FEDERAL ELECTION COMMISSION

Washington, DC 

BEFORE THE FEDERAL ELECTION COMMISSION

) 

In the Matter of ) 

) 

Hansjörg Wyss ) 

The Wyss Foundation ) MUR 7904 

Berger Action Fund, Inc. ) 

New Venture Fund ) 

Sixteen Thirty Fund ) 

) 

STATEMENT OF REASONS OF COMMISSIONERS 

SHANA M. BROUSSARD AND ELLEN L. WEINTRAUB 

The Complaint in this matter alleges that Hansjörg Wyss, a foreign national, made 

millions of dollars in prohibited indirect political contributions funneled through his non-profit 

entities, the Wyss Foundation and the Berger Action Fund, Inc., to two related politically active 

non-profit organizations Sixteen Thirty Fund (“STF”) and New Venture Fund (“NVF”), and 

unincorporated projects jointly managed by STF and NVF known as The Hub Project and the 

Hub Education and Engagement Fund. This statement addresses the Complaint’s allegations that 

Wyss provided these funds for election-related purposes and that the Wyss Foundation, the 

Berger Action Fund, NVF, STF, and The Hub Project all should have registered as political 

committees and filed required disclosure reports with the Commission as required by the Federal 

Election Campaign Act of 1971, as amended (the “Act”).

1

 

We voted to dismiss the allegations as to the Wyss Foundation and the Berger Action 

Fund for the reasons set forth in the First General Counsel’s Report of the Commission’s Office 

of the General Counsel (“OGC”).

2 Further, for the reasons set forth below, we voted to dismiss 

the allegations that STF, The Hub Project, NVF, and the Hub Education and Engagement Fund 

failed to register and report as political committees in violation of 52 U.S.C. §§ 30102, 30103, 

and 30104.3 

1 Compl. ¶¶ 6-7 (May 14, 2021). 

2 First Gen. Counsel’s Rpt. at 31; Certification (“Cert.”) ¶ 2.c (July 28, 2022).

3 Cert. ¶ 2 (July 28, 2022). 

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I. FACTUAL BACKGROUND

STF is a 501(c)(4) social welfare organization and states that it works on a variety of

issues, including economic equality, health care, climate, racial justice, and voter access.4 The 

organization spent over $400 million in 2020, including over $60 million in contributions to 

federal political committees5 and more than $250 million in grants to 170 other 501(c)(4) social 

welfare organizations.6

 

NVF is a 501(c)(3) charitable organization that appears to work on a wide range of 

issues, including conservation, global health, international development, education, disaster 

recovery, and the arts.7

 The Response from NVF states that at the end of 2019, NVF managed a 

portfolio of more than $460 million.8

 Among the many projects under NVF’s auspices is the Hub 

Education and Engagement Fund.9 NVF’s response explicitly states that “NVF does not engage 

in any activities to support or oppose candidates for elective office at any level of government.” 

As a 501(c)(3) organization, NVF asserts that it is barred under IRS rules from engaging in 

political activity and specifically denies that it is a political committee.10

STF states that The Hub Project cited in the Complaint is one of “numerous projects 

sponsored by STF,” and is a different project than the “Hub Education and Engagement Fund” 

sponsored by NVF, explaining that they are “two projects that complement one another but are 

sponsored by separate entities.”11

STF states that it spent nearly $73 million on contributions to federal political committees 

and electioneering communications in 2020. STF argues that this amount constituted less than 

4 New Venture Fund and Sixteen Thirty Fund Resp. at 2 (July 7, 2021) (“NVF/STF Resp.”).

5 Id. at 7.

6 IRS Form 990 (Unfiled), Sixteen Thirty Fund, 2020 Return of Organization Exempt from Income Tax, 

Sched. I, Part II (Oct. 29, 2021) [hereinafter STF 2020 Form 990], https://www.sixteenthirtyfund.org/wpcontent/uploads/2021/11/Sixteen-Thirty-Fund-2020-Public-Disclosure-Copy.pdf (copy not available on IRS 

website).

7 NVF/STF Resp. at 2.

8 Id. 

9 Id.; see also Work With Us, HUB PROJECT, https://thehubproject.org/jobs/ (last visited June 27, 2022) (“The 

Hub Education and Engagement Fund is a project of the New Venture Fund, a 501(c)(3) public charity that 

incubates new and innovative public-interest projects and grant-making programs.”). 

