This fact sheet describes “lobbying contacts” under the San Francisco Lobbyist Ordinance and explains how to count them. Understanding lobbying contacts helps in determining whether to register as a lobbyist and what to disclose in monthly lobbyist reports filed with the Ethics Commission.
Modes of Communication
A lobbying contact is any communication with a City officer to influence a local legislative or administrative action for which you are paid. All modes of communication are covered:
- In-person meetings, telephone calls, video conferences, texts, letters, faxes, and emails; and
- Communications with City staffers who you should expect will relay the conversation to the City officer, including departmental deputies and legislative aides.
Exceptions
Some communications with City officers are not considered contacts. For example, it is not a contact when you are:
- Making public comment or providing written testimony for a public hearing;
- Requesting to meet with a City officer, without making an attempt to influence;
- Making statements or providing testimony, as compelled by law;
- Providing information to the public by making a speech, appearing on TV, etc.
- Distributing information to members of your organization;
- Responding to RFPs or RFQs, without other contacts; or
- Communicating on behalf of a labor union for City employees regarding a collective bargaining agreement.
For a complete list of exceptions, see the Ethics Commission’s Lobbyist Manual.
Counting Contacts
Lobbyists must disclose each lobbying contact on their monthly reports; therefore, it is important to count such contacts accurately. Generally, the number of contacts depends on:
- How many legislative or administrative actions are discussed;
- How many officers you are meeting or otherwise communicating with; and
- When the communication is made.
Each communication to influence local legislative or administrative action can generally be considered a contact. Specifically:
- Each time you meet with ONE City officer regarding ONE local legislative or administrative action counts as ONE contact (i.e., 1 Action/1 Officer = 1 Contact; 2 Actions/1 Officer = 2 Contacts, etc.).Exception: a meeting with a City officer several times in one day about the same local legislative or administrative action will still count as ONE contact.
- Each City officer you meet about ONE local legislative or administrative action counts as ONE contact (i.e., 1 Action/1 Officer = 1 Contact; 1 Action/2 Officers = 2 Contacts, etc.).Exception: a meeting with a City officer and his or her staff member(s) about ONE local legislative or administrative action will still count as ONE contact.
NOTE: a communication about ONE real estate project is considered ONE local legislative or administrative contact.
The San Francisco Ethics Commission and the UC Hastings Center for State & Local Government Law collaborated to produce this fact sheet. Its guidance is necessarily general. Refer to the Lobbyist Ordinance and its implementing regulations regarding your specific situation.
Last Updated 12/8/14