CHANGE Illinois Action Fund testifies in support of nonprofit lobbying fee exemptions

CHANGE Illinois Action Fund Testimony:

Support HB4266 to level the playing field for small nonprofits

April 9, 2024

Illinois House Ethics and Elections Committee

To: Chair Maurice West, Vice-Chair Katie Stuart, Republican Spokesperson Patrick Windhorst and members

From: Ryan Tolley, Executive Director, CHANGE Illinois Action Fund


Thank you Chair West, Vice-Chair Stuart, Republican Spokesperson Windhorst, and committee members for providing me with the opportunity to submit written testimony on HB4266, to provide a lobbying fee waiver for small 501(c)(3) nonprofits. My name is Ryan Tolley and I am the executive director of the CHANGE Illinois Action Fund and CHANGE Illinois. Both are nonpartisan nonprofits that champion equitable democracy, ethics and efficiency in government and elections in Illinois. Through research, education and advocacy, we work to achieve an Illinois with ethical and efficient governments, including fair maps and ballots and vibrant elections.

I am writing on behalf of CHANGE Illinois Action Fund to advocate for the passage of HB4266. 


We believe that the legislation, HB4266, is a good step forward to ensure that small nonprofits in the state of Illinois are not limited by financial constraints to have a say, on behalf of their communities, in what happens in state government. While the $300 fee may not seem like a lot, it can quickly add up as many nonprofits may have a large portion or all of their staff meeting with elected officials to advocate on behalf of their communities. Oftentimes, at small nonprofits, all employees wear multiple hats and need to do a bit of everything. But, with the fees associated with lobbying they may have to limit the amount of people that can do activities that are defined as lobbying. This is keenly felt when organizations try to plan “advocacy days” in the state capitol and certain staff must be limited in the types of interactions they have if they are not registered as a lobbyist. 

I do feel compelled to also mention that our organization’s lobbying is done through our 501(c)(4) nonprofit, and, therefore, our organization would not qualify for the exemption that is being considered as it is strictly tied to 501(c)(3) nonprofits. 

Additional recommendations

In addition to the fee waiver, we would recommend that the committee considers providing activity reporting waivers for small nonprofits that do not have reportable expenses. Many nonprofits, whether out of principle or financial constraints, don’t make any expenditures that are required to be reported by the Illinois Lobbyist Registration Act. Regardless, those nonprofits are still required to submit activity reports twice a month. 

Unfortunately, it is very common for small nonprofits to mistakenly miss a reporting deadline and be hit with late filing fees. In order to ensure that small nonprofits are not also financially burdened for missing these frequent deadlines, we recommend that the state exempt nonprofits, who have not reported any expenditures in a year’s time, from filing activity reports. 

A different approach could be mirroring the frequency of the activity reports that are required by the City of Chicago. Instead of requiring reports to be filed every two weeks, the state could require that activity reports are due every quarter and give a longer window to lobbyists to file those quarterly reports. That would give more flexibility and not provide overly burdensome reporting requirements on small nonprofits with limited staffing resources. 

Thank you for your consideration of our recommendations. Please don’t hesitate to reach out if you have any questions regarding our written testimony. 

Best regards, 

Ryan Tolley 

Executive Director

CHANGE Illinois Action Fund