10 NVF/STF Resp. at 8-9.

11 Id. at 2 n.1, 6. The Hub Project’s website describes itself as “made up of organizers, communicators, digital 

strategists, creatives, researchers, and operations professionals . . . here to help campaigns and coalitions.” See Our 

Work Is Not About Us, HUB PROJECT, https://thehubproject.org/about/ (last visited June 27, 2022); Work With Us, 

HUB PROJECT, https://thehubproject.org/jobs/ (last visited June 27, 2022). The U.S. Patent and Trademark Office 

lists “The Hub Project” as a trademark registered to NVF. See Trademark Electronic Search System, U.S. PATENT &

TRADEMARK OFF., https://www.uspto.gov/trademarks/search (last visited June 27, 2022) (click “Search out 

trademark database (TESS)” and search “The Hub Project”).

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18% of its overall spending and that in prior years its “FECA disbursements,” which STF 

defined as independent expenditures, electioneering communications, and contributions to 

federal political committees, was an even lower percentage of its overall spending.12 The NVF 

and STF Response includes the following chart depicting STF’s spending from 2016 through 

2020:13

STF states that its overall “campaign spending” reported on its IRS filings – which

appears to include state and local election activity outside the Commission’s jurisdiction – did 

not exceed 25.3% of overall spending between 2016 and 2019; specifically, according to STF, 

the percentage of total local, state, and relevant federal spending compared to overall spending 

for each year was as follows: 18.4% (2016), 1.9% (2017), 25.3% (2018), and 13.4% (2019).14

The Response includes an affidavit from STF’s President verifying the group’s IRS filings and 

providing an estimate of STF’s 2020 total expenditures ($410,616,973).15 

At present, STF’s 2019 and 2020 Form 990s are not available to the public through the 

IRS’s website.16 However, STF’s website hosts what appears to be an unsigned copy of the 

12 NVF/STF Resp. at 6-7.

13 Id. at 8. According to STF’s FEC filings, it spent $12,875,630.64 in federal electioneering communications 

in 2020. FEC Electioneering Communications: Filtered Results, FEC.GOV, https://www.fec.gov/data/electioneeringcommunications/?committee_id=C30002786&committee_id=C30002810&committee_id=C30002844comm

ittee_id=C30003040&committee_id=C30003099&committee_id=C30003164 (last visited June 27, 2022) (showing 

all electioneering communications made by groups or projects controlled by STF).

14 NVF/STF Resp. at 8.

15 Id., Kurtz Aff. ¶ 4.

16 Sixteen Thirty Fund, IRS.GOV, https://apps.irs.gov/app/eos/detailsPage?ein=264486735&name=SIXTEEN 

%20THIRTY%20FUND&city=&state=&countryAbbr=US&dba=&type=COPYOFRETURNS&orgTags=COPYOF

RETURNS (last visited June 27, 2022) (providing available STF tax returns).

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group’s 2020 Form 990, dated October 29, 2021,17 which includes information that appears to 

support the numbers provided by the Response.18 According to this unofficial 2020 Form 990, 

STF discloses spending over $167 million on “political campaign activity expenditures” in 2020, 

including on state-level activity, which represents about 40% of its total spending for the 

calendar year.19 Of the more than $410 million in total expenses, STF spent more than $320 

million making grants to 246 organizations.20 STF lists 246 groups as grant recipients, of which 

the vast majority, measured both in number of recipients and total amounts of funds granted, are 

also social welfare organizations, as reflected in the following table and chart:

Organization 

Type 

Total Grant 

Recipients

Total Value of 

Grants 

Awarded

Highest Grant Average Grant 

Value

501(c)(4) 170 $250,418,705 $128,976,147 $1,473,051

527 38 $53,266,500 $7,700,000 $1,401,750

501(c)(3) 31 $19,573,375 $8,232,242 $631,399

Other 7 $1,333,930 $415,930 $190,561

STF’s President also released a public statement summarizing the group’s activity in 2020, 

stating that STF gave over $61 million to political committees and highlighted its $128 million 

grant to an organization called America Votes “to support their national efforts to expand access 

17 STF 2020 Form 990. OGC also located an unofficial copy of STF’s 2019 form. IRS Form 990, Sixteen 

Thirty Fund, 2019 Return of Organization Exempt from Income Tax, Sched. I, Part II (Nov. 11, 2020) [hereinafter 

STF 2019 Form 990], https://www.documentcloud.org/documents/21085690-sixteen-thirty-fund-2019-990. 

