Ethics Commission
City and County of San Francisco

San Francisco Ethics Commission Final Audit Report: Committee to Expand the Middle Class, Supported by Airbnb, Inc.; FPPC ID #1381999

May 10, 2019

I. Introduction

This Final Audit Report summarizes the results of the audit of the committee, Committee to Expand the Middle Class, Supported by Airbnb, Inc., FPPC Identification Number 1381999 (“the Committee”), for the period from April 24, 2016 through December 31, 2016. The Committee was selected using an objective criteria selection process, pursuant to the Commission’s authority under San Francisco Charter Section C3-699-11(4) and San Francisco Campaign and Governmental Code Section 2.135, from a pool of eligible committees active in San Francisco elections during calendar year 2016. The audit was conducted by Ethics Commission staff following the 2016 City election as part of the Commission’s 2016 audit cycle 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 materially complied with applicable requirements of State and local laws. Section 1.150(a) of the CFRO requires the Commission to audit all candidates for City elective office who receive public financing and authorizes other audits to be initiated of other committees irrespective of whether the committee received any public funds.

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 to the appropriate enforcement agency.

IV. Committee Information

The Committee was sponsored by Airbnb, Inc., a hospitality and travel lodging company based in San Francisco. The Committee qualified as a state general-purpose committee on January 16, 2016. The Committee’s organized “to support and/or oppose state and/or local candidates and ballot measures in the June and November 2016 elections”. On May 25, 2016, the Committee amended its status to county general-purpose committee and started filing campaign statements and disclosure reports with the San Francisco Ethics Commission. This change in filing status was triggered as a result of contributions made by the Committee to San Francisco based committees and candidates. On October 18, 2016, the Committee amended its status back to a state general-purpose committee as a result of an increase in spending on non-San Francisco based candidates and ballot measures (e.g. committees at the state level and in other jurisdictions). As required by law, the Committee continued filing copies of its campaign statements with the Ethics Commission through the period ending December 31, 2016. As of the date of this report the Committee is still active as a state general purpose committee.

For the period covered by the audit, Kevin Heneghan served as the treasurer and Patricia Mar was the Committee’s compliance officer. The Committee received $1,600,001 in monetary contributions and incurred $986,036.84 in campaign expenditures.

V. Audit Findings

The Commission determined that there were no material findings with respect to the audit of the Committee.

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