AFJ Weighs In

In Support of Fearless Foundation
Council on Foundations and Independent Sector Sign-On Letter (12/21/2023)
Alongside dozens of philanthropic and nonprofit organizations, AFJ signed-on to a statement in support of Fearless Foundation. As stated in the letter, “we believe that philanthropic organizations, charitable nonprofits, and individual donors have the right to exercise their values and views through giving money and other resources, as protected by the First Amendment. That includes efforts to support historically marginalized groups.”

California SB 459
Letter to the Senate on Concerns about SB 459  (8/25/2021)
Alliance for Justice submitted comments to the California State Senate on the dangerous ambiguities in SB 459 that would add additional reporting mandates, expenditure reports, and shorter deadlines on smaller nonprofits engaged in advocacy.

Testimony on HR1
Alliance for Justice Warns of Unintended Consequences of HR1  (3/2/2021)

Statement on Racial Equity and Police Brutality
Alliance for Justice Condemns Rampant Police Brutality (6/2/2020)
Alliance for Justice Statement on Policing and Racial Injustice (6/16/2020)
Alliance for Justice is committed to standing against racism in all of its manifestations, and Bolder Advocacy remains committed to working with justice-minded organizations looking to make long-overdue changes to local, state, and national structures that undermine public safety, particularly in communities of color.

Opposition to Ban on Behested Payments
Letter to Rules, Elections, and Intergovernmental Relations Committee (11/12/19)
Letter to Los Angeles City Ethics Commission (5/13/19)
Alliance for Justice opposed a ban on behested payments that would result in a severe impact on the ability of nonprofit organizations to fundraise for legitimate and worthy causes.

Sign On Letter for Census Funding and Outreach (6/3/19)
Alliance for Justice signed onto this letter, led by the Census Policy Advocacy Network (CPAN), thanking the Senate and Assembly budget committees for making census funding a priority.

Comments on Definition of Contributions(3/4/19)
Alliance for Justice submitted comments to the Federal Election Commission on the definition of “contributions” to request the FEC define the scope of “political purposes” to provide greater clarity to tax-exempt organizations engaging in advocacy.

Comments to DHS on Changes to Public Charge (12/12/2018)
Alliance for Justice submitted comments on the Department of Homeland Security’s Notice of Proposed Rulemaking to express our strong opposition to the changes regarding “public charge.”

Comments on Proposed Information Collection on 2020 Census, Docket No. USBC-2018-0005 (8/7/2018)
Alliance for Justice submitted comments on the proposed changes to the 2020 Census, urging the removal of the citizenship question.

Citizens Union Amicus Brief (7/2/2018)
Alliance for Justice joined an amicus brief with Institute for Free Speech in Citizens Union of the City of New York v. The Attorney General of the State of New York, as the challenged law would impose unprecedented burdens on nonprofits.

Parks Foundation Amicus Brief (2/3/2017)
On January 31, 2017, Alliance for Justice and Council on Foundations filed a joint amicus brief in Parks Foundation v. Commissioner of Internal Revenue in the United States Court of Appeals for the Ninth Circuit. The case raises significant yet rarely addressed issues regarding the application of the Internal Revenue Code’s lobbying rules to private foundations and charitable organizations. Click here to read more.

Comments to FPPC on the Definition of Lobbyist (7/19/2016)
Comments submitted to the California Fair Political Practices Commission on the proposed presumption that would apply to individuals who lobby California state government.

AFJ-Muslim Advocates Letter to Attorney General of California (1/25/2016)
Alliance for Justice, together with Muslim Advocates, submitted a letter to the Office of Attorney General of California commenting on proposed regulations to implement the newly upheld requirement for nonprofits doing business in California to file an unredacted copy of Form 990 Schedule B with that office. We expressed concern about the lack of safeguards in place to maintain the confidentiality of donor information.

AFJ-AFJ Action Campaign Letter to New York State Board of Elections (8/8/2014)
Alliance for Justice and the Alliance for Justice Action Campaign submitted a letter to the New York State Board of Elections to comment on the Emergency Regulations issued by the Board of Elections to implement Subpart C of the 2014-2015 New York State Executive Budget, Laws of 2014 (“The Budget Act”). This legislation established a new registration and reporting regime for persons who engage in “independent expenditures” as defined in the statute.

