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Minutes – February 25, 2022


Minutes of the Special Meeting of
The San Francisco Ethics Commission
Friday, February 25, 2022
Remote Meeting Held Online via WebEx and aired live on SFGovTV
(Approved April 8, 2022)

Note: SFGovTV provides a continuous archive of audio, video, and Caption Notes recordings of Ethics Commission meetings that allows viewers to watch those meetings online in full at the viewer’s convenience. These archives of Ethics Commission meetings may be accessed at SFGovTV at

(Note: A complete video recording of this meeting is available at SFGovTv.)

COMMISSION MEMBERS PRESENT: With Chair Yvonne Lee and Commissioners Michael Romano, Larry Bush, Daina Chiu, and Theis Finlev attending, a quorum was present.

STAFF PRESENTING: LeeAnn Pelham, Executive Director; Michael Canning, Policy Analyst; Ronald Contreraz, Online Meeting Moderator.




Item 1. Call to order and roll call.

Chair Yvonne Lee convened the meeting at 10:02 am and stated that the meeting is being held by Teleconference Pursuant to the Governor’s Executive Order N-29-20 and the Twelfth Supplement to Mayoral Proclamation Declaring the Existence of a Local Emergency Dated February 25, 2020. Online Meeting Moderator Ronald Contreraz summarized procedures for remote participation by members of the public.

Item 2. Public comment on matters appearing or not appearing on the agenda.

Maria Jenson, the executive director SOMA Arts Cultural Center stated strong disapproval and concern about the proposed measure, described the redefining of meaning of gift as punitive, expressed concern that the greatest negative impact would be on the on the BIPOC community. She said that the arts & culture sector needs to build community and that many of its events are free.

Vinay Patel, the director of APICC expressed concern about proposed ballot measure and its impact on BIPOC community. Cultural events allow people to feel part of community and the measure could be a barrier to that. There is a need to understand and navigate the law, which can be harmful. Also, if officials need to fill out forms to attend events, they might start choosing between events.

Amber Hasselbring, the director of Nature in the City stated that she finds the ballot measure troublesome and thinks it will make it harder for groups to participate with city. She asked how will it work? How will organizations need to report? With the corruption scandals, it’s already difficult to get projects moving. She said she doesn’t want to see nonprofits pay for City corruption.

Item 3. Public hearing, discussion, and possible action on proposed amendments to strengthen City’s gift and ethics laws through a) a potential ballot measure for the June 7, 2022 election, and b) amended Commission regulations.

Chair Lee noted the City representative scheduled for Item 4 needs to leave by noon and that if the Commission is still on Item 3 at 11:00am they will move to Item 4 at that time.

Chair Lee stated the special meeting was designed further engage members of the community on the proposed ballot measure and that the purpose of ballot measure is to strengthen city’s restricted sources gift rules and strengthen bribery rules.

Commissioner Romano stated that if callers see proposed provisions that they think will be harmful to their organizations, pointing to the specific provision will be helpful.

Commissioner Bush stated he welcomes comments from community-based nonprofits and noted reports from Controller identifying loopholes in gift rules. He said he hopes that nonprofits have read the eight reports issued over two years.

Commissioner Finlev asked City representatives to explain if there’s an importance to attend an event for the City, can the City pay for it and not rely on gifts? He asked community representatives to be specific about what their concerns are about impact on their interactions with City officials.

Chair Lee explained the process for the discussion panel with representatives from City Departments and reiterated that it would be most helpful if representative were very specific about their concerns and how these changes would impact their organizations. She also expressed a desire to hear their recommendations.

John Caldon from the War Memorial noted a letter was sent by nine department heads requesting that a racial equity analysis be conducted of the ballot measure. He noted that Friday morning meeting cannot be attended by all nonprofit employees and that the documentation is too voluminous to read.

Caldon stated that arts and culture departments are charged with providing grant funding and must ensure taxpayer money is being used properly. They must go to shows to verify city-funded works, and that the only way to see how a facility is operating is to go to the event, which requires a ticket. He stated he doesn’t think city / taxpayer money should be used to pay for city staff to go to city-operated buildings.

