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CCA - Political Activity and Lobbying Report, 2012

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10 Burton Hills Boulevard
Nashville, TN 37215

Political Activity
and Lobbying

POLITICAL
ACTIVITY
REPORT

Report 2012
Transparency is a critical part of the relationships we have with our
government partners and the taxpayers we ultimately serve, as
well as our shareholders, and we are committed to transparency
regarding our government relations and political efforts. In addition
to complying with applicable disclosure laws, CCA is going a step
further to produce this annual report, which we believe will bring
further clarity to our activities. We believe it is the right thing
to do for our business, our partners and our shareholders.
CCA’s political and government relations activities are designed
to educate federal, state and local officials on the benefits of
partnership corrections, CCA’s ability to assist them in meeting
their corrections needs and our track record of success. Our
company does not, under longstanding policy, lobby for
or against policies or legislation that would determine the
basis for an individual’s incarceration or detention.

America’s Leader in
Partnership Corrections
1		

CCA Political Activity and Lobbying Report 2012

Jan. 1, 2012 – Dec. 31, 2012

10 Burton Hills Boulevard
Nashville, TN 37215

Overview
Corporate funds are used to make political contributions where allowed by law
and where management has determined that such contributions will be an
effective use of the funds. CCA also sponsors a political action committee (CCA
PAC) that makes contributions to federal candidates and to candidates in certain
jurisdictions where contributions with corporate funds are not allowed.

POLITICAL
ACTIVITY
REPORT

CCA’s political contributions and lobbying activities are subject to robust
oversight, approval and compliance procedures. Political contributions
using corporate funds require approval by our Chief Executive Officer,
Chief Development Officer or a Vice President Partnership Relations
and, for compliance purposes, the Office of General Counsel.
Government relations engagements and expenditures require Vice Presidentlevel or above approval. The Office of General Counsel and external compliance
experts provide support for the company’s reporting and other compliance
obligations, as well as periodic compliance training for internal partnership
development personnel and contract government relations professionals.
The Nominating and Governance Committee of CCA’s Board of Directors
provides Board -level oversight of the Company’s political and government
relations activities and compliance procedures. Compliance policies and
procedures are addressed in CCA’s Code of Ethics and Business Conduct
and in greater detail in our “Government Relations” policy *.
CCA’s government relations activities are focused on government actions (legislative,
regulatory and executive) that impact the construction and operation of privately
operated prisons and detention facilities. The disclosures in the lobbying reports
filed by the company under the Federal Lobbying Disclosure Act of 1995, as
amended by the Honest Leadership and Open Government Act of 2007 (“LDA”),
are representative of the types of matters on which the company lobbies. As stated
in CCA’s most recent LDA report,** and as a matter of longstanding corporate
policy and practice, CCA does not lobby for or against policies or legislation that
would determine the basis for an individual’s incarceration or detention.

* http://phx.corporate-ir.net/External.File?item=UGFyZW50SUQ9NjExMjN8Q2hpbGRJRD0tMXxUeXBlPTM=&t=1
** http://disclosures.house.gov/ld/ldxmlrelease/2013/Q1/300555796.xml
2		

CCA Political Activity and Lobbying Report 2012

America’s Leader in
Partnership Corrections
Jan. 1, 2012 – Dec. 31, 2012

Political Contributions
10 Burton Hills Boulevard
Nashville, TN 37215

Table A-1

Totals by Source of Funds			 2012
Combined - Corporate and CCA PAC .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . .  .  .  .  .  . $956,135.86
Corporate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . $773,275.86
CCA PAC.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . $182,860.00

Totals by Recipient Category (Source in Parenthesis)
	 Federal Candidates, Parties & Committees (CCA PAC)	


$177,100

	 State Candidates, Parties & Committees (Combined)	


$407,960

	 National 527 (Corporate)	

$366,500

	 Local Candidates (Corporate)

$4,575.86

POLITICAL
ACTIVITY
REPORT

Table A-2

	

State	

Type	

CCA-PAC 	

CCA	

AL	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  2,500
	
AL Total.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 2,500
CA	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  9,500 .  .  .  .  .  .  .  .  .  72,000
	
Candidate (Local).  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . .  .  .  .  .  .  .  .  .  .  . 500
	
Political Committeee.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  5,000 .  .  .  .  .  .  .  .  .  80,000
	
Political Party. . . . . . . . . . . . . . . . . . . . . . . . . ..  .  .  .  .  .  .  .  . 30,000
	
Ballot Measure.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . .  .  .  .  .  .  .  .  . 50,000
	
CA Total	
14,500 	
232,500
CO	
	

Political Committee .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 24,050
CO Total		
24,050

DC	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . .  .  .  .  .  .  .  .  .  . 1,000
	
DC Total		
1,000
FL	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . .  .
	
