CITY AND COUNTY OF SAN FRANCISCO
Campaign Finance Audit Report
Engardio for District 4 Supervisor 2022
FPPC ID #: 1448795
January 1, 2022 – December 31, 2022
Introduction
To promote campaign compliance with laws and regulations, the San Francisco Ethics Commission (hereinafter the “Commission”) engaged Macias Gini & O’Connell LLP (MGO) to assist in assessing election committees’ compliance with applicable requirements. This report summarizes the audit results on the Engardio for District 4 Supervisor 2022 #1448795 committee (hereinafter “the Committee”) covering the period of January 1, 2022 through December 31, 2022.
Authority
The Commission has a duty and responsibility under San Francisco Charter Sec. C3.699-11(4) to audit campaign statements and other relevant documents that are filed with the Commission to ensure compliance with applicable state and campaign finance laws and regulations. Under SFC&GCC Sec. 1.150(a), all candidate committees whose candidates have received public financing must be audited and committee that have not received public financing may be randomly selected for audit at the discretion of the Executive Director of the Commission.
Objectives and Scope
The objective of the audit was to reasonably determine whether the Committee substantially complied with requirements of the Political Reform Act Sec. 81000 et. Seq. and supporting regulations, and the San Francisco Campaign Finance Reform Ordinance Sec 1.100 et. Seq. and supporting regulations. The audit was performed based on a review of the Committee’s filing and records covered by the review period to determine, among other things:
- Compliance with campaign activity disclosure and record-keeping requirements, and
- Compliance with applicable campaign activity limits, restrictions, and prohibitions.
As a recipient of public financing, the Committee was subject to mandatory audit.
Nothing in this report shall be interpreted to prevent an enforcement action by the Commission or another appropriate agency for conduct in violation of the law, whether or not that conduct is covered in this report.
The report will be forwarded to the Commission’s Enforcement Division for review to determine whether any further action may be warranted.
Committee Information
Background
The Committee’s primary purpose was to support the election of Joel Engardio to the Board of Supervisors, District 4, of the City and County of San Francisco (“City”) in the November 8, 2022 election. During the period covered by the audit, the Committee’s Treasurer was Joel Engardio. The Committee is ongoing and was established on May 31, 2022.
| Total Funds Raised | Total Expenditures Made | |
| Private Contributions | $179,967 | $425,718 |
| Public Funds Received | $255,000 |
The Committee activity totals were taken from disclosure statements filed with the Commission covering the period January 1, 2022 through December 31, 2022.
Audit Respondent
The audit respondent identified below was the primary audit contact during the audit and responded to audit inquiries and requests on behalf of the Committee.
Tricia Waineo
View Avenue Group, LLC
393 7th Avenue, Suite 301
San Francisco, CA 94118
Audit Findings
The CA Gov. Code Sec. 81000 et. Seq and supporting regulations, and SFC&GCC Sec. 1.100 et. Sec and supporting regulations, require campaign committees to timely disclose information about election campaign activity and adhere to applicable campaign activity limits, restrictions, and prohibitions.
The following findings were noted during the audit:
Campaign Disclosure Statements
- CA Gov. Code Sec. 84101(a) states, “A committee that is a committee by virtue of subdivision (a) of Section 82013 shall file a statement of organization. The committee shall file the original of the statement of organization with the Secretary of State and shall also file a copy of the statement of organization with the local filing officer, if any, with whom the committee is required to file the originals of its campaign reports pursuant to Section 84215. The original and copy of the statement of organization shall be filed within 10 days after the committee has qualified as a committee. The Secretary of State shall assign a number to each committee.”
Under CA Gov. Code Sec. 82013(a), “Committee” means any person who directly or indirectly receives contributions totaling $2,000 or more in a calendar year
The Committee did not file Form 410 – Statement of Organization within the required 10-day period of meeting the $2,000 qualification threshold. The Committee filed with the Secretary of State 11 days after qualification. Thus, the required form was filed 1 days late. In addition, a copy was not filed with the City & County of San Francisco Ethics Commission as mandated.
| Form 410 Filing | |
| Form 410 File Date | 6/15/2022 |
| Date $2,000 Threshold was Meet | 6/4/2022 |
| Days Between Filing and Meeting Threshold | 11 |
| Days Late | 1 |
Conclusion
Except as indicated in the Audit Findings section above, and in our opinion, the Committee substantially complied with the requirements of the Political Reform Act Sec. 81000 et seq. and supporting regulations, and the San Francisco Campaign Finance Reform Ordinance Sec. 1.100 et seq. and supporting regulations.
Auditee response
Audit Respondent did not provide a response to the audit findings.