For example, Disney is a member of the RATE Coalition, a social welfare group that was reportedly “preparing a seven-figure digital advertising campaign” as part of a “massive lobbying blitz” against raising corporate taxes.15
· Disney disclosed giving the California Taxpayers Association (CTA) $500,000 in political contributions in 2020. CTA is a social welfare group that lobbies in California, spending $110,631 on lobbying in 2020.16 Disney’s CTA involvement in Anaheim politics has drawn scrutiny. 2016 press reports noted that “Disney’s money follows a complicated path — typically flowing from group to group with names like “Orange County Freedom Fund” and “California Taxpayers Association,” before being spent on mailers that bear no trace of Disney’s sponsorship.17
· Disney also reportedly supports another social welfare group, Support Our Anaheim Resort Area, known as SOAR, that was founded in 2007 with backing from Disney in part to fight a housing development proposed near its resort, with Disney reportedly giving SOAR $2.1 million at that time.18
· Disney’s trade association membership in Associated Industries of Florida (AIF) has attracted media scrutiny in the ongoing Florida dark money scandal involving a social welfare group, Let’s Preserve the American Dream (LPTAD). LPTAD gave $1.15 million in 2020 to “Grow United Inc.,” another nonprofit that in turn provided more than half a million dollars that was used to fund “ghost” candidates in Florida senate races. LPTAD “has extensive ties to Associated Industries of Florida, the corporate-lobbying group whose biggest donors include … Walt Disney World.”19 LPTAD, which was originally named “Associated Industries for America’s Future” is run out of AIF’s Tallahassee headquarters by a former AIF vice president.20 Shareholders have no way to know if Disney made contributions to Let’s Preserve the American Dream, because Disney fails to provide disclosure of its contributions to social welfare groups.
Trade Association Blind Spot
· Corporations make payments to trade associations that are used lobby indirectly on their behalf without specific disclosure or accountability. Trade associations spend hundreds of millions to lobby. For example, the US Chamber of Commerce has spent more than $1.7 billion since 1998.21
· Disney shareholders face a trade association blind spot, as Disney fails to disclose a closed top limit for its trade association payments. Its 2020 trade association disclosure notes Disney belonged to three trade associations which received more than $500,000 in dues. All a reader can tell here is that these organizations received over $500,000. There is no way for a reader to know whether these trade associations received $500,001, $1,000,000 or $5,000,000 in dues. You don’t know, and that’s the problem for shareholders. It is also unclear whether this disclosure captures any payments in addition to dues made to trade associations, or the portions of these payments used for lobbying.
For example, Disney serves on the board of the National Association of Broadcasters, which spent $9,220,000 on lobbying in 2020,22 yet all a reader can tell is that Disney gave this group more than $500,000 and 100 percent of this unknown amount was used for lobbying. And Disney serves on the board of NCTA - The Internet & Television Association, which spent $15,460,000 on lobbying in 2020,23 yet a reader can only tell that Disney gave NCTA more than $500,000 and 24 percent of this amount was used for lobbying.
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Disney’s membership in certain trade associations also has significant indirect impact. For example, the Chamber is a member of the American Legislative Exchange Council (ALEC), serving on its Private Enterprise Advisory Council.28
· ALEC has attracted negative attention for its role in promoting bills that undermine regulations to address issues like climate change, workplace safety and workers’ rights. More recently it has drawn attention for “numerous ties to the Capitol insurrection and Big Lie” challenging the validity of the election results,29 as well as promoting voter suppression30 and critical race theory.31
· Even before the riots, ALEC drew negative scrutiny for putting brand reputations at risk when a lawyer associated with it was involved in a phone call President Trump made to Georgia Secretary of State Brad Raffensperger in an attempt to overturn election results.32
https://www.sec.gov/Archives/edgar/data/1699865/000121465922001877/j23223px14a6g.htm
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