The Ethics Commission provides two kinds of advice: written formal opinions and informal advice. S.F. Charter § C3.699-12. Written formal opinions are available to individuals who request advice about their responsibilities under local law. Formal opinions provide the requester immunity from subsequent enforcement action if the material facts are as stated in the request for advice, and if the District Attorney and City Attorney concur in the advice. See id. Informal advice does not provide similar protection. See id.
Past Advice Letters
| Date of Letter | Person Requesting Advice | Subject Matter |
|---|---|---|
| June 9, 2009 | Jess Mainardi | FPPC Regulation 18405 – Electronic Filing Requirements |
| April 13, 2009 | Patrick Buscovich | Application of compensated advocacy ban |
| City Attorney’s Concurrence | ||
| District Attorney’s Dissent | ||
| March 29, 2009 | Jesse Mainardi | FPPC Regulation 18405 |
| March 23, 2009 | Enrique Pearce | Campaign Finance Reform Ordinance (liability for accrued expenses) |
| September 15, 2008 | Arnie Lerner | Compensated Advocacy Waivers |
| June 27, 2008 | Stuart Sunshine | Post Employment Restrictions |
| December 3, 2007 | Dean L. Macris | Conflict of Interest Laws |
| November 30, 2007 | Ed Harrington | Conflict of Interest Laws |
| March 12, 2007 | Beverly J. Prior | Contracts with the City (SF C&GC Code sec. 3222) |
| City Attorney’s Concurrence | ||
| District Attorney’s Response | ||
| October 24, 2006 | Kevin Heneghan | Miscellaneous Concerns on C.F.R.O. |
| April 17, 2006 | Erich Seamon | Post Employment Restrictions |
| December 22, 2005 | Peter Bagatelos | Campaign Finance Reform Ordinance (electioneering communications) |
| November 10, 2005 | Gregory E. Swanson | Campaign Finance Reform Ordinance (application of 1.126 contribution ban to PAC of bank) |
| November 15, 2005 | Randall G. Knox | Compensated Advocacy Ban (C&GC 3.224)(application of ban to attorney engaged in practice of law) |
| October 11, 2005 | Vigo G. Nielsen,Jr. | Campaign Finance Reform Ordinance (application of section 1.135 to state major donors) |
| January 13, 2005 | Anthony Hall | Post Employment Restrictions |
| City Attorney’s Concurrence | ||
| District Attorney’s Response | ||
| January 4, 2005 | James R. Sutton, Esq. | Filing Obligations of Major Donors |
| December 20, 2004 | Ross Mirkarimi | Sections 1.114 and 1.200 of S.F C&GC Code (inaugural activities) |
| November 30, 2004 | Jim Lazarus | Campaign Finance Reform Ordinance (contributions from member of-non-profit) |
| August 5, 2004 | Gregory Asay | Post Employment Restrictions S.F. C&GC Code § 3.234 |
| City Attorney’s Concurrence | ||
| District Attorney’s Response | ||
| August 15, 2003 | Rob Black | Lobbyist Ordinance |
| August 12, 2003 | James R. Sutton, Esq. | Lobbyist Ordinance |
| April 7, 2003 | James R. Sutton, Esq. | Proposition J (application to non-profit organizations) |
| December 11, 2002 | Anita D. Stearns Mayo | Campaign Finance Reform Ordinance (transferred contributions) |
| August 15, 2002 | Peter A. Bagatelos | Campaign Finance Reform Ordinance |
| April 25, 2002 | H. William Brown | S.F. Charter Section C8.105(e) Post Employment Restrictions |
| City Attorney’s Concurrence | ||
| District Attorney’s Response | ||
| March 5, 2002 | Jared Blumenfeld | Taxpayer Protection Amendment of 2000 |
| City Attorney’s Concurrence | ||
| District Attorney’s Non-Concurrence | ||
| February 19, 2002 | Ron Dudum | Campaign Finance Reform Ordinance |
| February 19, 2002 | James R. Sutton, Esq. | Campaign Finance Reform Ordinance |
| November 5, 2001 | James R. Sutton, Esq. | Campaign Consultant Ordinance |
| September 24, 2001 | James R. Sutton, Esq. | Campaign Consultant Ordinance |
| September 20, 2001 | Vernon M. Billy | Lobbyists Ordinance |
| September 20, 2001 | H. William Brown | SF Charter Section C8.105(e), Post Employment Restrictions |
| July 23, 2001 | H. William Brown | SF Charter Section C8.105(e), Post Employment Restrictions |
| July 20, 2001 | Tim Kelley | Contracts with the City |
| May 15, 2001 | William W. Fay, D.D.S. | Compensated Advocacy Ordinance |
| May 9, 2001 | Christopher L. Bowman | Campaign Consultant Ordinance |
| February 21, 2001 | Merrill J. Schwartz, Esq. | SF Charter § C8.105(e) Post Employment Restrictions |
| June 22, 2000 | Esther Marks | Campaign Finance Reform Ordinance |
| City Attorney’s Concurrence | ||
| District Attorney’s Dissent | ||
| March 22, 2000 | James R. Sutton, Esq. | Campaign Finance Reform Ordinance |
| March 15, 2000 | Roger Sanders | Campaign Finance Reform Ordinance |
| March 10, 2000 | Supervisor Tom Ammiano | Campaign Finance Reform Ordinance |
| August 16, 1999 | James R. Sutton, Esq. | Campaign Consultant Ordinance |