18 Cf. NVF/STF Resp. at 7.

19 STF 2020 Form 990, Sched. C, Part I-A, line 2.

20 STF 2020 Form 990, Part I, line 18; id. Part IX, line 1; id., Sched. I. 

6%

77%

16%

1%

501(c)(3) 501(c)(4) 527s Other

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to vote by mail and increase voter turnout in communities of color and among traditionally 

disenfranchised people.”21 

II. LEGAL ANALYSIS

 The Complaint argues that Wyss made large indirect contributions through the Wyss 

Foundation and the Berger Action Fund, which were ultimately provided to STF, NVF and The 

Hub Project for election related purposes.22 Specifically, the Complaint argues that this money 

was funneled through The Hub Project. 23 According to the Complaint, The Hub Project has 

received approximately $56.5 million from the Wyss Foundation since 2007 and has been active 

in political campaigns by controlling the flow of money to other entities, including to Change 

Now, an independent expenditure-only political committee registered with the Commission that 

The Hub Project purportedly controls.24 Respondents Wyss, the Wyss Foundation, and the 

Berger Action Fund state that any grants made through these organizations were accompanied by 

restrictive covenants providing that the grants could not be used for electoral purposes.25

Respondents NVF and STF state that they complied with the grants’ terms and conditions and 

did not use the funds toward election-related expenses.

26 NVF denies engaging in any political 

activity, and STF states that the extent of its election-related activity does not make it a political 

committee.27 

A. Determining Political Committee Status

The Act and Commission regulations define a “political committee” as “any committee, 

club, association, or other group of persons that receives contributions aggregating in excess of 

$1,000 during a calendar year or which makes expenditures aggregating in excess of $1,000 

during a calendar year.”28 In Buckley v. Valeo,

29 the Supreme Court held that defining political 

committee status “only in terms of [the] amount of annual ‘contributions’ and ‘expenditures’” 

21 Amy Kurtz, Progressive Philanthropy Answered the Call in 2020, MEDIUM (Nov. 17, 2021), [hereinafter 

Kurtz Medium Post] https://amy-kurtz.medium.com/progressive-philanthropy-answered-the-call-in-2020-

57f038a6a5d2. 

22 Compl. ¶ 23 (citing Kenneth P. Vogel, Swiss Billionaire Quietly Becomes Influential Force Among 

Democrats, N.Y. TIMES (May 3, 2021), https://www.nytimes.com/2021/05/03/us/politics/hansjorg-wyss-moneydemocrats.html). 

23 See Compl. ¶¶ 14-21. 

24 Compl. ¶¶ 18-19, 21. 

25 Hansjörg Wyss, the Wyss Foundation, and the Berger Action Fund, Inc., Resp. at 1-2 and 6-8 

(July 7, 2021). 

26 NVF/STF Resp. at 3, 9-10. 

27 Id. at 3, 5-9.

28 52 U.S.C. § 30101(4)(A); 11 C.F.R. § 100.5. 

29 424 U.S. 1 (1976) (per curiam).

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might be overbroad, reaching “groups engaged purely in issue discussion.”30 To cure that 

infirmity, the Court concluded that the term “political committee” “need only encompass 

organizations that are under the control of a candidate or the major purpose of which is the 

nomination or election of a candidate.”31 Under the statute as thus construed, an organization that 

is not controlled by a candidate must register as a political committee only if it (1) crosses the 

$1,000 threshold and (2) has as its “major purpose” the nomination or election of federal 

candidates. 

