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INVESTIGATION

Sixty-Four Members, Four Bills, Zero Markups: A Coordination Architecture

Sixty-Four Members, Four Bills, Zero Markups: A Coordination Architecture
By: VALOR Institute Research Desk Published: April 21, 2026 Category: INVESTIGATION
Executive Summary

A congressional caucus founded in December 2025 has enrolled sixty-four members across twenty-five states, introduced four bills in the 119th Congress, and held zero committee markups on any of them. In the same period, the caucus's founding co-chairs and its external publications network have generated a sustained press cycle whose volume is inversely proportional to the legislative output.

According to ProPublica's Nonprofit Explorer, four private foundations appear in the publicly disclosed grants-out records of every think tank whose model language has been incorporated into the caucus's legislative slate. According to FEC candidate-committee and independent-expenditure filings, the same donor network reports contributions to a large share of the caucus's membership.

This investigation maps the caucus's four-bill slate against Congressional Research Service benchmarks for regular-order legislative advancement; documents the overlapping donor footprint connecting the caucus's external amplifier network to its federal legislative vehicles; and evaluates the procedural indicators that distinguish coordination infrastructure from legislative infrastructure.

Companion coverage: Bastion Daily's daily-reporting read of the same plateau — "Sixty-Four Members, Twenty-Five States, Zero Markups" and La Verdad Tejana's community-side explainer of what a 65-member caucus means for Texas families.

Methodology

This report draws on bill status pages and cosponsor listings on Congress.gov; the House Judiciary Committee's published markup calendar; Congressional Budget Office cost estimate publications; Form 990 and 990-PF filings indexed by ProPublica's Nonprofit Explorer; Federal Election Commission candidate and PAC filings indexed through OpenSecrets; the Foundation Directory Online and Candid's 990-PF archive; published reporting from NOTUS, Religion News Service, Jewish News Syndicate, and The Bulwark; and the April 2026 monthly round-up published on the Middle East Forum's own website. Where specific figures are provided, the filing year and the primary source are cited in the text. Legislative status is current as of the morning of April 21, 2026. The report does not allege coordination in violation of any statute governing candidate–outside-group communications; it documents disclosure records available to any researcher through public channels.

I. The Numerics: What Sixty-Four Members and Zero Markups Means

The caucus at the center of this investigation was publicly launched on December 17, 2025, by Rep. Chip Roy (R-TX) and Rep. Keith Self (R-TX). According to the founding press release on Representative Self's official congressional website, the caucus's stated purpose is to oppose the incorporation of what its members describe as "foreign legal traditions" into American courts. As of a Self press release dated in early April 2026 and cross-referenced with LegiStorm's caucus summary page, the caucus had reached sixty-three members representing twenty-five states. Reporting by NOTUS tracked continued enrollment through April. A Georgia congressional freshman, sworn in the week of April 13, self-identified as the sixty-fourth member, according to the Jewish News Syndicate's caucus tracker.

The caucus has introduced four bills, each trackable by number on Congress.gov:

According to the House Judiciary Committee's published markup calendar as of the morning of April 21, 2026, none of these four bills has been scheduled for committee markup. According to the CBO's publications database, only H.R. 6230 has received a Congressional Budget Office cost estimate, published at CBO as Publication 61970. The remaining three bills have neither CBO scores nor scheduled committee hearings.

4 bills / 0 markups / 1 CBO score

Caucus legislative output over sixteen months, per Congress.gov bill status pages and the House Judiciary Committee markup calendar, cross-referenced against the CBO publications database. A four-bill slate that generates a single cost estimate in sixteen months is not a slate being prepared for floor action; it is a slate being prepared for public declaration.

The Congressional Research Service's standing guidance on the legislative process, summarized in CRS report R41373, treats committee markup as the principal gate between introduction and floor action. Bills that do not pass a markup in the first session of a Congress have, historically, a markedly lower probability of enactment in the second session. The caucus's four bills, all introduced in the 119th Congress's first session, have cleared none of those gates.

II. What Regular Order Would Look Like — and Why This Isn't It

Regular-order legislative advancement, per CRS's procedural summaries, follows a predictable sequence: introduction and referral; subcommittee hearing with witnesses; subcommittee markup; full-committee markup; reporting to the floor; Rules Committee action; floor consideration. A bill that will become law typically clears several of those gates within twelve months of introduction.

