Ethics Commission
City and County of San Francisco

Payments Made at the Behest of a City Officer

Filings by Elected Officials

In accordance with the California Government Code section 82015, payments made at the behest of elected officials are presumed not to be campaign contributions if they meet the following guidelines:

  • the payments are made principally for legislative, governmental, or charitable purposes, and
  • the payments are made principally for purposes unrelated to the official’s candidacy for elected office.

Although such payments are not campaign contributions, they must be disclosed on the FPPC Form 803 and submitted to the elected official’s agency within 30 days after the total payments made by a single source equal to or exceed $5,000 in a calendar year. The agency must forward a copy of the report to the Ethics Commission within 30 days of its receipt.

After the $5,000 threshold is met for a particular calendar year, all subsequent payments made by the same source during the calendar year must be reported by the elected officer within 30 days after the date the payment is made.

These reports are public records.

View Filed FPPC 803 Filings

View Statements

Archived Behested Payments Filings (May 2015 to June 2018)

Archived Behested Payments Filings (September 1999 to April 2015)

Filings by Elected Officials and Board and Commission Members

On January 1, 2019, a new local law went into effect that established new requirements for behested payment reports. San Francisco Campaign and Governmental Conduct Code section 3.610 requires City elective officers and members of certain boards and commissions to file behested payment reports (SFEC Form 3610b) with the Ethics Commission.

An official must file SFEC Form 3610b any time a behested payment of $1,000 or more is made at his or her behest by an interested party. An interested party is a person who is a party or participant to certain types of proceedings before the official in question. Those proceedings are limited to administrative enforcement proceedings and proceedings regarding permits, licenses, or other entitlements for use. A party to such a proceeding is someone who files an application for a license, permit, or entitlement for use or is the subject of the administrative enforcement. A participant in such a proceeding is someone who is not a party to the proceeding but who actively supports or opposes a particular decision in the proceeding and has a financial interest in the decision.

The filing deadline for SFEC Form 3610b depends on the circumstances under which the behested payment was made.

If the behested payment was made while the proceeding involving the interested party is pending before the official, then the form must be filed within thirty days of the payment being made. If there is a series of behested payments, the form is due within 30 days of the payment that makes the total $1,000 or more.

If the behested payment was made within six months following the date on which a final decision was made in the proceeding involving the interested party, then the form must be filed within thirty days of the payment. If there is a series of behested payments, the form is due within 30 days of the payment that makes the total $1,000 or more.

Finally, if the behested payment was made in the 12 months prior to the commencement of the proceeding involving the interested party, the form is due within 30 days of the date the official knew or should have known that the source of the behested payment became an interested party.

View SFEC Form 3610b Filings by Elected Officials and Board and Commission Members

January 2019 to Present

SFEC Form 3610b filings are accessible via SF Open Data:

SFEC Form 3610b Filings

This dataset includes the contents of each filing that can be exported to a variety of data formats. The dataset also includes a link to a PDF copy of the filing.

SFEC Form 3610b Payors Subtable

This dataset includes a parsed sub-table of payors reported on an SFEC Form 3610b filing. The dataset can be joined with the above filings dataset to research payors included on a filing.

Archived SFEC Form 3600 Filings by Board and Commission Members

January 2018 to December 2018

SFEC Form 3600 was filed electronically and only pertained to Board and Commission Members. As of January 1, 2019, SFEC Form 3600 has been superseded by SFEC Form 3610b. The data on filed forms is posted to the San Francisco Open Data System.

  • Board And Commission Member Behested Payment Filings and Dataset – This dataset includes the contents of each filing that can be exported to a variety of data formats. The dataset also includes a link to a PDF copy of the filing.
    • Payors Dataset – This dataset includes a parsed sub-table of payors reported on an SFEC Form 3600 filing. The dataset can be joined with the above filings dataset to research payors included on a filing.

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