Although Buckley established the major purpose test, it provided no guidance as to the 

proper approach to determine an organization’s major purpose.32 After Buckley, the Commission 

adopted a policy of determining on a case-by-case basis whether an organization is a political 

committee, including whether its major purpose is the nomination or election of federal 

candidates.33 The Commission decided that determining an organization’s major purpose 

“requires the flexibility of a case-by-case analysis of an organization’s conduct that is 

incompatible with a one-size-fits-all rule,” and that “any list of factors developed by the 

Commission would not likely be exhaustive in any event, as evidenced by the multitude of fact 

patterns at issue in the Commission’s enforcement actions considering the political committee 

status of various entities.”34 

To determine an entity’s “major purpose,” the Commission considers a group’s “overall 

conduct,” including, among other factors, public statements about its mission, organizational 

documents, and government filings (e.g., IRS filings), and the proportion of spending related to 

“Federal campaign activity (i.e., the nomination or election of a Federal candidate).”35 With 

respect to such comparative spending, the Commission has stated that it compares how much of 

an organization’s spending is for “federal campaign activity” relative to “activities that [a]re not 

campaign related.”36 A district court has concluded that electioneering communications 

30 Id. at 79. 

31 Id. 

32 See, e.g., Real Truth About Abortion, Inc. v. FEC (formerly Real Truth About Obama v. FEC), 681 F.3d 

544, 556 (4th Cir. 2012), cert. denied, 568 U.S. 1114 (Jan. 7, 2013) (No. 12-311) (“RTAA”) (“Although Buckley did 

create the major purpose test, it did not mandate a particular methodology for determining an organization’s major 

purpose.”).

33 See, e.g., Independent Expenditures; Corporate and Labor Organization Expenditures, 57 Fed. Reg. 33,548, 

33,558-59 (July 29, 1992) (Notice of Proposed Rulemaking); Definition of Political Committee, 66 Fed. Reg. 

13,681, 13,685-86 (Mar. 7, 2001) (Advance Notice of Proposed Rulemaking); see also Summary of Comments and 

Possible Options on the Advance Notice of Proposed Rulemaking on the Definition of “Political Committee,” 

(Sept. 12, 2001), https://sers.fec.gov/fosers/showpdf.htm?docid=5684; Cert. (Sept. 27, 2001) (voting 6-0 to hold 

proposed rulemaking in abeyance), https://sers.fec.gov/fosers/showpdf.htm?docid=5669. 

34 Political Committee Status, 72 Fed. Reg. 5595, 5602 (Feb. 7, 2007) (Supplemental Explanation and 

Justification) [hereinafter Supplemental E&J].

35 Id. at 5597, 5605. 

36 Supplemental E&J at 5597, 5605-06. This approach was subsequently challenged and upheld in federal 

district court. See Shays v. FEC, 511 F. Supp. 2d 19 (D.D.C. 2007). In 2012, in RTAA, the Fourth Circuit upheld the 

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“presumptively” indicate a purpose of nominating or electing a candidate, and thus that in a prior 

matter it was contrary to law for a controlling group of Commissioners to categorically exclude 

non-express advocacy in a Commission analysis of the major purpose of the entity at issue.

37 

Political committees must comply with certain organizational and reporting requirements 

set forth in the Act. They must register with the Commission, file periodic reports for disclosure 

to the public, appoint a treasurer who maintains its records, and identify themselves through 

“disclaimers” on all of their political advertising, on their websites, and in mass emails.

38

B. Commission Precedent Does Not Support Finding Reason to Believe That

Respondents STF and The Hub Project Are Political Committees

1. Statutory Spending Threshold

 STF, through The Hub Project and its other initiatives, appears to have met the first part

of the test for political committee status, the statutory spending threshold.39 To assess whether an 

organization has made an “expenditure” for purposes of the statutory spending threshold, the 

Commission analyzes whether spending on any of an organization’s communications made 

independently of a candidate constitutes express advocacy under 11 C.F.R. § 100.22.40 In 2020, 

STF provided almost $6 million to Change Now, the independent expenditure-only political 

Commission’s case-by-case approach in the face of a constitutional challenge. See 681 F.3d 544; see also Free 

Speech v. FEC, 720 F.3d 788 (10th Cir. 2013) (quoting RTAA and upholding Commission’s case-by-case method of 

determining political committee status), cert. denied, 572 U.S. 1114 (2014). 