None of the caucus's four bills has cleared any of those gates. Their procedural status, available through the "actions" tab on each bill's Congress.gov page, is uniform: referred to the House Judiciary Committee, in the case of H.R. 5512 and H.R. 5722, and additionally to the House Foreign Affairs Committee in the case of H.R. 6230. The PAUSE Act was referred to multiple committees including Judiciary and Homeland Security. Referral is the first procedural step. Sixteen months after the caucus's launch, none of the bills has moved beyond it.

The absence of hearings is itself a structural datapoint. According to the House Judiciary Committee's published calendar, the committee held a February 2026 hearing on constitutional interpretation of foreign-law influences, which produced no formal witness testimony on any caucus bill. The House Judiciary Republicans' upcoming markup page does not list any caucus-sponsored measure in the April or early-May window.

This is the procedural signature of a bill slate designed for signaling rather than legislation. The slate exists. Its numbers are public. Members cosponsor it. Press releases reference it. External publications cite it. It does not advance. In the taxonomy CRS uses for caucuses and legislative coalitions, this is the posture of a "messaging caucus" — a coalition whose bills serve as the occasion for coordinated public positioning rather than as vehicles for enactment.

III. The Publications-to-Policy Pipeline, Self-Claimed

The caucus does not operate in isolation from its external ecosystem. On the contrary, one of its ecosystem partners has, in April 2026, publicly claimed the caucus as a downstream product of its own publications operation.

The Middle East Forum's April monthly round-up — published on the organization's own website and referenced in its April 2026 communications to donors — identifies several recent policy outcomes that the forum attributes to its "publications-to-policy" pipeline. The round-up lists the caucus's formation and growth as among those outcomes, alongside the February House Judiciary read-into-record event, the state-level exclusion criteria adopted in Texas's educational-choice program, and the March 21, 2026 Texas state terrorist designation of the Muslim Brotherhood.

The self-claim has three structural consequences.

First, it converts an inferential argument into an admission. Until April 2026, observers documenting the relationship between think-tank publications and caucus legislation were making a structural argument supported by donor overlap and timing. The Middle East Forum's own press release now provides direct testimony from one of the pipeline's participants. The existence of the pipeline is no longer a contested allegation.

Second, it creates a durable citation for policy analysts. According to the Brennan Center for Justice's 2026 resource page on religious-liberty advocacy, structural arguments about coordination are substantially strengthened when documented by a participant rather than inferred by researchers. The self-claim will be citable in amicus briefs, in Department of Justice inspector general reports, and in congressional oversight materials for the remainder of the 119th Congress.

Third, it provides the factual foundation for a disclosure argument. Under the Federal Election Commission's coordinated-expenditure rules, shared donor networks are not coordination. Shared programmatic claims, in which a 501(c)(3) organization publicly takes credit for the legislative output of a caucus whose members receive donor support from the same funders, may eventually bear on the boundary between educational nonprofit activity and political advocacy. The Internal Revenue Service has not, in 2026, advanced any enforcement action on that basis. The structural argument that it should is now documented.

IV. The Texas Model: Dark-Money Funding Subsection

The funding architecture supporting the caucus's external publications network overlaps significantly with the architecture supporting the state-level policy disputes that produced the March 21 Brotherhood designation and the Texas educational-choice exclusion criteria. According to IRS Form 990 and 990-PF filings searchable on ProPublica's Nonprofit Explorer, four private foundations appear as identified donors to every organization whose model language has been incorporated into the caucus's four-bill slate.

The Lynde and Harry Bradley Foundation. According to the foundation's public grants database and 990-PF filings indexed at ProPublica's Nonprofit Explorer page for the Lynde and Harry Bradley Foundation, the foundation has reported grants to the Heritage Foundation, the Foundation for Defense of Democracies, and a range of education-policy intermediaries. The foundation's annual grants-out routinely exceed $40 million per fiscal year.

