Most Americans assume their state legislators write the bills they vote on. They often don't. A well-documented pipeline connects anonymously funded think tanks to template legislation that arrives in statehouses pre-written, pre-packaged, and ready for introduction — with the drafters' names nowhere on the bill.
When a bill passes your state legislature, the official record shows the name of the legislator who introduced it. What the record rarely shows is the name of the organization that wrote it, the donors who funded that organization, or the policy outcome those donors had an interest in seeing enacted.
This is not a recent phenomenon. Model legislation — draft bills prepared by policy organizations and distributed to state lawmakers for introduction — has been a feature of American lawmaking for decades. What has changed is the scale, the sophistication, and the anonymity of the funding flowing into the organizations that produce it. The result is a legislative pipeline that shapes state law across the country with minimal public awareness and less accountability than a municipal contractor.
Model legislation is draft statutory text prepared by a think tank, trade association, or advocacy organization and distributed to state lawmakers for introduction in their legislatures. Because most states require only that a bill be introduced by a legislator — not that its drafting origin be disclosed — model legislation frequently travels from organization to statehouse to enacted law without any public record of who wrote it or who funded the organization that did.
Model legislation is legal. It is practiced across the political spectrum. The accountability problem is not the practice itself — it is the opacity of the funding behind the organizations producing it.
The Pipeline in Practice
The mechanics of the model legislation pipeline follow a consistent pattern. A policy organization identifies a legislative priority aligned with its donors' interests. It drafts statutory language, often with the help of affiliated attorneys. It distributes that language to sympathetic lawmakers in multiple states, often through coordinated outreach campaigns that include briefings in state capitals, constituent contact programs, and legislative testimony by affiliated experts. Once bills are introduced, the same organization mobilizes supporters to generate public pressure — further obscuring the fact that the campaign originated not with constituent demand but with a funded policy operation.
The pipeline's efficiency is its most notable feature. A single organization can shape legislation in dozens of states simultaneously, with each bill appearing to be a locally generated response to constituent concern rather than a coordinated campaign executed from a single address in Washington, D.C. Legislators are often unaware of the full network behind the bills they introduce; they receive the draft, are briefed by articulate experts, and introduce legislation that serves their constituents' perceived interests — or so the briefing tells them.
The Center for Public Integrity documented one such network producing identical or near-identical legislation in dozens of states. The research found that bills drafted by the same organizations, using the same statutory language, were introduced in state after state while the original drafters' identities were scrubbed from the public record. "Because most states don't require disclosure of bill sources," the investigation found, "this process often occurs with minimal public scrutiny."
"When a donor-advised fund cuts a check to a think tank that drafts a bill that a legislator introduces in a statehouse, the American voter has no way to trace the line from funder to law. That is not transparency. That is the architecture of invisible influence."
The Funding Architecture Behind the Bills
The organizations that produce model legislation are funded through the same donor-advised fund infrastructure documented in earlier VALOR investigations. The mechanism is by now familiar: high-net-worth donors contribute to donor-advised funds maintained by Fidelity Charitable, Schwab Charitable, DonorsTrust, or similar vehicles. Those funds distribute grants to policy organizations. The policy organizations produce research and legislation. The legislation shapes law. At every step, the donor's identity is shielded from public view.
DonorsTrust — the primary vehicle for conservative dark money — held $1.4 billion in net assets as of the end of 2024 and distributed $195.3 million to more than 300 organizations in that year alone. Organizations at the center of documented model legislation campaigns are among its recipients. America First Legal Foundation received $21.3 million in 2024 — a 565% increase from its 2023 funding — through donor-advised vehicles whose original donors remain undisclosed.
The funding network behind domestic security model legislation has been documented through IRS Form 990 filings and published investigative research. The Center for American Progress documented that seven conservative foundations distributed $42.6 million between 2001 and 2009 to a network of policy organizations that produced anti-Sharia legislation. Between 2017 and 2019, 35 charitable institutions distributed $105.8 million to 26 organizations in the same network. Total documented funding: $206 million. Actual funding was almost certainly higher.
The Funding Network: Documented Figures
Defense Contractor Money and Security Policy Research
The presence of defense contractor funding in domestic security policy research creates a conflict of interest that has received insufficient attention. Boeing, Raytheon, Lockheed Martin, and General Dynamics are not neutral observers of American security policy. They are among the largest beneficiaries of the government contracts that security policy decisions authorize. Their donations to policy organizations that influence security legislation are not charitable acts — they are strategic investments in the regulatory environment that determines their revenue.
The conflict is structural. A think tank that receives funding from a defense contractor has a financial incentive to produce research supporting expanded security operations, increased defense spending, and a policy environment that treats security threats as ubiquitous and urgent. A defense contractor that funds security research has an incentive to ensure the research concludes that its products and services are necessary. The American public, reading the think tank's congressional testimony or policy briefs, has no way of knowing that the "independent" expert who produced the analysis has a funding relationship with the corporation that benefits from the recommended policy.
