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San Francisco Ethics Commission Audit Report: Steve Braccini for District 2 Supervisor, FPPC ID #1265008

  1. Introduction

    This Audit Report summarizes the audit results of the committee, Steve Braccini for District 2 Supervisor, Identification Number 1265008 (“the Committee”), from January 1, 2004 through June 30, 2005.  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 seq.) and San Francisco’s Campaign Finance Reform Ordinance (“CFRO”) (San Francisco Campaign and Governmental Conduct Code § 1.100, et seq). [1]

  2. 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 along with other relevant documents to determine whether the candidate complied with applicable requirements of State and local laws.  The Commission randomly selected the Committee for audit.

  3. 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 expenditures;
    4. Accuracy of total reported receipts, disbursements, and cash balances as compared to bank records; and
    5. Compliance with all record-keeping requirements.

    The Commission posts audit reports to its web site and, in cases of violations of law, forwards them to the appropriate enforcement agency.

  4. Committee Information

    The Committee was formed in April 2004 to support the election of Steve Braccini to the Board of Supervisors, District 2 in the November 2, 2004 general election.  Eric Passetti served as the treasurer.  The Committee’s filing obligations were completed on June 30, 2005.

  5. Audit Findings

    For the period covered by the audit, the Committee received $78,654 in contributions (including $2,865 of non-monetary contributions).  The Committee incurred expenditures of $75,789.

    The Commission determined that there were two material findings with respect to the audit of the Committee, as follows:

    1. The Committee did not file the required itemized disclosure statement for one of its four mass mailings, in violation of San Francisco Campaign and Governmental Conduct Code (S.F. C&GC Code) section 1.161.


      Estimated Amount Reported on Disclosure Statement

      Date of Mass Mailing

      Date of Filing

      Timely Filing of Itemized Disclosure Statement

      Included “paid for by”?

      Number of Pieces Mailed








      The Choice is Critical







      Real Solutions







      The Differences are Real







      Mailer to Republican Households



       Not filed

















      S.F. C&GC Code section 1.161 requires that any candidate seeking City elective office who pays for a mass mailing that advocates for or against candidates to include the statement, “paid for by _____ (insert candidate’s name and street address)” in at least 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 a clearly legible original or copy of the mass mailing and the Itemized Disclosure Statement for Mass Mailings within five working days after the date of the mailing.

      Committee’s Response to Finding:

      “The Committee relied exclusively on its registered consultant for the filing of any itemized disclosure.  Hence, the Committee was not aware that an itemized disclosure was not filed.” 

    2. The Committee did not include in its recorded telephone messages, the statement: “paid for by _____ (insert name of person who paid for the recorded telephone message)” for six of its eight messages, in violation of S.F. C&GC Code section 1.163.

      S.F. C&GC Code section 1.163 requires that any recorded telephone messages distributed to 500 or more individuals or households must include the statement: “paid for by _____ (insert name of person who paid for the recorded telephone message).”  Statements required pursuant to this section shall be audible and played at the same volume and speed as the rest of the recorded telephone message.  Any person paying for a recorded telephone message must maintain a transcript of the message and a record of the number of distributed calls for each message.

      Committee’s Response to Finding:

      “The Committee exclusively relied on its registered consultant in preparing all recorded telephone messages.  Any resultant non-compliance was completely a mistake and unintentional.”

      “The Committee tried its best to comply with all requirements, so any alleged violation of law was completely inadvertent and unintentional.  I was a first time candidate, who was a novice at running for elected office.  Please note that not only myself, the candidate, but also my treasurer, who was responsible for these filings, were novices at running for elected office.  As such, any alleged non-compliant reporting was a mistake and completely unintentional.”


[1] During the period covered by the audit, Article 1, Chapter 3 of the San Francisco Campaign and Governmental Conduct Code (S.F. C&GC Code) 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 1.112.

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