Caldon noted the FPPC does not consider a ticket as described above to be a gift. He said Ethics staff were able to identify tickets that War Memorial gave out because the dept already uses the Form 802; it’s a transparent process. The Form 802 process allows arts & culture departments to connect with the community. Caldon stated a belief that the existing framework is working.

Commissioner Romano pointed out that the concern is not city officials attending events for their jobs, but for purely entertainment purposes and asked Caldon for his thoughts on this.

Caldon argued these tickets are not for enjoyment and that they often are going to a show outside of work hours.

Commissioner Romano re-pointed out the concern is that it is not a ticket for job purposes but for enjoyment and asked about tickets for a plus-one.

Caldon responded that plus-ones can be a “secret shopper” that gives an outside eye to the operations or venue. He noted that the FPPC rules allow a plus-one.

Commissioner Finlev stated that the proposal allows tickets for necessary purposes. He asked if the proposal would impact this necessary function.

Caldon stated he has not seen revised language and does not know what Ethics Staff’s position is. He questioned who will make the determination of “necessary”—the appointing officer or Ethics staff? He noted a Form 802 must identify public purpose of a ticket.

Commissioner Finlev asked Caldon if he will be willing to work with ETH staff to work on language to define public purpose.

Caldon reiterated that a law already exists that does so this defining.

Commissioner Finlev asked about limits on the number of shows.

Caldon stated that the policy already includes that—limits how many tickets public official can accept. Stated that Ethics Staff could have engaged with departments on refining their policy, creating regulations, and working within existing law.

Commissioner Chiu asked what other provisions of the regulations or ballot measure are problematic for Mr. Caldon.

Commissioner Romano clarified that the ticket rules are in proposed regulation amendments.

Caldon discussed nonprofits being impacted by a sweeping law and stated that he supports strengthening of bribery laws and timely enforcement. He stated a nonprofit that won’t receive training and that isn’t attempting undue influence but just to engage community has a chilling effect.

Commissioner Chiu asked how would a prohibition on giving a gift chill engagement. Caldon said determining what is allowed to give can get blurred and confusion could scare people off, especially small nonprofits.

Commissioner Chiu stated the concern is that city dollars that flow to an entity have strings attached. The point of the proposals is to prevent organizations that receive City funds from providing gifts back to officials responsible for renewing their contracts (be it vendor or grantee).

Caldon stated he thinks existing laws do this already. Commissioner Chiu expressed disagreement, stating that we’ve had federal indictments, some of the corrupt activity was not prohibited by the City. She stated that a culture change is necessary, that it is important to understand that if you work for an organization with ties to the City, you need to be careful about gifts.

Caldon stated that in the new rules the definition of restricted sources becomes much broader, “thing of value” is too broad and there is no de minimis exception. Being prevented from accepting anything could be rude or damaging in some communities.

Commissioner Chiu clarified this is not a blanket ban on gifts, but on a director that wants to give a gift to the city official making the decision to renew contract or grant.

Caldon noted that the only entities he needs to interact with are restricted sources. The entities he’s doing business with – those are the relationships he’s supposed to be forming. He does not believe a minor gift would cause a city official to inappropriately award a contract.

Commissioner Chiu asked what done now would the ordinance prevent?

Caldon mentioned small Christmas gifts, cards, gift baskets (cookies, juice)—the proposal would ban all this.

Commissioner Romano asked if setting a de minimis dollar value fix this problem?

Caldon respond yes and noted that existing law already sets a dollar value.

Deputy City Attorney Andrew Shen clarified gift rule sets de minimis gift value of $25 and that the proposed regulation amendments would set a $15 de minimis value for routine office courtesies received at the office of a restricted source.

Commissioner Bush asked if de minimis gifts can be cash. Caldon responded no, cash is prohibited.

Commissioner Bush continued that other than state and federal bribery rules, there is nothing to stop Nuru from soliciting gifts for parties. He asked if Caldon had looked at the Controller’s recommendations. Caldon said he hasn’t seen all the reports. Regarding behested payments, he applauds Ethics for going after the root of the issues.

Commissioner Bush asked if there is a ceiling on number of tickets to a recipient, and Caldon responded that yes, there is already a ceiling in department ticket distribution policies.

