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Ethics Commission Fines Permit Consultants $12,000 for Yearlong Omission in Disclosure Obligations, Fines Candidate Committees for Disclaimer Violations


Date: June 15, 2021
Contact: Pat Ford (415) 252-3100

At its monthly public meeting Friday, the San Francisco Ethics Commission approved four settlement agreements in which respondents admitted to violations of the City’s Campaign and Governmental Conduct Code and agreed to pay a monetary penalty. One of the settlement agreements, also referred to as a stipulation, pertained to failure to timely report permit consulting activities. The Commission also penalized three candidate-controlled committees and their treasurers for failing to include required disclaimers on their political advertisements.

Permit Consultant Settlement

The Commission fined Eun Young “Amy” Lee and Mark Luellen more than $12,000 for violating San Francisco Campaign and Governmental Conduct Code section 3.410(c) for four counts each, for a total of eight counts, for failing to timely disclose the permit consulting services that they provided to their clients over the course of calendar year 2020. Lee and Luellen, both former City employees, work together at the same consulting firm.

City law requires permit consultants to file quarterly reports with the Commission, and each quarterly report must contain basic information about the permit consultant’s activities. This helps the public understand instances in which a consultant is being paid by a client to help secure permits from the City. For each contact with the Department of Building Inspection, Entertainment Commission, Planning Department, or Department of Public Works, permit consultants must disclose the name of each City officer or employee with whom the permit consultant made contact, a description of the permit sought or obtained, and the client on whose behalf the contact was made. Permit consultants must also disclose the amount of payment the permit consultant received or expected to receive.

Because Lee and Luellen failed to disclose their permit consulting activity for a full year, they failed to timely report 80 contacts with City employees or officials on behalf of multiple clients for which they were collectively paid more than $50,000 for their services. As part of the stipulated agreement, the respondents acknowledged the violations, filed their outstanding reports, and agreed to pay a $12,670 fine, representing 25 percent of the income from their unreported services.

Political Advertising Disclaimer Settlements

The Commission also approved three settlements resolving liability for candidate campaign advertisements that failed to include proper disclaimers. In these, Supervisors Matt Haney, Rafael Mandelman, and Ahsha Safai – along with their committees and treasurers – acknowledged the political advertising violations and agreed to pay penalties ranging from $500 to $1000.

Each of these three settlements was executed under the Commission’s newer Streamlined Administrative Resolution Program, which the Commission adopted in February 2021. By establishing a standardized method for resolving an expanded range of matters through a streamlined stipulated settlement with the Ethics Commission, and by establishing a framework of standardized penalty formulas for violations of forty-one provisions of law across three articles of the Campaign & Governmental Conduct Code, the Streamlined Program is designed to provide accountability for violations of City laws while reducing the amount of time and resources required for a more formal case resolution. The Program accordingly allows the Commission’s investigative and enforcement staff to reserve a larger share of investigative resources for broader scope investigations of greater severity, complexity, and breadth.

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The San Francisco Ethics Commission was created directly by the City’s voters with the passage of Proposition K in November 1993 and is responsible for the independent and impartial administration and enforcement of laws related to campaign finance, public financing of candidates, governmental ethics, conflicts of interests, and registration and reporting by lobbyists, campaign consultants, permit consultants, and major developers. 

Our mission is to practice and promote the highest standards of integrity in government. We achieve that by delivering impactful programs that promote fair, transparent, and accountable governmental decision making for the benefit of all San Franciscans. Public service is a public trust, and our aim is to ensure that San Franciscans can have confidence that the operations of the City and County and the decisions made by its officials and employees are fair, just, and made without any regard to private or personal gain.

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