checking to promote compliance by reporting entities and the reliability of the information in the database. It compliments the other proposed disclosure bills, HB495, HB500 and HB489, as well as the proposed oversight bill HB492. HB489 (electioneering): We support this bill, Its passage would help reduce one significant form of dark money support by making this support transparent. It adopts a definition of electioneering that is already utilized in other jurisdictions. It would help ensure that campaign finance disclosure includes not only ads that directly advocate support or opposition to candidates, but also ads close to election dates that imply support or opposition in ways that are likely intended to influence election outcomes. It also requires public disclosure within ads of top 3 donors. SB318, its counterpart, was approved by the Senate with bipartisan support on January 24th. HB 492 (record retention, guidance and review): We support this bill. It deals with a number of issues discussed by the Joint Subcommittee on Campaign Finance. It requires improved instructions for report forms, along with assistance to campaign offices, and clearly defines the campaign office responsibilities for record retention for expenditures above $500. It addresses a fundamental gap in oversight by providing the Department of Elections with the authority to review campaign finance reports and records. The proposed sample sizes are cost effective and appropriate (100% of state-wide candidates, 10% of state legislature candidates and 1% of other offices for campaigns costing more than $25,000). These and other provisions should help enable cross-checking of data, and the use of algorithms for campaigns and reviewers to identify and address report shortcomings related to completeness, accuracy and compliance. We note that it would help ensure meaningful implementation of proposed HB973, restricting personal use of campaign funds. HB495 (electronic filing): We support this bill. We commend the inclusion of electronic filing of independent expenditures, as well as by all candidates except for candidates running for local office who raise less than $25,000. It addresses measures that were discussed and agreed in principle by the Joint Subcommittee on Campaign Finance Reform. The parts of it pertaining to candidates are largely comparable to SB222 which has been approved by the Senate P&E Committee and was approved by unanimous vote by the Senate on January 24. HB500 (electioneering): We support this bill. We appreciate that it enhances disclosure by expanding advertisement provisions to include more forms of electioneering communications. Thank you for the opportunity to comment. Thank you for this opportunity to testify.

Nancy Morgan, Coordinator of the VA Chapter of American Promise. We support this bill because critical to the foundation of a campaign finance system is a solid structure of monitoring and enforcement. Virginia, as mentioned in the Joint Subcommittee, currently doesn’t have the ability to provide oversight of existing regulation, such as the “Stand-by-your ad” nor does it have the regulatory oversight capacity to undertake basic monitoring of campaign finance reports. Part of the reason, VA ranks 46 out 50 in the SWAMP index, a ranking of states based on criteria related to transparency and accountability is deficiencies in enforcing its own regulations. This bill moves to address key deficiencies within the Department of Elections, which include lack of ability/authority to monitor and audit campaign finance reports, require retention of records and identify inconsistencies in filing.

I am writing in support of Del David Bulova HB 492 Campaign finance; record retention requirements and reviews of campaign finance disclosure reports. Requires campaign committee treasurers to retain certain records that may be used in reviews of campaign committee accounts. The bill gives the Department of Elections the authority and duty to conduct reviews of a percentage of campaign committees and to report the results of such reviews annually to the State Board of Elections, the Governor, the and General Assembly and make such report available on the Department's website. • Currently the Department of Elections has very weak oversight (monitoring and enforcement) of campaign finance regulations. They can’t even monitor existing regulations like the “Stand-by-Your-Ad” act. • The provisions of this bill respond to recommendations in the draft report of the Sub-Committee on Campaign Finance Reform which met over the Aug-Oct period. • It improves disclosure of campaign finance information to the public. • Sets the stage for a robust system of monitoring and enforcing campaign finance reform which is very weak now, as revealed in our ranking in the 2020 SWAMP Index (46 out of 50 states) Mindy Mitchell 3601 5th St S Arlington, VA 22204

Voting is a constitutional right. Any law that restricts rather than expands our constitutional right & DUTY to vote is simply voter suppression. We must not repeal any expansions of absentee ballots. Do not decrease early voting. - extend the number of days allowed. Do not eliminate any ballot box locations- expand. We have no need to re-register absentee ballots every year. No excuse absentee voting is absolutely crucial. The state must provide easy and free access to voter ID if a photo is required. Since the USPS has slowed considerably, we must keep the 3 day rule for receiving ballots after election day. All local elections must be on Election Day (in Nov). Election Day should be a holiday. Until we do a complete overhaul of campaign finance & eliminate dark money/special interests there must be no restrictions on outreach, education & registration or from where a candidate may collect funds. Voter registration up to and including Election Day is absolutely crucial to ensure all citizens vote. I support all bills expanding our rights and abilities to make voting as easy as possible. I oppose all bills attempting to restrict any access to our ballot and our vote. The process is too important for the elected officials to be able to restrict us from our duty to be informed voters. Keep expanding our rights. Do not restrict, suppress or subvert them.