Commissioner Bush asked if after an event, a City official who attended an event needs to write a report. Caldon stated that yes, this is required by the FPPC as part of the Form 802, though what constitutes a report is not clarified and it could be strengthened.

Commissioner Bush asks if their ticket policy changed in past 15 years. Caldon responded that no, it has not and could be updated.

Commissioner Bush asked how much are orchestra seats. Caldon responded that they are $50-$250. Commissioner Bush state that the tickets would exceed the gift limit. Caldon explained that the FPPC doesn’t consider it a gift.

Commissioner Bush asked about what the public’s response is to this system. Caldon stated he thinks the public would expect that War Memorial staff would attend shows at the facility they oversee.

[Chair Lee paused discussion of Item 3 to move to Item 4; discussion of Item 3 resumed at 12:55pm]

Shawn Rosenmoss from the Department of the Environment stated that there is no racial equity scan of the ordinance, and the Commission hasn’t told why it has not done one. This will have a chilling effect on partnerships with community organizations; the commission has not demonstrated that proposals will not have such an effect. Hopes the commission will listen to their concerns.

Commissioner Finlev asked Rosenmoss to describe the impact on the department. Rosenmoss stated she is not the department head and she doesn’t know specifics. She thinks small nonprofit organizations will not read to understand all the laws, and they will simply not invite City officials to attending events. She stated that there are some things in there that department heads want clarified or taken out.

Rosenmoss said to do a racial equity scan—ask what the unintended consequences are. Why hasn’t the commission done it this? She is concerned that impacted people will not be able to voice concerns at 3-hour meeting on a Friday. Commissioner Finlev agreed that a racial equity plan should be discussed.

Commissioner Finlev asked what actual gift objects are being given. Rosenmoss responded with an example of a local restaurant donating food. She asked how many events could be attended before she reaches the limit on allowable food, and how to track and report that.?

Chair Lee clarified that if everyone is invited to freely share in provided food, this is not the issue. The issue would be a private luncheon.

Policy Analyst Michael Canning confirmed that things freely available to the public are not considered gifts under the law. He noted that we already have a restricted source rule with exceptions, and that deptments are already doing what they need to do to comply—the proposal is amending that existing rule.

Rosenmoss stated that it is not about letter of the law. You can tell each organization 1,000 times, but it still creates an atmosphere—organizations will need to worry about how to report. The proposed law would create an atmosphere, this is what other CBOs have been saying.

Commissioner Bush stated that he thinks the current atmosphere in City Hall is that it’s about who you know, trading favors.

Rosenmoss asked Commission Bush for data on that claim.

Commissioner Bush responded that he has experience in City government and can read the newspapers.

Extended public comment began.

Charles Head, the president Coalition for SF Neighborhoods (CSFN) stated he was firmly in favor of the ballot measure. Other organizations say they have a problem with this proposal because grantees will get confused, but Head stated he believes that this is not a valid concern—reasonable people will do reasonable things regarding the giving of gifts. Not understanding the law is not an excuse.

Head noted that his organization has run afoul of gift laws before, they recognized their mistake and paid a fine. The idea that the proposal would ban gifts outright is incorrect. CSFN would like this proposal to be on June ballot.

Commissioner Finlev ask what top three parts of proposed measure does Head believe would benefit the city? Head responded that CSFN is in favor of all that is the ballot measure.

Commissioner Chiu asked for Head’s thoughts on chilling effect raised by other organizations. Head responded that organizations already have forms, procedures, vetting—CSFN already requests information from its grantees. He does not think that adding additional reporting will cause organizations to not want to deal with the city outright.

Mary Kate Bacalao of Compass Family Services stated she opposes measure on behalf of homeless services organizations. The measure should allow public officials to accept tickets to non-profit orgs, especially those representing people of color. Analysis shows that nonprofit finances are fragile due to lack of investment and burdensome reporting requirements. She stated it is vital that public officials can attend nonprofit fundraisers. Members of the public should not face criminal or civil penalties for gifts that don’t meet the definition of bribery.

