Criminality needs two components: mens rea, the intent to commit a crime and mens acta, the act of committing the crime. While the first was there when the ACORN employees set out the plan, it was not carried out, and certainly the filmakers had neither in mind.
The most I figure you could get them on is the unlicensed practice of law.
Good points, and actually these women are just pawns in the whole scheme of things. I hope this leads to the bigger fish in this scum pond.