AFJ Letter to California Fair Political Practices Commission(7/16/2014)
Alliance for Justice submitted a letter to the California Fair Political Practices Commission to comment on proposed regulations to implement SB 27, a recently passed law that should allow more nonprofits to engage around state and local ballot measures without having to file complicated campaign finance forms.

AFJ Letter to San Francisco Board of Supervisors Government Audit and Oversight Committee (4/15/2014)
Alliance for Justice submitted a letter to the San Francisco Board of Supervisors expressing concerns regarding proposed changes to San Francisco’s lobbying regulations being considered by the Government Audit and Oversight Committee.

AFJ Letter to the IRS Requesting Immediate Retraction of Erroneous Statement Regarding Judicial and Executive Nominees(3/27/2014)
Alliance for Justice called on the Service to issue an immediate clarification about the treatment of activities to influence executive and judicial appointments and nominations made in the recent Notice of Proposed Rulemaking: Guidance for Tax-Exempt Social Welfare Organizations on Candidate-Related Political Activities. Read blog post.

AFJ In-Depth Comments to the IRS Regarding Notice of Proposed Rulemaking for Social Welfare Organizations and Appendix A (2/28/2014)

AFJ Supports California Bill SB 27 
Alliance for Justice submitted this letter in support of SB 27 currently making its way through the California legislature. SB 27 allows for meaningful public disclosure of the funding of political and ballot measure activity by nonprofit organizations. Yet it manages to do so without unnecessarily burdening legitimate nonprofit organizations that wish to speak out on environmental, economic, social justice, health, access to reproductive care, violence prevention, and other important issues that protect and strengthen the public good. (8/22/2013)

AFJ Second Round of Comments to New York Attorney General Eric Schneiderman
Comments outline our concerns about draft regulations affecting 501(c)(4)s and propose alternatives that advance the goal of transparency, but also allow true membership organizations to continue to their social welfare work. (5/17/2013)

AFJ Comments to New York Attorney General Eric Schneiderman
Comments submitted raising questions about the first draft regulations affecting 501(c)(4)s. (3/6/2013)

AFJ Letter to New York City Campaign Finance Board
AFJ submitted a letter in January 2013 raising concerns about the Campaign Finance Board’s interpretation of “membership communications.”

Comments to Senate Rules Committee on S. 2219 — The DISCLOSE Act 
Comments to the Senate Rules Committee registering concern that new rules created by the DISCLOSE Act would severely curtail issue advocacy by nonprofit organizations. (4/04/2012)

Sign-on Letter to NYC Campaign Finance Board on Independent Expenditure Regulations           
Sign-on letter to New York City Campaign Finance Board  warning of unintended consequences of Independent Expenditures  regulations, including limiting the ability of nonprofits to participate in policy debates. (10/27/2011)

Comments to FPPC on Reporting Contributions to Multi-Purpose Groups            
Comments submitted to the California Fair Political Practices Commission urging a more clear rule for reporting contributions to multi-purpose groups (10/21/11)

One California Pledge signed by AFJ
Sign-on pledge urging California to define a vision for its future that honors the state’s spirit of inclusion and diversity. (9/2011)

Sign-on Letter to UVA about FOIA Requests
Sign-on letter urging the University of Virginia to balance interests in public disclosure against the public interest in academic freedom. (4/14/2011)

Sign-on Letter to Rep Peter King objecting to hearings on radicalization of American Muslims
Sign-on letter to Rep. Peter King objecting to the House Homeland Security Committee’s plans to hold hearings on the “radicalization” of American Muslims. (3/7/2011)

Organizational Sign on Letter in Support of LAANE
Sign-on letter opposing an effort to discredit Los Angeles Alliance for a New Economy. (2011)

Letter to Gov-elect Cuomo supporting Public Financing
Sign-on letter to Governor-elect Andrew Cuomo from national membership organizations urging support for a public financing system in New York. (12/2010)