Candidate (Local).  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . .  .
	
Political Committee .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .
	
Political Party. . . . . . . . . . . . . . . . . . . . . . . . . ..  .
	
FL Total		

 .
 .
 .
 .

 .
 .
 .
 .

 .
 .
 .
 .

 .
 .
 .
 .

 .
 .
 .
 .

 .
 .
 .
 .

 .
 .
 .
 .

 . 3,500
 . 1,750
16,000
20,000
41,250

GA	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  6,000 .  .  .  .  .  .  .  .  .  19,250
	
Candidate (Local).  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . .  .  .  .  .  .  .  .  .  . 1,076
	
Political Committee .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 3,500
	
GA Total	
9,500 	
20,326
ID	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . .  .  .  .  .  .  .  .  .  . 7,250
	
Political Committee .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 2,250
	
ID Total.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . .  .  .  .  .  .  .  .  .  . 9,500
IN	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  2,500 .  .  .  .  .  .  .  .  .  . 5,000
	
IN Total	
2,500 	
5,000
KS	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  1,000
	
Political Committee .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 2,500 .  .  .  .  .  .  .  .  .  . 2,000
	
KS Total	
3,500 	
2,000
KY	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  10,000
	
Political Committee .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 5,000
	
Political Party. . . . . . . . . . . . . . . . . . . . . . 2,000
	
KY Total	
17,000 	
MA	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  2,500
	
MA Total	
2,500

3		

CCA Political Activity and Lobbying Report 2012

America’s Leader in
Partnership Corrections
Jan. 1, 2012 – Dec. 31, 2012

Political Contributions (continued)
10 Burton Hills Boulevard
Nashville, TN 37215

Table A-2 (continued)

	

State	

Type	

CCA-PAC 	

CCA	

MS	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  2,000 .  .  .  .  .  .  .  .  .  .  .  800
	
MS Total	
2,000 	
800
MT	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  7,260
	
Political Party. . . . . . . . . . . . . . . . . . . . . . 1,100
	
MT Total	
8,360 	
NV	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  6,000
	
NV Total	
6,000 	

POLITICAL
ACTIVITY
REPORT

NM	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  2,000 .  .  .  .  .  .  .  .  .  . 9,500
	
NM Total	
2,000 	
9,500
NC	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  500
	
NC Total	
500 	
ND	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  2,500
	
ND Total	
2,500 	
OH	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  4,000
	
Political Committee .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 24,500
	
OH Total	
28,500 	
OK	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  1,000
	
OK Total	
1,000 	
PR	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  2,500
	
PR Total	
2,500 	
SC	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . .  .  .  .  .  .  .  .  .  . 3,500
	
Political Committee .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 2,500 .  .  .  .  .  .  .  .  .  .  .  .  .  .
	
SC Total	
2,500 	
3,500
TN	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  14,000 .  .  .  .  .  .  .  .  .  28,100
	
Candidate (Local).  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . .  .  .  .  .  .  .  .  .  . 1,250
	
Political Committee .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 8,500 .  .  .  .  .  .  .  .  .  . 4,000
	
Political Party. . . . . . . . . . . . . . . . . . . . . . . . . ..  .  .  .  .  .  .  .  . 20,000
	
TN Total	
22,500 	
53,350
TX	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  6,000 .  .  .  .  .  .  .  .  .  .  .  .  .  .
	
Political Committee .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 8,500 .  .  .  .  .  .  .  .  .  .  .  .  .  .
	
