Ethics Commission
City and County of San Francisco

San Francisco Ethics Commission Audit Report: Tom Valtin for Supervisor, FPPC ID #1309850

I. Introduction

This Audit Report summarizes the audit results of the committee, Tom Valtin for Supervisor, Identification Number 1309850 (“the Committee”), for the period from January 1, 2008 through December 31, 2008.  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.  Section 1.150(a) of the CFRO requires the Commission to audit all candidates who receive public financing.

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 expenditures;
  4. Accuracy of total reported receipts, disbursements, and cash balances as compared to bank records;
  5. Compliance with all record-keeping requirements;
  6. Compliance with all provisions related to the Commission’s public financing program; and
  7. Any unexpended public funds that must be returned to the City up to the amount of public funds received by the candidate. 

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

IV. Committee Information

The Committee was formed in August 2008 to support the election of Tom Valtin to the  Board of Supervisors, District 9.  Tom Valtin served as the treasurer.  The Committee was active as of December 31, 2008.

V. Audit Findings

For the period covered by the audit, the Committee received $15,188 in contributions and $17,168 in public funds and incurred qualified campaign expenditures of $32,173.  The CFRO provides that any candidate who receives public funds must return unexpended campaign funds to the City up to the amount of public funds received by the candidate (San Francisco Campaign and Governmental Conduct Code (S.F. C&GC Code) § 1.148(d)).  The Committee does not have any unexpended funds to return; on November 14, 2008, the Committee returned $308.87, which was the amount that remained in its contingency account. [1]

There was one material finding with respect to this Audit Report.  The Committee failed to timely disclose expenditures of $6,178, or 19 percent of the total expenditures made, in violation of Government Code Sections 84211(b) and (i).

Government Code Section 84211:  Failure to Timely Report Expenditures Totaling $6,178

The Act requires that all campaign expenditures incurred be reported on the campaign disclosure statements. (Government Code Section 84211 (b)).  In addition, for each reporting period, the campaign statements must contain the total amount of expenditures made during the period covered by the campaign statement to persons who have received one hundred dollars ($100) or more (Government Code Sections 84211 (i)).  An expenditure can be disclosed on various schedules of the campaign statements depending on whether it was paid. (Government Code Sections 84211 (b) and (i)).

The Committee failed to timely report expenditures of $6,178, or 19 percent of total expenditures.  The Committee was required to report the expenditure based on the earlier of when the expenditure was paid or when the Committee received the goods or services.  During the reporting period covering 10/1-10/18/08, the Committee incurred and paid for an expenditure of $6,178 related to mailing costs.  This expenditure should have been reported on Schedule E (“Payments and Contributions Made”) of the campaign statements covering through 10/18/2008.  Instead, the Committee reported this expenditure on the campaign statements of the subsequent period covering through 12/31/08. 

VI. Committee’s Response to Finding

Ben Avery, the Committee’s campaign manager, states that the Committee fully intended to and provided provide proper documentation to the Commission for the $6,178.50 expenditure.  The campaign manager also states that although a timing mistake may have been made with reporting, the expenditure was reported and documented during the following reporting period. 


[1] Unexpended funds are calculated by subtracting any unpaid bills, on-going qualified campaign expenditures, and forfeitures from the amount of cash that the Committee had on the 30th day following the date of the election.

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