Ethics Commission
City and County of San Francisco

San Francisco Ethics Commission Final Audit Report: No on V, Enough is Enough: Don’t Tax Our Groceries, with Major Funding by American Beverage Association California PAC; FPPC ID #1382995

May 1, 2019

I. Introduction

This Audit Report summarizes the results of the audit of the committee No On V, Enough is Enough: Don’t Tax Out Groceries, with Major Funding by American Beverage Association California PAC, FPPC Identification Number 1382995 (“the Committee”), for the period from January 1 through December 31, 2016. The Committee was selected for 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 elections during the 2016 calendar year. 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

On February 18, 2016, the Committee was established as a primarily-formed ballot measure committee supporting a voter initiative to establish a tax on the distribution of sugar-sweetened beverages in San Francisco. This initiative became Measure V and was approved by voters in the November 8, 2016 election. The Committee was sponsored by the American Beverage Association California PAC, the political committee of the American Beverage Association trade organization that represents the interests of non-alcoholic beverage companies. The Committee terminated its status as of June 28, 2017.

For the period covered by the audit, Elli Abdoli, a campaign attorney of a political law firm Nielsen Merksamer, was the treasurer and Armeen Komeili, a campaign attorney of the same law firm, was the assistant treasurer. The Committee received $22,534,554.97 in contributions (including non-monetary contributions of $35,554.97) and incurred $22,645,376.19 in campaign expenditures (including non-monetary contributions of $35,554.97).

V. Audit Findings

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

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