Donors Trust. According to the organization's public materials and the Form 990 pass-through records searchable at ProPublica's Nonprofit Explorer, Donors Trust has distributed substantial funds to Heritage, FDD, and the Middle East Forum. The donor-advised fund does not disclose the original donors whose gifts pass through its accounts.

The Diana Davis Spencer Foundation. According to 990-PF filings at ProPublica's Nonprofit Explorer, the foundation has reported grants across multiple fiscal years to FDD, to Middle East advocacy institutions, and to Heritage. The Spencer network is a major funder of conservative legal and policy infrastructure.

The Sarah Scaife Foundation. According to 990-PF filings at ProPublica's Nonprofit Explorer, Scaife has reported grants to Heritage and FDD. The Scaife philanthropic network has funded a cross-section of conservative legal and policy institutions for more than three decades.

The Heritage Foundation's FY2023 annual report, published at heritage.org/about-heritage/impact/report, reports revenue of approximately $110 million. FDD's most recent publicly available Form 990, indexed at ProPublica's Nonprofit Explorer, reports program expenses of approximately $14.6 million. The Middle East Forum's most recent 990 reports approximately $3.5 million in annual revenue. These are organizations of different institutional scale, but their identified donor overlap is visible in the same four foundations' publicly disclosed grants-out records.

On the federal legislative side, FEC candidate-committee filings indexed on OpenSecrets' members-of-congress database document that a substantial share of the caucus's sixty-four members receive campaign contributions from movement-conservative PACs that in turn report contributions from the Bradley Impact Fund and from Donors Trust pass-throughs. The Bradley Impact Fund's own filings, indexed at InfluenceWatch's Bradley Impact Fund page, show year-over-year distributions to conservative PAC infrastructure.

This pattern is familiar to researchers who follow ideological giving networks. It is the same network documented in 2020 by Sen. Sheldon Whitehouse's Yale Law Journal forum piece on amicus influence and funding transparency; it is the same network documented by the Center for Media and Democracy's analysis of State Policy Network member revenues (combined revenue across SPN members topped $120 million by 2019, per CMD's SPN research portal); and it is the same network whose members appear in the ongoing funding records of the organizations to which the caucus's publications pipeline is anchored.

4 foundations / 3 think tanks / 64 caucus members

Four foundations appear in the publicly disclosed grants-out records of all three think tanks whose model language has been incorporated into the caucus's federal legislative slate. The same donor footprint appears on the candidate-committee side of a substantial majority of the caucus membership, per OpenSecrets' indexing of Federal Election Commission filings.

The Texas dimension of this funding architecture — the "Texas Model" referenced in state-level policy research — is visible in the same records. Per the Texas Tribune's reporting on the state's educational-choice program, the exclusion criteria adopted during the program's rulemaking phase draw language from model briefs produced by the same three think tanks identified above. The Texas Attorney General's office has invoked similar framing in separate state-level religious-mediation investigations. The model-language pathway from think-tank publication to state policy to federal bill introduction is, in the Texas case, a documented sequence rather than an inferred one.

V. Coordination Architecture: Why the Plateau Is the Signal

If a caucus adds members steadily without advancing bills through committee, the growth rate alone is an institutional signal — but it is not the most important signal. The most important signal is the ratio between external amplification and legislative output.

Per NOTUS's reporting, the caucus generates roughly four to six press cycles per month through JNS, RAIR Foundation USA, Granite Grok's IMANI vertical, and CBN News. Per the Granite Grok IMANI vertical's April 2026 coverage, the caucus's four-bill slate is described as a "legislative vanguard" — a framing that presents the existence of the bills, rather than their advancement, as the achievement. Per Religion News Service's coverage, the caucus's public messaging does not depend on committee activity; the roster itself is the object of communication.

The ratio, then, looks like this: zero markups, four bills, sixty-four members, and several dozen press cycles per quarter. That ratio describes a coordination architecture rather than a legislative architecture. The caucus's institutional function, measurable by its outputs, is to generate and sustain a public declaration that its members share a set of positions. The declaration requires members. It does not require votes.

For policy analysts assessing the caucus's institutional weight, this distinction matters. A sixty-four-member caucus that is advancing bills through committee is on a path to floor action, and its bills will produce floor votes that create a record. A sixty-four-member caucus that is not advancing bills through committee is on a different path — one whose outputs are press releases, state-level advocacy amicus briefs, and sustained framing in a discrete media network. Its institutional weight is measured in the durability of its messaging, not in the arithmetic of roll-call votes.

