To the members of the Commission to Investigate Public Corruption:
Over the last few weeks, the commission has heard many useful and appealing recommendations for combating corruption and improving public trust in state government. We fully support many of these ideas, but want to ensure that you do not lose sight of the fundamental problem of both legal and illegal corruption in Albany: the “show me the money” culture that permeates state politics.
The members of the Commission have a once-in-a-generation opportunity to address the corrupting nature of New York’s broken campaign finance system and the crisis of public trust it engenders. It is critical that the Commission take bold action and push for transformative polices that include comprehensive campaign finance reform.
Although each of our groups has additional recommendations for improving governance and integrity in Albany, we are unanimous that all of the following elements are essential for comprehensive reform and meaningful change in Albany, and urge you to ensure that the following elements of comprehensive campaign finance reform are part of your ongoing investigations, discussions and recommendations:
- Limited matching funds for small donations. A voluntary program for candidates that matches small donations – $175 or less – from natural persons residing in New York State with public funds will encourage small donors to contribute and participate in the electoral process. This new means of financing a campaign will make running for public office more attractive to a larger pool of possible candidates. And once elected, a publicly financed office holder would not be beholden to special interests and large donors. A similar system of matching small donations has been in place for more than twenty years in New York City and has earned strong support among voters and candidates alike.
- Independent and robust enforcement. New York State’s enforcement of campaign finance laws is notoriously lax, leading to corruption and abuses of the system. We need a new, independent oversight and enforcement body with strong effective responsibility for all campaign finance law administration including public financing.
- Reasonable contribution limits. New York State’s soft money loopholes and exorbitant contribution limits encourage politicians and parties to seek huge funds from their contributors. We need to set reasonable hard money limits on contributions that will allow citizens to show their political support without being shaken down for unlimited donations, and close the “housekeeping” loophole which allows unlimited contributions of soft money. We should close the LLC loophole by treating LLCs as corporations rather than individuals, and treat contributions from non-political accounts of affiliated unions, LLCs, LLPs, and corporations as coming from a single source. Finally, we must protect against “pay-to-play” by reducing contribution limits for lobbyists and contractors doing business with the state, and by declining to provide public matching funds for contributions by lobbyists and contractors.
- Disclosure of campaign contributions and political expenditures. As a result of the Citizens United decision, tens of millions of dollars in political spending are hidden from public view. Transparency is an essential principle of free and competitive markets. The rise of Super PACs during the 2012 election cycle makes this reform even more urgent. We should require disclosure, including names and addresses of employers, from bundlers.
Having worked on these issues for many years, we understand that getting Albany to adopt comprehensive campaign finance reform is no easy task. But your commission, specifically established to serve as an independent and forceful voice for restoring public trust in government, can help make it possible by including in your report a bold and declarative set of proposed actions in support of campaign finance reform to be taken up and passed by the legislature upon their return. Not including a bold prescription for campaign finance reform will almost certainly allow politicians in Albany to continue to ignore the public call for change.
Please let us know how we can be of assistance in the coming weeks and months.
Dick Dadey, Executive Director
Russ Haven, Esq., Legislative Counsel
New York Public Interest Research Group, Inc.
Susan Lerner, Executive Director
Common Cause New York
Bill Mahoney, Research Coordinator
New York Public Interest Research Group, Inc.
Lawrence Norden, Deputy Director Democracy Program
Brennan Center for Justice
Sally Robinson, President
 Our groups support additional campaign finance reforms, including those listed in the attached document. We view the items listed in the text of this letter as the most critical reforms.