Ethics Commission
City and County of San Francisco

San Francisco Ethics Commission Audit Report: Committee to Elect Eli M. Horn, FPPC ID #1305634

I. Introduction

This Audit Report summarizes the audit results of the committee, Committee to Elect Eli M. Horn, Identification Number 1305634 ("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 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; and
  5. Compliance with all record-keeping requirements.
  6. Compliance with all provisions related to the Commission's public financing program; and
  7. Determination of any unexpended public funds that must be returned to the Election Campaign Fund up to the amount of public funds received by the candidate.

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 was formed in March 2008 to support the election of Eli Horn to the District 11 seat of the Board of Supervisors in the November 4, 2008 general election. Reylita Bambilla 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 $15,020 in contributions,1 $680 in non-monetary contributions, and $30,960 of public financing. The Committee made qualified campaign expenditures of $49,031.2 The Committee did not have any unexpended funds.3

There was one material finding with respect to this audit. The Committee made cash expenditures of $100 or more, totaling $7,480, in violation of Government Code section 84300(b) and San Francisco Campaign & Government Conduct Code (S.F. C&GCC) section 1.106.

DateAmountPurpose
8/4/08$1,500Cash withdrawal of more than $100. Payments to canvass workers were $100 or greater.
8/8/08$600Cash withdrawal of more than $100.
8/14/08$880Cash withdrawal of more than $100. Paid $880 rent.
9/8/08$2,000Cash withdrawal of more than $100. Payments to canvass workers were $100 or greater.
9/12/08$2,000Cash withdrawal of more than $100.
10/22/08$500Cash withdrawal of more than $100.  Paid $500 to caterer.

Government Code section 84300(b), which is incorporated into local law by S.F. C&GCC section 1.106, provides that no expenditure of $100 or more may be made in cash.

VI. Committee's Response to Findings

The committee was provided with an opportunity to comment on this audit report.

The candidate, Eli Horn, stated that the committee's errors were not intentional. Mr. Horn explained that he was a "first time" candidate who made these errors because he was not aware of the rules. Mr. Horn stated that he stopped making cash payments when he realized that the committee was not allowed to make cash payments of $100 or more.


1 The committee reported receiving additional contributions during 2009, which this audit does not cover.

2 The committee reported making additional expenditures during 2009, which this audit does not cover.

3 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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