Bacalao stated gift laws should not burden nonprofits. Vague language could be enforced selectively to target politically unpopular or minority organizations. She said the proposal does not differentiate de minimis everyday gifts, e.g. a cup of coffee. Bacalao compared proposed rules to public assistance rules from Trump administration which were complicated, and many immigrant families avoided seeking public assistance rather than risk violating complex rules. It is important for the Commission to consider how different sectors will be impacted by overly broad language, particularly housing and human services.

Commissioner Finlev asked Bacalao to clarify regarding free tickets to fundraisers – would city officials not go if a ticket was not free? Bacalao responded that it is important to make it as easy as possible for public officials to attend.

Commissioner Finlev asked if other organizations will see that public officials are there, then think this must be a good organization? Bacalao responded that it says a lot when high-profile people show up to support an organization that supports front-line workers.

Finlev asked about how much fundraisers cost to attend. Bacalao said that she couldn’t say, anywhere from $50-300. There’s a fee to attend, then the idea is that people also donate at the event, e.g. through a silent auction.

Commissioner Finlev asked Ethics staff if the proposal is to get rid of affiliated entity rule. Canning clarified that previous proposal was to remove liability for giving a gift, while the other proposal was that only affiliates of an organization would not be penalized.

Bacalao said they are not familiar with affiliate language. They think it is important for nonprofit board members and officers to be able to interact with public officials. Bacalao said she thinks that criminal or civil penalties should not be enforced for, for example, giving a cup of coffee.

Commissioner Bush stated that his understanding is that nonprofit organizations are not required to disclose City Hall contacts like lobbyists.

Bacalao said that 501c3 organizations are required to disclose amounts spent lobbying to the IRS.

Bush said that this discloses how much nonprofits spent, not which City officials they met with. Noted that there are nonprofits with millions of dollars in donations that do not disclose their contributors.

Bacalao said that some nonprofits do disclose on their websites who their donors are.

Chair Lee stated that she sympathizes with nonprofits with tight budgets. She thinks Commissioners need to clarify and specify concerns raised. In her experience, nonprofits want to highlight the public officials who are involved. Chair Lee asked for clarification regarding if a department representative is invited to a nonprofit, is that allowable?

Canning clarified there is a current exception for City officials to attend nonprofit events that are necessary for their role. Also clarified that currently a greeting card likely does not count as something of value; the measure can clarify that written communications could be specified as not being of value. Noted that proposal to remove general $25 de minimis value was because departments have bundled gifts individually less than $25.

Shen recommended that the above be clarified in the regulations, e.g. define “necessary” and define “thing of value.”

Sean McMorris from California Common Cause read from statement he earlier submitted to Commission. California Common Cause supports the reforms in the measure except for increased gift-giver liability. Gift-givers may be unfamiliar with the law may and may not be bad actors. Chasing down gift-givers is resource intensive. Rather, the impetus should be on City employees who should be made known that they need to be vigilant about not accepting gifts from individuals they have business with. He said California Common Cause supports the measure if it is amended to remove liability for gift-givers, except for lobbyists and permit consultants.

Commissioner Finlev asked if McMorris can speak to how San Francisco compares to other municipalities’ ethics commissions? McMorris replied that cities large enough to have ethics laws and that the best comparisons are Los Angeles and San Jose. Los Angeles’s restricted sources laws are robust and they only place liability on gift receivers. He said San Jose’s law is quite vague, but it appears to place liability on both the givers and receivers of restricted gifts.

Kaushik Roy of the Shanti Project spoke about concerns of what would happen if proposal moved forward. San Francisco has a unique and innovative public health model—one of the biggest reasons is the special access and relationships that nonprofits have with City officials. It is important to build relationships and trust. Roy thinks the chilling effect would be real, especially with fines and penalties involved. Working for a nonprofit is already thankless, this would be another layer of difficulty.

Roy added that he believes it is the clients of nonprofits that will pay the price of the chilling effect. At beginning of pandemic, Shanti was asked to spearhead a support program—this happened because of its relationships with the City. The Commission should do a racial impact report. There is a disconnect between what Commissioners are focusing on and what speakers are focusing on. The Commissioners are focused on letter of the law, but the community is saying it’s not about letter of the law, it is about the unintended consequences.

