Ethics Commission
City and County of San Francisco

Important Notice Regarding the San Francisco Lobbyist Ordinance

On January 1, 2010, the new amendments to the Lobbyist Ordinance took effect.   The Lobbyist Ordinance can be found at https://www.sfethics.org/ethics/2009/12/lobbyist-ordinance-2010.html.  

If you will meet the minimum threshold requirements to require registration as a lobbyist, you must register no later than five business days of qualifying.   Please register by providing the following information via email to either ethics.commission@sfgov.org or garrett.chatfield@sfgov.org :

  1. Your name
  2. Your firm, if any
  3. Your business address
  4. Your business telephone
  5. Your e-mail address
  6. A digital photograph of yourself (head and shoulders) in JPEG format, no larger than 2 megabytes

In addition, please send the $500 registration fee to the Ethics Commission at 25 Van Ness Avenue, Suite 220, San Francisco, CA   94102.   Your registration will not be complete until the Ethics Commission receives the registration fee and ALL of the required information listed above.  

At a training on the new ordinance, several issues were raised by lobbyists and below are some guidelines for you to follow.   Please contact the Ethics Commission is you have any questions.

Issue 1

How does a lobbyist add a client to his or her account without any promised payments?

Solution

The Commission has added a section to the lobbyist electronic filing system that will allow a lobbyist to list a client without the need to list an associated activity.   This will be implemented on January 31, 2010.

Issue 2

Can a lobbyist terminate before the end of the year?

Solution

The Commission will develop a method to be made available later this year that would allow a lobbyist to self-terminate in the lobbyist’s electronic account.   Once this is implemented, lobbyists will be notified of its availability.   Until its implementation, registered lobbyist must submit a signed letter to the Ethics Commission requesting to terminate.

Issue 3

The lobbyist ordinance requires a lobbyist to report the name, business address and business telephone number of each person from whom the lobbyist or the lobbyist's employer received or expected to receive economic consideration to influence local legislative or administrative action during the reporting period.  

How does a lobbyist working in a firm with multiple lobbyists report their economic consideration?

Solution

Any firm that employs multiple lobbyists may choose to designate a single individual lobbyist to be responsible for reporting the promised economic consideration to the firm from all clients.   Other lobbyists in the firm would not need to report any economic consideration promised to the firm.   All lobbyists in the firm will still report their individual contacts during the reporting period.

Alternatively, a firm with multiple registered lobbyists may elect to have each lobbyist individually report a proportional share of the promised consideration to the firm.   The firm should determine how to allocate promised economic consideration among the registered lobbyists such that the sum of all of the individually reported promised economic consideration equals the total economic consideration promised to the firm by each client.

Issue 4

The lobbyist ordinance requires lobbyists to report all political contributions of $100 or more made or delivered by the lobbyist or the lobbyist's employer, or made by a client at the behest of the lobbyist or the lobbyist's employer during the reporting period to an officer of the City and County, a candidate for such office, a committee controlled by such officer or candidate, or a committee primarily formed to support or oppose such officer or candidate, or any committee primarily formed to support or oppose a ballot measure to be voted on only in San Francisco. This report shall include such political contributions arranged by the lobbyist, or for which the lobbyist acted as an agent or intermediary.  

How does a lobbyist properly report political contributions of $100 or more?  

Solution

For a political contribution of $100 or more made by the lobbyist’s employer, the lobbyist’s employer may designate a single registered lobbyist at the firm or organization to report the contribution.   The lobbyist should identify the lobbyist’s employer as the source of the funds.

For a political contribution of $100 or more made by the individual lobbyist, the lobbyist should identify himself or herself as the source of the funds.

For a political contribution of $100 or more delivered by the lobbyist or lobbyist’s employer, made at the behest of the lobbyist or lobbyist’s employer, arranged by the lobbyist, or where the lobbyist served as an agent or intermediary, the lobbyist should identify the third-party source of the funds.   The lobbyist’s employer may designate a single registered lobbyist at the firm or organization to report contributions delivered or arranged by the employer.

A lobbyist who hosts fundraising events is responsible for reporting each contribution received during the event as the lobbyist is deemed to have “arranged” the contributions.   When multiple lobbyists within a firm host a single fundraising event, they may designate a single lobbyist to report the contributions arranged, received, or delivered as a result of the event.

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