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San Francisco Ethics Commission Audit Report: Committee to Rebuild the San Francisco Zoo, FPPC ID #970164


I. Introduction

This Audit Report contains information pertaining to the audit of the Committee to Rebuild the San Francisco Zoo, Identification Number 970164 ("the Committee") for the period from January 1, 1997 through June 30, 1997. The audit was conducted to determine whether the Committee materially complied with the requirements and prohibitions imposed by the Political Reform Act ("the Act") (Government Code Section 81000, et seq.) and San Francisco’s Campaign Finance Reform Ordinance ("the CFRO") (S.F. Administrative Code Section 16.501, et seq.).

During the period covered by the audit, the Committee reported total contributions of $509,670 and total expenditures of $539,619. This audit revealed two material findings: 1) The Committee failed to maintain copies of major donor notifications in violation of Government Code Section 84104; and 2) The Committee failed to obtain and disclose occupation and employer information for 41 percent of the contributors that required such information, in violation of Government Code Sections 84211(f)(3) and (4).

II. Committee Information

The Committee filed a Statement of Organization with the Secretary of State’s Office on January 28, 1997 indicating that it had qualified as a committee on January 24, 1997. The Committee was primarily formed to support the passage of Proposition C, the Zoo Facilities Bonds, in the June 3, 1997 general election. On February 3, 1998 the Committee filed a Recipient Committee Statement of Termination indicating that its filing obligations were completed on December 31, 1997. The Committee’s treasurer was Wayne Reading.

III. Audit Authority

The Commission is mandated by San Francisco Charter Section C3.699-11(4) to audit campaign statements and other relevant documents to determine whether campaign committees comply with applicable requirements and prohibitions imposed by State and local law.

IV. Audit Scope and Procedures

This audit was performed in accordance with generally accepted auditing standards. The audit involved a thorough review of the Committee’s records for the time period covered by the audit. This review was conducted to determine:

  1. Compliance with all disclosure requirements, pertaining to contributions, expenditures, accrued expenditures, and loans, including itemization when required;
  2. Compliance with applicable filing deadlines;
  3. Compliance with restrictions on contributions, loans and expenditures;
  4. Accuracy of total reported receipts, disbursements and cash balances as compared to bank records; and
  5. Compliance with all record-keeping requirements.

V. Summary of Applicable Law

A. Notification of Contributors

Individuals and entities that contribute more than $10,000 in a calendar year must file "major donor" statements. (Government Code Sections 82013(c) and 84211(v)). The Act requires committee treasurers to notify donors who contributed $5,000 or more in a calendar year that the contributor is required to file "major donor" statements if the $10,000 threshold is met. (Government Code Section 84105). Treasurers must send the major donor notification within two weeks of receipt of the contributions. (Government Code Section 84105).

In addition, the Act requires that committee treasurers maintain detailed accounts, records, bills and receipts that are necessary to prepare campaign statements and comply with the campaign disclosure provisions of the Act. (Government Code Section 84104). The detailed accounts, records, bills and receipts are to be retained by the filer for a period of four years. (Page 71 of Information Manual D prepared by the Fair Political Practices Commission).

B. Occupation/Employer Information for Itemized Contributions

Committees are required to report the occupation and employer information of persons who make cumulative contributions in the amount of $100 or more. (Government Code Sections 84211(f)(3) and (4)). The Act requires committees to report the contributor’s occupation, the name of his/her employer, or if the contributor is self-employed, the name of the business.

VI. Material Findings

A. Section 84104: Failure to Maintain Records of Major Donor Notification

The Committee received four contributions of $5,000 or more. The Committee’s records did not contain copies of letters sent to potential major donors. The Committee’s Attorney told staff that he was not able to locate copies of the major donor notifications. The Committee states that it did notify all the contributors of these requirements but merely failed to keep records of these four major donor notifications.

The Ethics Commission concluded that the Committee failed to comply with its record-keeping requirements with respect to maintaining notifications of possible major donor obligations. (Government Code Sections 84104).

B. Section 84211(f): Failure to Obtain and Disclose Occupation/Employer Information

The Committee was required to obtain and disclose information about the occupation and employer of individuals who contributed a cumulative amount of $100 or more. Based on a review of the contributions that required the disclosure of such information, 41 percent lacked information about the contributors’ occupation and employer. The Committee’s Attorney offered no explanation for the missing information.

The Ethics Commission concluded that the Committee failed to comply with its disclosure requirements with respect to obtaining and disclosing information about the occupation and employer for individuals who contributed $100 or more.

VII. Conclusion

Through the examination of the Committee’s records and campaign disclosure statements, the Auditor verified that the Committee accurately and timely disclosed all contributions received and expenditures made. However, the Committee failed to maintain records of major donor notifications, in violation of Section 84104 of the Act. The Committee also failed to obtain and disclose occupation and employer information for 41 percent of the contributors that required such information, in violation of Sections 84211(f)(3) and (4) of the Act.

_____________________________________ __________________
Shaista Shaikh                                                             Date
Campaign Finance Auditor

______________________________________ __________________
Ginny Vida                                                                   Date
Executive Director

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