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San Francisco Ethics Commission Audit Report: UNITE HERE Local 2 PAC, FPPC ID #1243324


I. Introduction

This Audit Report summarizes the audit results of the committee, UNITE HERE Local 2 PAC, Identification Number 1243324 (“the Committee”), for the period from January 1, 2014 through December 31, 2015. 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). The Committee was selected for random audit from the 2015 audit cycle.

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:

A. Compliance with all disclosure requirements pertaining to contributions, expenditures, accrued expenditures, and loans, including itemization when required;
B. Compliance with applicable filing deadlines;
C. Compliance with restrictions on contributions, loans, and expenditures;
D. Accuracy of total reported receipts, disbursements, and cash balances as compared to bank records;
E. Compliance with all record-keeping requirements;
F. Compliance with all provisions related to the Commission’s public financing program; and
G. 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 apparent violations of law, forwards them to the appropriate enforcement agency.

IV. Committee Information

The Committee qualified as a committee on January 1, 1990 to conduct political activities for its sponsor, Unite Here Local 2. For the period covered by the audit, Lamoin Warlein-Jaen served as the treasurer and Ian Lewis served as assistant treasurer. At the time this report was issued, the treasurer was Tina Chen and Ian Lewis was the assistant treasurer. Also, the Committee had not terminated as of the date of this report.

V. Audit Findings

For the period covered by the audit, the Committee received $406,446 in contributions (including non-monetary contributions of $32,898) and incurred $374,273 in campaign expenditures.

The Commission determined that there was one finding with respect to the audit of the Committee: 1) the Committee failed to file FPPC Form 497 Late Contribution Report (FPPC Form 497) for two late contributions it made totaling $9,100 of the $144,490 required to be reported on FPPC Form 497, or 6 percent, in violation of Government Code sections 82036 and 84203.

Government Code Sections 82036 and 84203: Late Contribution Reports

Government Code section 82036 identifies a late contribution as a contribution, including a loan, that totals in the aggregate one thousand dollars ($1,000) or more and is made to or received by a candidate, a controlled committee, or a committee formed or existing primarily to support or oppose a candidate or measure during the 90-day period preceding the date of the election, or on the date of the election, at which the candidate or measure is to be voted on. Government Code section 84203 requires each candidate or committee that makes or receives a late contribution, as defined in Section 82036, to report the late contribution within 24 hours of the time it is made in the case of the candidate or committee that makes the contribution and within 24 hours of the time it is received in the case of the recipient.

The Committee made 22 late contributions totaling $144,490 that it was required to disclose on FPPC Form 497 within 24 hours of making the contributions. Of these 22 late contributions, the Committee reported 20 late contributions totaling $135,390 on FPPC Form 497. The Committee did not file FPPC Form 497 for two contributions totaling $9,100, which represents 6% of the total amount required to be reported on FPPC Form 497. The contributions for which the Committee did not file late contributions reports were made during the 90-day periods preceding the November 4, 2014 and November 3, 2015 elections.

Election Date Name of Committee to whom Contribution was made Date of Contribution Amount Type of Contribution
11/03/2015 Committee to Save the Mission, Yes on Prop. I 09/03/2015 $5,000 Monetary
11/04/2014 David Campos for Assembly 2014 08/28/2014 $4,100 Monetary

Total Not Reported on Form 497 Late Contribution Report: $9,100
Percentage of Contribution Amount Not Reported on Form 497 Late Contribution Report: 6%

VI. Committee’s Response to Findings

The Committee provided the following comment in response to the audit finding:

“We have reviewed the draft audit report and do not dispute the preliminary finding. The two contributions were reported later on Form 460 but due to an oversight we failed to report them within 24 hours on Form 497. This was entirely inadvertent. These contributions represent a very small portion of the contributions we have made—which were otherwise found to have been correctly reported—and we have always attempted to fully comply with all provisions of the Political Reform Act and Campaign Finance Reform Ordinance. Unfortunately, we did not do so in this case, but we will do our best to make sure this does not happen again.”

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