Commissioner Romano said that we don’t want unintended consequences and we don’t want to create undue burden. What if smaller budget organizations—whatever that may be—was exempt from these laws? Would that alleviate his concerns? Roy responded that it potentially would. He believes that the current language would more negatively impact the smaller organizations not the larger ones.

Commissioner Finlev asked if there are specific activities that would be chilled? Roy responded that it’s all about the relationships—interactions, meals, attending events. Officials come to events to learn about an issue or an organization.

Commissioner Bush stated there are other rules we can look at, for example in Los Angeles, laws don’t apply to organizations that file an abbreviated 990, or that provide housing, receive public funding, etc. A lot of the provisions viewed as concerning would not come into play in San Francisco if we exempted groups that file abbreviated 990s. Roy said he agrees with this suggestion and wants to clarify that if the Commission doesn’t rush this process, the Commission and the organizations can agree and get this right.

Commissioner Bush clarified that he was not advocating for a delay and that the public expects action. Commissioner Bush is concerned we haven’t heard from the police union, building trade union, etc.

Kathie Lowry from Larkin Street Youth Services spoke in support of the measures, however, she said that aspects of the law could negatively impact relationships. The restricted source definition is overly broad, extending to members of the public engaged in public advocacy. Also, the attempt to influence language is vague. Lowry asked about what kind of staffing will be devoted to this. The broader definition of restricted sources could draw staff resources away from more serious violations.

Lowry stated she wants to expand the language to allow officials to attend events even if not directly involved and wants to remove the cap on the number of events. Attending events gives City officials the opportunity to participate and inspire increased private giving. Lowry stated she wants an exception for giving a plaque or similar symbol of recognition. She believes the Commission should focus on the most threatening entities, not the smaller nonprofits.

Commissioner Bush asked about groups like the America’s Cup, with a $12 billion budget from City contractors, or sister city committees, under direct control of an elected City official, how do those fit in? Lowry noted most of the callers are from smaller community nonprofits and thinks the above does not apply to the concerns raised by callers.

Commissioner Bush clarified the proposal does not make a distinction between the two types off nonprofits and asked if Lowry thinks there should be a distinction. Lowry responded that she thinks it would be worth looking at.

Commissioner Finlev stated he thinks it is worthwhile to look at distinguishing between different types of entities. Asked Lowry to clarify events attended by unaffiliated entities. Lowry stated her understanding is that officials who attend an event must be directly affiliated with the organization putting on the event. Lowry also said she was in favor of uncompensated board members being exempted.

Debbi Lerman from the San Francisco Human Services Network stated the measure goes too far regarding nonprofit fundraisers. Nonprofits should be able to provide free tickets to public officials. The language in the proposal is vague. It is common practice to provide officials with free tickets, this allows community-based organizations to build relationships with City officials, especially those representing underrepresented groups.

Lerman stated that regarding restricted sources, the measure equates small everyday gifts with bribery and equates any interaction expressing a policy position to lobbying. This proposal would turn thousands of people into restricted sources.

Lerman said that the $15 limit on in-office courtises is unrealistic in San Francisco and has no provision to adjust for inflation.

Lerman said gift laws need to focus on highest-risk bad actors, not casting suspicion broadly on community-based organizations. The law would go too far into innocent day-to-day interactions.

Commissioner Finlev stated that one of Lerman’s proposals in her letter was to adjust the language regarding “beneficial to the city” and asked if she would support a department paying for its staff to attend events they should oversee. Lerman stated it could be complicated for deptments to determine who gets to go to which events that can be paid for by taxpayer money or out of their own pockets.

Commissioner Finlev asked if in Lerman’s experience, are City folks in attendance only those who had tickets paid for them? Lerman responded that that public officials have paid out of their own pocket in the past, but they will not want to pay to go to every nonprofit’s events.

Commissioner Romano stated he understands that the relationship between government and nonprofits is important, but that public officials should not be supporting a certain nonprofit because they were given a gift. Those decisions should be made based on the merits. If attendance is a necessary part of the job, then the government agency should pay for it. Commissioner Romano stressed that the Commission does not want to add burden to small community-based organizations.