This problem was precisely what Senate Finance Committee Chairman Charles Grassley identified when he introduced the Think Tank Transparency Act — a bill that has been reintroduced in 2025 and again in 2026 without yet passing. The bill would require policy organizations to disclose major donors using the same Schedule B format that corporations use to disclose shareholders. The principle is straightforward: if a think tank's research shapes American policy, the American public deserves to know who funded that research.
The Foreign Money Problem
Foreign government funding of American think tanks represents a distinct accountability failure. When a foreign government funds an organization that shapes American national security policy, it acquires policy influence without the disclosure requirements that apply to registered foreign agents. The Foreign Agents Registration Act was designed to address this problem — but its application to think tanks has been inconsistent, and the donor-advised fund infrastructure provides a mechanism for routing foreign money through domestic intermediaries in ways that obscure its origin.
The documented $2.5 million UAE transfer to the Foundation for Defense of Democracies illustrates the problem. FDD has been one of the most influential foreign policy think tanks in Washington, providing expert testimony to Congress on Iran sanctions, counterterrorism policy, and Middle East strategy. It has published research cited by executive branch officials and congressional committees. Its funding relationship with a Gulf state government — disclosed not through voluntary transparency but through investigative journalism — raises questions that apply equally to every foreign policy think tank in Washington: who funds these institutions, and does that funding create conflicts of interest in the policy recommendations they produce?
The Quincy Institute for Responsible Statecraft, which monitors think tank funding, has documented that organizations receiving funding from foreign governments or defense contractors consistently produce policy recommendations that benefit their funders. This is not evidence of corruption in any individual case. It is evidence of a structural incentive problem that transparency requirements would at least make visible.
The "Copy-Paste" Signature
The most visible evidence of the model legislation pipeline is linguistic. When the Center for Public Integrity reviewed domestic security bills introduced in multiple states, it found identical or near-identical language appearing in bills sponsored by different legislators in different states — language that could only have originated from a common source. Legislators who introduce these bills typically have no awareness that they are the fourth or fourteenth member of a coordinated campaign; they believe they are responding to a constituent concern that happens to have a perfectly drafted statutory solution available.
This is how the pipeline works at its most effective: the legislator is not co-opted, they are convenient. The organization provides the research, the expert witnesses, the model language, the constituent activation infrastructure, and the political framing. The legislator provides the title and the vote. The donor provides the money. The public provides no input, because the public does not know it is looking at a coordinated campaign rather than an organic legislative response.
The accountability failure is not that legislators use model legislation. They always have. The failure is that the sources and funders behind model legislation are systematically undisclosed, allowing policy organizations to shape American law while shielding from public view the financial interests that are driving the legislative agenda.
The Accountability Gap: What Disclosure Would Reveal
- Which policy organizations draft model legislation — and which donors fund those organizations
- Whether defense contractors are funding security policy research that benefits their contracts
- Whether foreign governments are funding American domestic policy research
- Which legislators introduce model legislation from which organizations — and whether those legislators receive campaign contributions from the same donor networks
- Whether the "independent" experts testifying before state legislatures have financial relationships with the organizations that funded the bill being considered
The Bipartisan Case for Transparency
Think tank transparency is not a partisan issue. The same accountability standard that should apply to conservative organizations shaping security and immigration policy should apply to progressive organizations shaping environmental and regulatory policy. The same disclosure requirements that would expose foreign government funding of foreign policy hawkishness would expose the funding relationships behind progressive climate and development policy. The principle is consistent: Americans deserve to know who is funding the institutions that shape their laws.
Senator Grassley, a Republican who has spent decades as a leading voice for government accountability, has made think tank transparency a signature issue precisely because he understands that accountability is not ideological. Heritage Foundation President Kevin Roberts has expressed support for the principle of transparency. The Quincy Institute, which leans in a non-interventionist direction on foreign policy, has advocated for think tank funding disclosure after documenting the influence of defense contractor money on foreign policy positions.
The Think Tank Transparency Act would not ban dark money donations. It would not restrict policy research. It would not prevent any organization from drafting model legislation and distributing it to sympathetic lawmakers. It would require only that policy organizations answer a single question that every other institution seeking to influence American policy is required to answer: Who is funding you?
VALOR Institute — Accountability Standard
The VALOR Institute's accountability test is consistent: does the public have the information it needs to evaluate whether the institutions shaping American policy are acting in the public interest or in the interest of their funders? Applied to the model legislation pipeline, the answer is unambiguously no. Anonymous donors fund think tanks that draft state legislation while shielding their identities from the citizens whose laws those think tanks are writing. Defense contractors fund security research while their government contracts depend on the security environment that research shapes. Foreign governments fund American policy research through intermediaries designed to obscure the foreign origin of the funding. Senator Grassley's Think Tank Transparency Act addresses this accountability gap with a proportionate, bipartisan response. The American public — and the legislators who represent them — should demand its passage.
The bills your state legislature votes on were written somewhere. The question is whether you are allowed to know where — and who paid for them.
This investigation was prepared by the VALOR Institute Research Desk. Financial figures drawn from IRS Form 990 public filings, Center for American Progress research, Center for Public Integrity investigations, Quincy Institute Think Tank Funding Tracker, and Associated Press reporting. All figures represent public records. VALOR Institute analysis represents institutional editorial judgment and does not constitute legal advice.