37 See Citizens for Resp. & Ethics in Wash. v. FEC, 299 F. Supp. 3d 83, 93 (D.D.C. 2018) (“CREW II”) 

(determining that the Commission “must presumptively treat spending on electioneering ads as indicating a purpose 

of nominating or electing a candidate”); see also id. at 100 (“The Commission may in special circumstances 

conclude that an electioneering ad does not have [an election-related major] purpose. But given Congress’s 

recognition that the ‘vast majority’ of electioneering ads have the purpose of electing a candidate, the Commission’s 

exclusion of electioneering ads from its major-purpose analysis should be the rare exception, not the rule.”). Citizens 

for Resp. & Ethics in Wash. v. FEC, 209 F. Supp. 3d 77, 93 (D.D.C. 2016) (“CREW I”) (stating that it is improper to 

“exclude from . . . consideration all non-express advocacy in the context of disclosure”). See also, Factual & Legal 

Analysis at 9, 15, MUR 6538R (Americans for Job Security, et al.) (noting the court’s instruction “to look beyond 

express advocacy,” the Commission considered the group’s spending on both independent expenditures and 

electioneering communications as part of the major purpose analysis).

38 See 52 U.S.C. §§ 30102-30104; 11 C.F.R. § 110.11(a)(1).

39 52 U.S.C. § 30101(3) (defining political committee as “any committee, club, association, or other group of 

persons which receives contributions, aggregating in excess of $1,000 during a calendar year or which makes 

expenditures aggregating in excess of $1,000 during a calendar year”). 

40 Supplemental E&J at 5606.

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committee allegedly under the direct control of The Hub Project.41 STF also spent $114,100 on 

independent expenditures in 2018 through other organizations.42 

2. Major Purpose

Having determined that STF has met the statutory spending threshold for being a political 

committee, the Commission next applies the second part of the test: whether STF’s “major 

purpose” is the nomination or election of a candidate. As set forth above, the Commission makes 

the major-purpose determination on a case-by-case basis. Historically, the Commission has 

considered several factors, including the organization’s public statements and the proportion of 

its spending on federal election activities relative to other spending.43 

In this case, STF’s and The Hub Project’s public statements do not support the allegation 

that these Respondents’ major purpose is the nomination or election of federal candidates. STF’s 

website describes its mission broadly as “Empowering Progressive Changemakers” and 

identifies a wide variety of specific issue initiatives, pertaining, for example, to health care; 

social, racial, and economic justice; climate change; voting access; and civic participation.

44

Likewise, a public statement from STF’s President discusses STF’s “mobiliz[ation]” in 2020 to 

face issues such as “a global pandemic, a long-overdue reckoning with racial justice, and a 

climate crisis.” This statement acknowledges giving “over $61 million to political committees”

during “the most consequential election of our lives,” but also noted the organization’s more 

extensive spending on state and local ballot measures, Supreme Court reform, lobbying for 

legislative change, and ensuring access to voting during the pandemic.45 The few public 

statements about STF in the record, taken as a whole, seem to reflect a general purpose of 

supporting and facilitating voting and advocacy pertaining to progressive issues, and less so the 

purpose of electing specific federal candidates. 

41 See supra page 5; STF 2020 Form 990 at Sched. C, Part IV. In 2019, STF gave $25,000 to Change Now.

STF 2019 IRS Form 990 at Sched. I, Part II. 

42 STF spent $548,228.80 in independent expenditures in 2016 through Sixteen Thirty Fund/Make it Work 

America1 and Sixteen Thirty Fund/Make it Work America Action, along with other projects. See FEC Independent 

Expenditures: Filtered Results, FEC.GOV, https://www.fec.gov/data/independent-expenditures/?data_type= 

processed&most_recent=true&committee_id=C90016320&committee_id=C90016338&committee_id=C90017484

&committee_id=C90017922&committee_id=C90018102&committee_id=C90018110&is_notice=false (last visited 

June 27, 2022) (showing all independent expenditures made by entities associated with STF).

43 Supplemental E&J, 72 Fed. Reg at 5605.

44 See SIXTEEN THIRTY FUND, https://www.sixteenthirtyfund.org/ (last visited June 27, 2022) (stating that 

STF “empower[s] progressive changemakers”); About Us, SIXTEEN THIRTY FUND, https://www.sixteenthirtyfund.

org/about-us/ (last visited June 27, 2022) (quoting STF President as stating “[W]e have a responsibility to mobilize 

in the face of societal challenges and provide new investments and initiatives to advocate for what we believe in—

from addressing climate change, to protecting voting rights and access to health care, to promoting equity and social 

justice”).

45 Kurtz Medium Post.

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Turning to comparative spending, the available information about STF’s spending falls 

short of the necessary showing that STF’s major purpose is the nomination or election of a 

federal candidate under the analysis applied in prior Commission matters. STF’s Response states 

that in 2020 it spent only 17.75% of its overall budget giving directly to federal political 

committees and making independent expenditures and electioneering communications, which is 

far below the level of comparative spending found in cases in which the Commission has voted 

to proceed.

