Ethics Commission
City and County of San Francisco

San Francisco Ethics Commission Audit Report: San Francisco Young Democrats, FPPC ID #961946

I. Introduction

This Audit Report summarizes the audit results of the committee, San Francisco Young Democrats, Identification Number 961946 (“the Committee”), from January 1, 2013 through December 31, 2014. The audit was conducted pursuant to the Commission’s random audit program 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 2014 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 the committee complied with applicable requirements of State and local laws.

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.

The Commission posts audit reports to its web site and, in cases of apparent violations of law, forwards them as appropriate for possible enforcement action.

IV. Committee Information

The Committee is a general purpose recipient committee formed to support endorsed candidates and to provide social and political opportunity for San Francisco young Democrats.  During the period covered by the audit, Ryan Blake and Julian Bartlett served as the Committee’s treasurers.  Carissa McFadden serves as the current Treasurer and Matthew Herrick serves as the current Assistant Treasurer.  The Committee remains open as of the date of this audit report.

V. Audit Findings

For the period covered by the audit, the Committee received $57,874 in contributions (including miscellaneous increases to cash of $7,385) and made $51,513 in campaign expenditures.

The Commission determined that there were two findings with respect to the audit of the Committee:   1) The Committee failed to maintain complete campaign records for campaign receipts (contributions and miscellaneous increases to cash) totaling $54,956 or 95 percent of total receipts, in violation of Government Code section 84104 and S.F. C&GC Code sections 1.106 and 1.109; and 2) the Committee failed to maintain complete campaign records for expenditures made totaling $23,597, or 46 percent of total expenditures made, in violation of Government Code section 84104 and S.F. C&GC Code sections 1.106 and 1.109.

Government Code Section 84104 and Campaign and Governmental Conduct Code Sections 1.106 and 1.109: Recordkeeping Regarding Contributions Received and Miscellaneous Increases to Cash

Government Code section 84104 provides that it is the duty of each candidate, treasurer and elected officer to maintain detailed accounts, records, bills and receipts that are necessary to prepare campaign statements, and to retain the documents for a period of four years following the date the appropriate campaign statement is filed.  Section 84104 is incorporated into the Campaign Finance Reform Ordinance at S.F. C&GC Code section 1.106.

The Committee did not maintain complete records for contributions received and miscellaneous increases to cash.  The Committee failed to maintain supporting documentation for campaign receipts totaling $54,956 or 95 percent of total receipts.  The contributions and miscellaneous increases to cash for which there was a lack of supporting documents were received over seven reporting periods: 1/1-6/30/13; 7/1-9/21/13; 9/22-10/19/13; 1/1-3/17/14; 5/18-6/30/14; 7/1-9/30/14; and 10/1-10/18/14.  The lack of recordkeeping prevented auditors from verifying the information that was reported on the Committee’s campaign statements.  See Attachment A to Audit Report.

Government Code Section 84104 and Campaign and Governmental Conduct Code Sections 1.106 and 1.109: Recordkeeping Regarding Expenditures Made

Government Code section 84104 provides that it is the duty of each candidate, treasurer and elected officer to maintain detailed accounts, records, bills and receipts that are necessary to prepare campaign statements, and to retain the documents for a period of four years following the date the appropriate campaign statement is filed.  Section 84104 is incorporated into the Campaign Finance Reform Ordinance at S.F. C&GC Code section 1.106.

The Committee did not maintain complete records for expenditures made.  The Committee failed to maintain supporting documentation for expenditures totaling $23,597, or 46 percent of total expenditures.  Consequently, the Commission was unable to fully verify whether the $23,597 in payments were appropriate campaign expenditures. These expenditures were made over ten reporting periods: 1/1-6/30/13; 7/1-9/21/13; 9/22-10/19/13; 10/20-12/31/13; 1/1-3/17/14; 3/18-5/17/14; 5/18-6/30/14; 7/1-9/30/14; 10/1-10/18/14; and 10/19-12/31/14.  The lack of recordkeeping prevented auditors from verifying the information that was reported on the Committee’s campaign statements.   See Attachment B to Audit Report.

VI. Committee’s Response to Findings

The Committee did not provide comments to the findings when given the opportunity prior to the release of this audit report.  However, previously during the audit, the Committee had stated the following:

“We are an amateur organization of young professionals interested in the political process. Our board is amateur/volunteer and our treasurers, in particular, had no formal training in campaign finance or compliance. When treasurers at SFYD were elected, they were handed loose records, loose receipts and a check book. We are continuing to work on our efforts to improve our systems, training, and reporting methods for future treasurers.”

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