I. Introduction
This Audit Report summarizes the audit results of the committee, San Francisco Chamber of Commerce 21st Century Committee, Identification Number 891575 (“the Committee”), for the period from January 1, 2005 through December 31, 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 seq.) and San Francisco’s Campaign Finance Reform Ordinance (“CFRO”) (San Francisco Campaign and Governmental Conduct Code section 1.100, et seq).
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 along with other relevant documents to determine whether a committee complied with applicable requirements of State and local laws.
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:
- Compliance with all disclosure requirements pertaining to contributions, expenditures, accrued expenditures, and loans, including itemization when required;
- Compliance with applicable filing deadlines;
- Compliance with restrictions on contributions, loans, and expenditures;
- Accuracy of total reported receipts, disbursements, and cash balances as compared to bank records;
- Compliance with all record-keeping requirements.
The Commission posts audit reports to its web site and, in cases of apparent violations of law, forwards them to the appropriate enforcement agency.
IV. Committee Information
The Committee is a general purpose committee that was formed prior to the period covered by the audit to oppose and support local ballot measures. Jim Lazarus and Melissa A. Mikesell served as the treasurers. The Committee was active as of December 31, 2006.
V. Audit Findings
For the period covered by the audit, the Committee received $271,663 in contributions (including $457 of non-monetary contributions) and incurred $207,019 in expenditures.
The Commission determined that there was one material finding with respect to the audit of the Committee. The Committee did not timely send major donor notice letters to twelve contributors who contributed $5,000 or more, in violation of Government Code section 84105.
A committee who receives contributions of $5,000 or more from any person must inform the contributor that he or she may be required to file campaign reports. The notification must occur within two weeks of receipt of the contributions but need not be sent to any contributor who has an identification number assigned by the Secretary of State issued pursuant to Section 84101.
The details of the major donor contributions are as follows:
Major Donor |
Amount |
Date of Contribution |
Notification Due Date |
Date Notification Was Sent |
Days Late |
Gap Inc. |
$10,000 |
02/03/05 |
02/17/05 |
03/24/05 |
35 days |
GreenLeaf |
$5,000 |
01/01/06 |
01/15/06 |
05/10/06 |
114 days |
Charles Schwab |
$10,000 |
01/29/06 |
02/12/06 |
05/23/06 |
100 days |
Degenkolb Engineers |
$5,000 |
01/29/06 |
02/12/06 |
05/23/06 |
100 days |
Gap Inc. |
$10,000 |
01/29/06 |
02/12/06 |
05/23/06 |
100 days |
Pacific Telesis Group & Affiliates of SBC Communications Inc. |
$10,000 |
01/29/06 |
02/12/06 |
05/23/06 |
100 days |
Bechtel Corporation |
$5,000 |
06/27/06 |
07/11/06 |
07/13/06 |
2 days |
Parsons Brinckerhoff Quade & Douglas, Inc. |
$5,000 |
07/14/06 |
07/28/06 |
10/24/06 |
88 days |
CH2M Hill Companies, Ltd |
$5,000 |
07/21/06 |
08/03/06 |
10/24/06 |
82 days |
California Pacific Medical Center |
$5,000 |
10/25/06 |
11/08/06 |
01/17/07 |
70 days |
URS |
$5,000 |
11/06/06 |
11/20/06 |
01/17/07 |
58 days |
CB-1 Garage Co LLC – Millennium Partners |
$10,000 |
11/07/06 |
11/21/06 |
12/07/06 |
16 days |
VI. Committee’s Response to Finding
The Committee was provided an opportunity to review and comment on this audit report. The Committee’s comments are as follows:
The Committee sent the notification memorandum to all of these contributors before the filing deadline for the contributor’s Major Donor report. Because the PAC notified all of these contributors that they may have to file a Major Donor report before these reports were actually due, sending the notification memorandum more than 15 days after receiving the contribution did not cause any harm to the public.