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San Francisco Ethics Commission Audit Report: Lisa Feldstein for D5 Supervisor, FPPC ID #1265042


I. Introduction

This Audit Report summarizes the
audit results of the committee, Lisa Feldstein for D5 Supervisor,
Identification Number 1265042
(“the Committee”), from January 1, 2004 through February 28, 2006. 
The audit was conducted to determine whether the Committee materially
complied with the requirements of the Political Reform Act (“the Act”)
(California Government Code section 81000, et
and San Francisco’s Campaign Finance Reform Ordinance (“CFRO”) (San
Francisco Campaign and Governmental Conduct Code § 1.100, et seq).[1]

II. Audit Authority

San Francisco Charter section
C3.699-11 authorizes
the Ethics Commission (“the Commission”) to audit campaign statements
that are filed with the Commission. 
Section 1.150(a) of the CFRO requires the Commission to audit all
candidates who receive public financing. 
Audits of publicly financed candidates include a review of campaign
statements and other relevant documents to determine whether the
candidate complied with applicable requirements of State and local law.

III. Audit Scope and Procedures

This audit was performed in
accordance with generally accepted auditing standards. 
The audit involved a review of the Committee’s records for the 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
  4. Accuracy of total reported receipts, disbursements, and
    cash balances as compared to bank records;
  5. Compliance with all record-keeping requirements; and
  6. Compliance with all provisions related to the Commission’s
    public financing program.

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

IV. Committee Information

The Committee was formed in
April 2004 to
support the election of Lisa Feldstein, Board of Supervisors, District
5 in the November 2, 2004 general election. 
David Wilbur served as the treasurer. 
The committee terminated on February 28, 2006.

V. Audit Findings

For the period covered by the audit,
the Committee
received $47,156 in contributions and $35,792 in public funds, and
incurred expenditures of $81,611. 
The CFRO provides that any candidate who receives public funds must
return unexpended campaign funds to the Election Campaign Fund. 
The Commission determined that the Committee had unexpended funds of
$485, which the Committee has returned to the Election Campaign Fund.[2]

The Commission determined that
there was one material finding with respect to the audit of the
The Committee did not timely file the required itemized disclosure
statements for one mass mailing in violation of San Francisco Campaign
and Governmental Conduct Code section 1.161.

The Committee spent about
$43,000 on mass mailings. 
The Committee timely filed four of the five required
itemized disclosure statements.  The statement filed late is
as follows:


Reported on Disclosure Statement

of Mass Mailing

of Filing

Days Late










16 working days

The Political Reform Act
defines mass mailings as 200 substantially similar pieces of mail sent
within a calendar month. 
Section 1.161 of the CFRO requires any candidate seeking City elective
office, who pays for a mass mailing that advocates for or against
candidates to include on the mailing statement, “paid for by ______
(insert candidate’s name and address)” in not less than 14-point type
and in a color or print which contrasts with the background so as to be
easily legible.  The
candidate must also file
with the Commission a clearly legible original or copy of the mass
mailing and an itemized disclosure statement within five working days
after the date of the mailing.

Committee’s Response to Findings

The Committee was provided with an
opportunity to comment on this audit report. 
The Committee did not provide any comments.

During the period covered by the audit, Article 1, Chapter 3 of the San
Francisco Campaign and Governmental Conduct Code (S.F. C&GC
codified the Electronic Filing Ordinance. 
As a
result of recent amendments to CFRO, the provisions of the Electronic
Filing Ordinance are now combined in S.F. C&GC Code section


Unexpended funds are calculated by subtracting any unpaid bills,
on-going qualified campaign expenditures, and

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