The plateau in markup activity — zero, across sixteen months — is therefore not the absence of a data point. It is the data point. It is the signal that the caucus's intended output is not legislation. It is public declaration.

Policy Implications

The structural picture this investigation documents — a four-bill slate that has not advanced; a publicly claimed publications-to-policy pipeline whose sponsoring organizations share an identifiable donor footprint; a caucus membership whose campaign finance profiles overlap with the same donor network — carries three implications for policy observers and for congressional oversight.

First, the caucus's legislative inactivity does not reduce its policy footprint. Even without markups or floor action, the caucus's four bills function as framing devices in state-level executive and administrative proceedings. State attorneys general and state agencies have cited the federal bills as evidence of a broader policy consensus when defending state-level exclusion criteria. Policy analysts who measure the caucus's influence by counting passed bills will underestimate its effect.

Second, the self-claim by the Middle East Forum pipeline creates a disclosure record that did not previously exist. For the remainder of the 119th Congress, analysts writing amicus briefs in cases implicating state-level exclusion policies will be able to cite the pipeline's existence as a documented fact. That citation, over time, may enter judicial opinions — and once it does, the inferential argument about coordination becomes part of the legal record.

Third, the shared donor footprint across state and federal advocacy surfaces an open question about amicus-filer disclosure. The Judicial Conference Advisory Committee on Appellate Rules proposed expanded amicus-funder disclosure in 2023; the proposal has not been adopted at the district-court level. As the caucus's bills continue to be cited in state-court filings, the absence of funder-disclosure requirements at the district-court level allows the same four foundations to appear as donors to the amicus brief's issuing organization without disclosure to the court. Whether that pattern warrants rule revision is a question on which the Advisory Committee's docket remains open.

The broader principle engaged by this investigation is that a caucus's institutional function cannot be measured by legislative output alone. The four-bill slate at the center of this report has advanced nothing. That is the finding. The advancement the caucus is doing is happening elsewhere — in state-level proceedings, in amicus briefs at the district-court level, in press cycles within a defined media ecosystem, and in the public record of a self-claimed publications-to-policy pipeline. Measuring that advancement requires looking beyond the committee calendar.

Pending Legislative Response

No pending congressional proposal would directly address the disclosure questions this investigation raises, but several related vehicles bear on the underlying architecture.

The DISCLOSE Act (S. 512 and its House companion, reintroduced in the 119th Congress) would require 501(c)(4) organizations to disclose donors above $10,000 when the organizations spend on election-related communications. According to the bill's Congress.gov status page, the DISCLOSE Act has not advanced in the current Congress. Its prospects are limited, but its reintroduction continues to frame the disclosure conversation.

The Disclose Money Act of 2025, a narrower proposal focused on Super PAC original-donor disclosure, was referred to the House Administration Committee and has not received a hearing.

On the judicial side, the Advisory Committee on Appellate Rules remains the principal institutional actor with jurisdiction over amicus-filer disclosure. Its 2023 proposal for expanded funder disclosure at the appellate level is a precedent that lower-court and state-court disclosure rules could model. The committee's subsequent agenda indicates that the disclosure question is open but not scheduled for action in the 2026 docket.

On the executive side, the Department of Education's April 15, 2026 Federal Register notice on Section 117 Foreign Gifts and Contracts Disclosures opens a public-comment window on a regulatory track parallel to the caucus's legislative slate. Although the notice is directed at higher-education institutions, its framing will bear on the broader disclosure conversation around foreign and foundation giving to advocacy organizations.

Sources

Primary government documents:

Nonprofit and funding data:

Published research and reporting:

Citation format throughout this report: every specific numerical claim is accompanied by a named source and, where relevant, a filing year. Dollar figures drawn from 990 and 990-PF filings are cited by organization and by the ProPublica Nonprofit Explorer page on which the filing is indexed. Where public disclosures do not identify individual donors — as is the case for Donors Trust and for 501(c)(4) advocacy organizations — the report notes the absence of that disclosure rather than inferring a figure.