August 2, 2019
This Audit Report summarizes the audit results for the committee Action Now Initiative (Nonprofit 501(c)(4))/Yes on V, FPPC Identification Number 1384702 (“the Committee”), for the period from January 1, 2016 through December 31, 2016. The Committee was selected for audit using an objective criteria method pursuant to Sec. 1.150(a) and 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 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 CFRO requires the Commission to audit all candidates who receive public financing and authorizes audits of other committees to be initiated 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 is based on documentation provided by the Committee and involved a review of the Committee’s filings and records for the period covered by the audit. This review was conducted to determine, among other things:
- Compliance with all disclosure requirements pertaining to contributions, expenditures, accrued expenditures, and loans, including itemization when required;
- Compliance with applicable filing deadlines;
- Compliance with any applicable restrictions on contributions, loans, and expenditures;
- Accuracy of total reported receipts, disbursements, and cash balances as compared to bank records; and
- Compliance with all record-keeping requirements.
The Commission posts to its website all Audit Reports. The Audit Division forwards Audit Reports to the Commission’s Enforcement Division, or other appropriate agency with jurisdiction, to enforce findings of non-compliance with the law. The scope of an audit is not exhaustive of all conduct by a committee during the audit period and conduct by a committee not identified as a material finding in an Audit Report may nevertheless be subject to investigation and possible enforcement by the Ethics Commission or another agency with jurisdiction to enforce applicable campaign finance laws, and a committee may be found to be in violation of such laws.
IV. Committee Information
The Committee is a 501(c)(4) multipurpose organization. Because of political expenditures made, the Committee qualified as a recipient committee under state law. Unlike other recipient committees, a multipurpose organization that qualifies as a recipient committee must report only its political expenditures and the sources of those funds. The Committee was established as a primarily formed committee on March 1, 2016 to support the passage of a ballot measure to enact a soda and sugary beverage tax in San Francisco in the November 2016 election. The measure was approved as Measure V by San Francisco voters in the November 2016 election to impose a tax on all soda and sugary beverages at a rate of one cent per ounce.
For the period covered by the audit, Ashley Hanna served as the treasurer and Shannon O’Leary served as the assistant treasurer. The Committee received $3,260,000 in contributions (the Committee did not receive any loans or non-monetary contributions) and made $3,260,000 in campaign contributions to committees in California. The Committee was terminated on December 31, 2016.
V. Audit Findings
The Commission concluded that there were no material findings with respect to the audit of the Committee.