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San Francisco Ethics Commission Audit Report: Bernal Heights Democratic Club, FPPC ID #923351


San Francisco      
Ethics Commission                   
30 Van
Ness Avenue, Suite 3900
San Francisco CA  94102
Phone 581-2300 Fax 581-2317



I.          Introduction

This Audit Report contains information pertaining to the audit of the committee Bernal Heights Democratic Club, Identification Number 923351 (“the Committee”), for the period from January 1, 2001 through December 31, 2002.  The audit was conducted to determine whether the Committee materially complied with the requirements and prohibitions imposed by the Political Reform Act (“the Act”) (California Government Code Section 81000, et seq.) and San Francisco ’s Campaign Finance Reform Ordinance (“CFRO”) and Electronic Filing Ordinance (S.F. Campaign and Governmental Conduct Code §§ 1.100, et seq., and 1.300, et seq.).

For the period covered by the audit, the Committee received total contributions of $3,300 and incurred expenditures of $3,642.  There was one material finding with respect to this Audit: the Committee failed to retain complete campaign records, in violation of Government Code Sections 84104 and S.F. C&GC Code Section 1.106.

II.        Committee Information

The Committee is a general purpose committee formed to support candidates and issues of benefit to Bernal Heights and other San Francisco communities.  The Committee was formed prior to the period covered by the audit.  The Committee has not terminated as of the date of this report.  David Looman assumed the position of treasurer in 2002 and is the Committee’s current treasurer.  Prior to 2002, the treasurer of record was Buck Bagot.

III.       Audit Authority

San Francisco Charter Section C3.699-11 authorizes the Ethics Commission to audit campaign statements that are filed with the Commission and other relevant documents to determine whether a committee complied with applicable requirements of State and local law.  The Ethics Commission, by a random process, selected the Committee for audit.

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 applicable filing deadlines;
  2. Compliance with restrictions on contributions, loans and expenditures;
  3. Accuracy of total reported receipts, disbursements and cash balances as compared to bank records; and
  4. Compliance with all organizational and record-keeping requirements.

V.        Summary of Applicable Law

Government Code Section 84104: Recordkeeping

Government Code Section 84104 provides that it is the duty of each candidate, treasurer and elected officer to maintain detailed accounts, records, bills and receipts that are necessary to prepare campaign statements, and to retain the documents for a period of four years following the date the appropriate campaign statement is filed.  Section 84104 is incorporated into the Campaign Finance Reform Ordinance at S.F. C&GC Code section 1.106.

VI.       Material Findings

Government Code Section 84104 and S.F. C&GC Code Section 1.106: Recordkeeping

According to the current treasurer, David Looman, the Committee did not have a treasurer during year 2001[1].  The Committee did not timely file its campaign statement for year 2001 and did not retain campaign records for year 2001.  When Mr. Looman became the Committee’s treasurer in 2002, he filed the required campaign statements covering the year 2001 and the Committee paid fines for the campaign statements that were filed late.

The Committee failed to retain campaign records for year 2001 (i.e., copies of contributor checks and invoices/receipts relating to payments).  As a result, the Commission was unable to determine whether required campaign statements covering year 2001 were accurately filed.  The review of the Committee’s bank statements indicated that the total contributions and expenditures disclosed on each campaign statement agreed with the activities listed on the bank statements.  Of the $3,300 in contributions received during the years 2001 and 2002, the Committee’s records did not contain copies of contributor checks for contributions received in 2001, which totaled $881, or 27 percent of the total contributions for the period covered by the audit.  With respect to expenditures, the records did not contain a sample of the slate cards produced by the Committee and invoices/receipts for 5 payments of $25 or more totaling $1,368.99, or 38 percent of the total expenditures.


VII.     Committee’s Response to Findings


Mr. Looman, the Committee’s treasurer, expressed concern that the Commission selected for audit a committee that had a low level of financial activity.  He stated that after the Committee voluntary filed campaign statements for prior unreported periods, the Commission levied fines on the Committee, which were paid.  Mr. Looman believes that because the Committee voluntarily brought itself into full compliance it should be commended for its civic responsibility and honesty.


VIII.    Conclusion

Through the examination of the Committee’s records and campaign disclosure statements, the Auditor found that the Committee failed to retain complete campaign records, in violation of Government Code Sections 84104 and S.F. C&GC Code Section 1.106.

Audit reports are posted to the Commission’s web site and are forwarded, in cases of apparent violations of law, to the appropriate enforcement agency.

Date:  April 20, 2005

[1] There is no indication that the former treasurer absolved himself of treasurer responsibilities before he stopped performing his duties as treasurer.  According to the Fair Political Practice Commission, a treasurer is absolved when a committee designates a new treasurer.  If a new treasurer is not designated, the treasurer has the option of terminating the committee or submitting a letter of resignation to the local filing officer and to the Secretary of State.

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