Ethics Commission
City and County of San Francisco

Who Must File as a Campaign Consultant

A campaign consultant is a person or entity that receives or is promised $1,000 or more in a calendar year for providing either “campaign management” services or “campaign strategy” services.

Campaign management services include conducting, coordinating or supervising a campaign to elect, defeat, retain or recall a City candidate, or adopt or defeat a City measure, including but not limited to hiring or authorizing the hiring of campaign staff and consultants, spending or authorizing the expenditure of campaign funds, directing, supervising or conducting the solicitation of contributions to the campaign, and selecting or recommending vendors or subvendors of goods or services for the campaign.

Campaign strategy services include planning for the election, defeat, retention or recall of a City candidate, or for the adoption or defeat of a City measure, including but not limited to producing or authorizing the production of campaign literature and print and broadcast advertising, seeking endorsements of organizations or individuals, seeking financing, or advising on public policy positions.

Notwithstanding the above, the following persons and entities are not campaign consultants:

  • Employees of campaign consultants
  • Clients of campaign consultants
  • Attorneys who provide only legal services
  • Accountants who provide only accounting services
  • Pollsters who provide only polling services
  • Treasurers who provide only those services required by the Political Reform Act, Government Code Section 81000, et seq.

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