TX Total	
14,500 	
VA	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  4,500 .  .  .  .  .  .  .  .  .  . 1,000
	
VA Total	
4,500 	
1,000
VT	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . .  .  .  .  .  .  .  .  .  . 1,200
	
Political Committee .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  . 1,800
	
VT Total		
3,000
WI	Candidate.  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  .  3,500 .  .  .  .  .  .  .  .  .  .  .  .  .  .
	
WI Total	
3,500 	
	
National Parties		
30,000 	
	

National 527’s		

366,500

	

GRAND TOTAL	

773,276

182,860 	

America’s Leader in
Partnership Corrections
4		

CCA Political Activity and Lobbying Report 2012

Jan. 1, 2012 – Dec. 31, 2012

527 Organizations
CCA contributed to the following national 527 organizations in 2012:
•	 Democratic Governors Association

10 Burton Hills Boulevard
Nashville, TN 37215

•	 Republican Governors Association
•	 Republican State Leadership Committee
The aggregate total of contributions to these organizations
is included in the summary data listed above.
Additional information regarding recipient candidate and political committees,
as well as the laws, rules and regulations applicable to political contributions by
corporations and corporate affiliated political action committees, is available
publicly through Internet sites maintained by the relevant Federal (i.e., the
Federal Election Commission and Internal Revenue Service websites, www.
fec.gov and www.irs.gov) and state agencies (e.g., www.sos.ca.gov).

POLITICAL
ACTIVITY
REPORT

Lobbying Information
CCA retains the services of consultant government relations professionals in
jurisdictions where it does or may in the future do business. CCA employees also
register as lobbyists in jurisdictions where their activities meet the statutory definition.
The list below shows CCA’s consultant registered lobbyists in 2012 by jurisdiction.
Table B-1

Jurisdiction	
	

Firm Name

Jurisdiction	

Federal	
Akin Gump Strauss Hauer & Feld LLP	
	
Mehlman Vogel Castagnetti, Inc.	
	
McBee Strategic Consulting, LLC	
		
	
Alabama	
Capitol Resources LLC	
		
Arizona	
Policy Development Group Inc.	
	
Molera Alvarez LLC	
	
Highground Inc. *	
		
Arkansas	
The Capitol Group *	
		
California	
Capitol Advocacy	
		
Colorado	
Brownstein Hyatt Farber Schreck, LLP	
	
Christiansen Corporate Resources	
		
Connecticut	
The O’Leary Group *	
		
Florida	
Smith, Bryan & Myers	
		
Georgia	
McKenna Long & Akridge LLP	
	
Piedmont Public Affairs	
		
Hawaii	
Capitol Consultants of Hawaii LLP *	
		
Idaho	
Lobby Idaho, LLC	
Indiana	
Barnes & Thornburg LLP	
		
Illinois	
Dorgan-McPike & Associates
Kentucky	
MML&K Government Solutions	
		
Louisiana	
Haynie & Associates	

Firm Name	

Maine	
Michtell *
Tardy		
Minnesota	
Hill Capitol Strategies	
	
Mississippi	
Buddy, Medlin & Associates *	
	
Capitol Resources LLC	
		
Montana	
Anderson, Baker & Swanson PLLC	
		
New Hampshire	
Rath, Young & Pignatelli PC	
		
New Jersey	
Princeton Public Affairs Group *	
		
New Mexico	
Edwin Mahr	
	
Ohio	
The Credo Company		
		
Oklahoma	
Fried Kipatrick Guinn LLC
	
Scott Adkins Consulting, Inc.	
		
Tennessee	
Johnson Poss Government Relations	
		
Texas	
The Texas Lobby Group	
		
Vermont	
McLean, Meehan & Rice LLC
		
Washington	
Bogard & Johnson LLC
		
West Virginia	
Capitol Advocates		
		
Wisconsin	
The Welch Group *	
		
District of Columbia	 Group 360, LLC		
		
Los Angeles County	 Ek & Ek

* Firm with which CCA no longer contracts for government relations services.

5		

CCA Political Activity and Lobbying Report 2012

America’s Leader in
Partnership Corrections
Jan. 1, 2012 – Dec. 31, 2012

CCA’s contracts with its outside government relations professionals contain
strict conflict of interest clauses that permit CCA to terminate the relationship
if the professional or his or her firm engages in activities that conflict with
CCA’s commitment not to lobby for or against policies or legislation that
would determine the basis for an individual’s incarceration or detention.