Comments to FPPC on the Definition of Express Advocacy
Comments submitted to the FPPC on the proposed changes to the definition of express advocacy. (08/12/2010)

Sign-On Letter to Leader Pelosi on DISCLOSE Act
Sign-on Letter to Majority Leader Pelosi expressing opposition to the NRA carve-out provision in the 2010 DISCLOSE Act. (6/16/2010)

Amicus Brief to US Court of Appeals in Support of ACORN
Amius brief on behalf of Alliance of Justice and  others filed with the US Court of Appeals for the Second Circuit to help the Court understand the significance of ACORN and organizational advocacy. (5/21/2010)

Sign-on Letter to HUD on Funding for ACORN Housing Corporation
Sign-on letter to Housing and Urban Development Secretary Shaun Donovan urging continued funding for ACORN Housing Corporation. (12/10/2009)

Standing Up for ACORN Press Statement
Press Release with a Collection of statements by leaders of progressive organizations in support of ACORN. (10/1/2009)

Sign-on Letter to Congress About Estate Tax
Sign-on letter to Congress expressing support for defeating cuts to the estate tax. (5/5/2009)

Amicus Brief to US District Court in opposition to compel third party document production
Amicus brief arguing that subpoenas served upon several pro-choice groups threaten the Constitutional rights of privacy, petition, association, and assembly of public interest organizations. (10/20/2008)

Letter on LSC Reauthorization
Letter urging Congress to lift funding restrictions on private funds given to Legal Service Corporation grantees. (1/2/2009)

Comments to IRS on draft Form 990 Instructions
Comments to IRS in response to request for comments on draft instructions for the newly revised Form 990. (5/30/2008)

Comments to FEC on Electioneering Communications rulemaking
Comments submitted to the FEC regarding the  Notice of Proposed Rulemaking, “Electioneering Communications”. (10/1/2007)

Comments to IRS on redesigned Form 990
Comments to IRS in response to request for comments on the draft redesign of Form 990. (9/14/2007)

Letter to House Expenditure Responsibility requirements for Donor Advised Funds
Comments submitted to the House of Representatives’ Ways and Means Committee regarding expenditure responsibility requirements for Donor Advised Funds. (6/29/2007)

Comments to Treasury on Expenditure Responsibility Requirements for Donor Advised Funds
Letter asking the Department of the Treasury to provide guidance on the expenditure responsibility requirements for Donor Advised Funds. (5/11/2007)

Letter to Senate in support of changes to CFC
AFJ Letter to Senate expressing support for eliminating the overhead requirement for participating in the Combined Federal Campaign. (4/6/2007)

Letter to House in Support of Changes to CFC
Letter to House expressing support for eliminating the overhead requirement for participating in the Combined Federal Campaign. (3/19/2007)

Comments to FEC on Grassroots Lobbying exception to Electioneering Communications
Comments to the FEC urging the issuance of a rule exempting grassroots lobbying from the definition of electioneering communications under the Federal Election Campaign Act (Notice 2006-4). (4/17/2006)

Sign on Letter to House Opposing 527 Reform Act
501(c)(4) Sign on letter urging the House to oppose the 527 Reform Act, legislation designed to effectively abolish “527 organizations”. (4/5/2006)

Comments to FEC on Coordinated Communications Supplemental Rulemaking 2006-5
Comments to the FEC reaffirming the need to avoid chilling nonprofit advocacy rights when defining coordinated communications.  (3/22/2006)

Petition for Rulemaking on Grassroots Lobbying Exemption to Electioneering Communications
Request to the FEC urging a rulemaking to create an exemption for at least some forms of grassroots lobbying from the prohibition on electioneering communications. (2/16/2006)

Comments to FEC on Coordinated Communications Rulemaking 2005-28
Comments to the FEC urging protection of nonprofit advocacy rights when defining coordinated communications. (1/13/2006)

Comments to FEC on Electioneering Communications Rulemaking 2005-20
Comments to the FEC urging an exemption for 501(c)(3) organizations from the electioneering communications prohibition. (9/30/2005)

Comments to FEC on Internet Communications rulemaking
Comments to the FEC in response to proposed rulemaking on how to regulate Internet communications. (6/3/2005)