46 

The available information does indicate that some of the social welfare organizations to 

which STF made substantial grants themselves engaged in making contributions to political 

committees and making independent expenditures or electioneering communications. 

Now, if the Commission were to impute every penny of the grant recipients’ spending on 

contributions, independent expenditures, and electioneering communications to STF, STF’s 

relevant 2020 spending percentages could approach spending levels that the Commission has 

concluded satisfy the major purpose test.47 But the information before the Commission does not 

establish the degree to which STF’s grants supported this activity. 

More importantly, the Commission has not previously considered the spending of an 

organization’s grantees in establishing whether the organization itself met the major purpose test. 

Rather, the Commission to date, has examined only the organization’s own direct contributions, 

expenditures, and relevant communications.48 We voted to abide by those precedents here; the 

Commission cannot retroactively hold respondents to a standard in the enforcement context that 

they could not have previously divined. These Respondents appear to have comported their 

conduct with the guidance previously issued by the Commission. Considering only such direct 

spending, we do not believe that the record before us justifies pursuing this complaint. 

46 NVF/STF Resp. at 7. See, e.g., F&LA at 8-10, MUR 7465 (Freedom Vote, Inc.) (finding reason to believe 

where an organization’s campaign activity constituted 61% of total expenditures one year, and nearly 47% over the 

span of two later years, with an open question about accounting irregularities in those years); F&LA at 15, 

MUR 6538R (Americans for Job Security, et al.) (“More than half of [AJS’s total spending] was for independent 

expenditures . . . and the electioneering communications analyzed above . . . . The Commission has never set a 

threshold on the proportion of spending on major purpose activities required for political committee status and 

declines to do so now. Without determining whether it is necessary to cross a 50 percent threshold to determine an 

organization’s major purpose, it is sufficient in this case, based on the available information, to find reason to believe 

that AJS’s major purpose had become the nomination or election of federal candidates.” (emphasis in original)). See 

also, Supplemental E&J, 72 Fed. Reg. at 5605 (providing three examples of organizations whose major purpose was 

federal campaign activity where the organizations respectively spent 91%, 50-75%, and 68% of their budgets on 

federal campaign activity). 

47 First Gen. Counsel’s Rpt. at 22, 26-28, 29. This theory formed the basis of OGC’s recommendation that 

the Commission find reason to believe that STF was a political committee.

48 See, e.g., MUR 7465 (Freedom Vote, Inc.) (examining spending on independent expenditures and direct

contributions); F&LA at MUR 6538R (Americans for Job Security, et al.) (examining spending on independent

expenditures and electioneering communications). 

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We are not oblivious to the concern that an organization could avoid political committee 

status by funneling its funds through successive organizations, each of which spent just under 

half of its funds on direct campaign advocacy and then passed along the rest to another 

organization that repeated the process until substantially all of the original funds were spent on 

direct advocacy through multiple steps in the chain.49 We believe that this is an analysis that the 

Commission could and should engage in going forward. 

In sum, the record before us does not contain compelling statements attributable to STF 

reflecting a major purpose of nominating or electing candidates. Furthermore, the available

financial information is insufficient to support a conclusion that STF’s own spending reflects a 

purpose of nominating or electing a candidate. Accordingly, under the Commission’s prior 

guidance, there is insufficient information in the record before us to find reason to believe that 

Sixteen Thirty Fund should have registered and reported as a political committee. Similarly, the 

record lacks information supporting reason to believe that The Hub Project or the Hub Education 

and Engagement Fund should have registered and reported as political committees. Accordingly, 

we voted to dismiss the allegations that Respondents violated 52 U.S.C. §§ 30102, 30103, and 

30104. 

Moving forward, the regulated community should take note that we will consider the 

grantmaking of alleged political committees to be a relevant criterion when considering an 

entity’s major purpose. 

September 1, 2022

___________________________

Shana M. Broussard 

Commissioner

___________________________ 

Ellen L. Weintraub

Commissioner

49 After only five rounds of groups spending 49% on direct advocacy and passing the rest along to the next 

group, 97% of the initial sum would be spent on direct advocacy.

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