10 Burton Hills Boulevard
Nashville, TN 37215

Reported Lobbying-Related Expenses
In 2012, CCA and its consultant lobbyists reported approximately $2.6 million in
fees and other expenditures relating to lobbying on behalf of CCA at the Federal,
state and local levels. This amount includes fees paid to consultant lobbyists
(see Fees for Direct Lobbying, below), compensation paid to CCA employees who
engage in lobbying or lobbying-related activities and lobbying-related expenses
(such as travel expenses), as required by applicable Federal, state and local rules
regarding lobbying disclosure. Of this amount, $970,000 was attributable to Federal
lobbying-related activities and the remainder ($1.6 million) to state and local
activities. None of this amount related to “grassroots lobbying” communications
(communications directed to the general public that refer to specific legislation
or regulation, reflects a view on such legislation or regulation or encourages
the recipient to take action with respect to such legislation or regulation).

POLITICAL
ACTIVITY
REPORT

Fees for Direct Lobbying
In 2012, CCA paid an aggregate amount of approximately $1.6 million to consultant
government relations professionals for direct lobbying (as defined in Internal
Revenue Code (IRC)162(e)). Of that amount, $ 0.8 million was for lobbying at the
Federal level and $0.8 million was for lobbying at the state and local levels.

Trade and Membership Associations,
Chambers of Commerce and Other Groups
CCA, its facilities and employees also are members of certain trade and
membership associations, chambers of commerce and other groups.
Below is a list of such organizations to which CCA paid dues or fees of
$25,000 or more in 2012, of which a portion were not tax deductible as
a result of being used by the organization for lobbying purposes:
Table B-2

Trade Association,
Membership Association
& Chamber	

Non-Deductible
Portion for
Lobbying

est. 35%	
55%	
est. 10%	

$26,250
$13,750
$6,650

$166,500 		

$46,650

Total Paid

Florida Chamber of Commerce	
US Chamber of Commerce	 	
Combined Other State & Local Chambers of Commerce	
	

	
% Non-Deductible
for Lobbying

TOTAL	

$75,000 	
$25,000 	
$66,500 	

America’s Leader in
Partnership Corrections
6		

CCA Political Activity and Lobbying Report 2012

Jan. 1, 2012 – Dec. 31, 2012

CCA contributes or pays dues to other tax exempt organizations that
engage in advocacy or educational efforts on behalf of their constituencies.
CCA has not been made aware that any dues paid by CCA are used for
lobbying or other political activities. For example, CCA supported the
National and Southern Governors Associations in 2012. CCA did not
contribute $25,000 or more to any such organization in 2012.
In 2012, CCA was not a member of any partnership corrections-related or similar trade
association that engages in political activities on behalf of its members. Many CCA
employees are members of the American Correctional Association (“ACA”), which is a
501(c)(3) charitable organization. CCA also pays audit and accreditation related fees to
the ACA. 501(c)(3) organizations are subject to strict limitations on political activities,
and CCA has not been made aware that any dues or fees paid by CCA or its member
employees are used for lobbying. In connection with the company’s conversion
to a real estate investment trust beginning in fiscal year 2013, CCA has become a
member of NAREIT, the National Association of Real Estate Investment Trusts.

10 Burton Hills Boulevard
Nashville, TN 37215

POLITICAL
ACTIVITY
REPORT

CCA is not currently a member of the American Legislative Exchange Council
(“ALEC”) or any similar organization that writes and endorses model legislation,
and neither the company nor any of its employees has been a member of
ALEC since 2010. For additional background, visit: http://thecca360.com.

This report is not a supplement to any other report filed or required to be filed
by the company with any governmental agency. To the extent the report
contains information about CCA-PAC, it is not intended as a solicitation for
contributions to CCA-PAC from any person. The report has not been audited and
the company undertakes no obligation to issue any updates or corrections.
7		

CCA Political Activity and Lobbying Report 2012

America’s Leader in
Partnership Corrections
Jan. 1, 2012 – Dec. 31, 2012

 

 

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