Lobbyists and Campaign Consultants – Late Filing Policy and Procedures

Policy and Procedure for Reduction or Waiver of Fines Imposed for the Late Filing of Lobbyist and Campaign Consultant Statements. 

Under San Francisco’s Lobbyist Ordinance, local lobbyists are required to register with the Ethics Commission and periodically report certain information about contacts with, and efforts to influence decisions by, City officers. (S.F. Campaign & Gov’t Conduct Code §2.100, et seq.) Similarly, San Francisco’s Campaign Consultant Ordinance requires campaign consultants to register with and report information about campaign consulting activity to the Ethics Commission. (S.F. Campaign & Gov’t Conduct Code §1.500, et seq.)

The late filing of lobbyist and campaign consultant registration statements, quarterly reports, and other required materials can deprive the public of important, time-sensitive information about local government. For this reason, local law mandates that the Ethics Commission impose late fines for each day after the deadline until the filings are received by the Commission. For lobbyists, the fine is $50 per calendar day. For campaign consultants, the fine is $50 per calendar day or $100 per calendar day if the deadline is fewer than thirty days before or after an election.

Policy. Under the Lobbyist and Campaign Consultant Ordinances, the Ethics Commission may reduce or waive a late filing fine if the Commission determines that the late filing was not willful and that enforcement will not further the purposes of the law. (S.F. C&GC Code §§ 2.145(a), 1.525(a).) However, because the majority of lobbyists and campaign consultants devote significant time and effort to ensure that such statements are complete and accurate as well as timely, the Ethics Commission is disinclined to grant reductions and waivers of late fines. Any one seeking a waiver has a heavy burden of demonstrating why enforcement will not further the purposes of the law.

Procedure. Any request for a reduction or waiver of late filing fines must be made in writing, signed by the filer, and addressed to the Executive Director of the Commission. The request must explain why the filer believes the late filing was not willful and enforcement will not further the purposes of the law. If the filing was late due to exceptional circumstances beyond the filer’s control (such as hospitalization, incapacitation or death of the filer, or loss of records due to natural disaster), the request should describe the exceptional circumstances and attach documentation.

The Executive Director’s determination regarding a request for a reduction or waiver of late filing fines shall be final.

The following do not constitute legitimate reasons for reducing or waiving late filing fines:

  • the filer was not aware of the law or its requirements;
  • the filer did not receive notice of filing requirements;
  • the filer was unavailable to sign forms;
  • the filer incorrectly addressed the filing;
  • the filer did not know where to obtain blank forms;
  • the filer did not have complete information by the filing deadline;
  • the filer did not receive or read his or her mail in a timely manner; and
  • secretarial error.

If you have questions or require additional information, please contact the Ethics Commission staff at 415-252-3100.

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