Lerman stated her impression is that little transactions are not the deciding factor in public officials awarding grants and that the officials ask good questions, read reports, etc. These tickets, small transactions are about getting them in the door, building the relationship. Having officials at events helps large and small organizations.

Commissioner Bush stated that gifts are not really about birthday day cards; they’re about, for example, departments giving 50 tickets to Outside Lands. We need to clarify what we’re targeting.

Lerman agrees those are the types of large gifts we should be targeting, by individuals seeking a contract. Lerman reiterated the callers are concerned about small-budget nonprofits giving small gifts, nothing that will cause an official to sway their decision for personal benefit. Even the 990-EZ limit is too small.

Commissioner Romano asked what is the right number then for a small nonprofit? Lerman suggested $100 million as the limit for a large organization and stated that a $30 million organization in San Francisco is not big.

Commissioner Romano stated that a $30 million organization has the resources to navigate the regulatory environment. A public official’s job is not to fund nonprofits, it’s to run the city. Lerman said that when a nonprofit is awarded a grant, it’s expected to raise a certain amount of its own dollars and it’s in the City’s best interest to ensure it is funded.

Commissioner Finlev asked for clarification—do contracts say that “the organization will raise x in its own dollars”? Lerman responded that the RFP may say that the City will only give the organization the same amount in the next year and that the organization needs to raise the rest. Other departments may explicitly say the organization needs to match the award.

Chair Lee asked about organizations underwriting cost of a tickets. Lerman responded that some organizations have profit built into cost of ticket.

Francisco Da Costa stated that this discussion is not focused on the real issues and that the Commission should not focus on small gift amounts. The Commission doesn’t have ability to monitor, and it needs to focus on enforcement.

Commissioner Bush referenced Controller’s report on grants by San Francisco Public Utilities Commission to community-based organizations based on no criteria.

Vinay Patel the director of APICC, stated that a lot of the corruption that was happening was related to for-profit entities. Regarding the 990EZ, $200K is a two-person organization in San Francisco, that is too small a definition. If the issue is related to unions, etc. – that’s what the proposal should be tailored to. The Commission should consider who it wants to target and tailor the language.

Extended public comment ended.

Chair Lee asked for suggestions on how to move forward and for how to share with the people of San Francisco what the Commission has been working on.

Commissioner Finlev suggested the Commission consider what was discussed, have Staff write ideas into options and proposals, which are then presented to the Commission. He added that it is important for the Commission to have a substantive discussion about what was discussed today.

Commissioner Chiu asked Staff to explore Form 990EZ, the gift law model in Los Angeles, and to continue the meet and confer process and report back at March meeting. Specifically, Commissioner Chiu would like staff to consider Common Cause’s feedback on restricted source liability.

Commission Bush made a motion to express appreciation to participants in today’s meeting and appreciation to the Controller for their work into examining corruption issues. The Commission’s actions rely on continued discussion with our partners and the Commission will soon have a measure for the voters to decide.

Commissioner Chiu seconded the motion and the Commission unanimously voted (5-0) to adopt the following statement: “The Ethics Commission expresses appreciation to all participants in today’s meeting, and to the Controller for the work that Office has done in examining corruption issues. The Ethics Commission’s policy action relies on continued discussions with partners, and while not expected to have a measure for the June ballot, we are hopeful to have something to present to the voters.”

Chair Lee expressed interested in Staff producing a revised FAQ document in the future.

Motion 220225-03 (Bush/Chiu): Moved, seconded, and passed (5-0) to adopt a statement expressing appreciation and intent to present a measure to voters.


Item 4. UPDATE WITH LABOR NEGOTIATOR – LABOR NEGOTIATIONS [Discussion and possible action.]

Chair Lee introduced the item and explained the need to go into private session to discuss labor negotiations. She stated the topic of discussion is the status of the meet and confer process with the San Francisco Municipal Executives Association (MEA) regarding the Commission’s proposed June 2022 ballot measure and regulation amendments. Jonathan White, the DHR employee relations manager, is to present in closed session. Chair Lee then explained the process that public comment on Item 4 will first be received and then a vote a will be taken on whether to meet in closed session under California Government Code Section 54957.6 and Sunshine Ordinance Section 67.10(e) to discuss labor negotiations. Then, if a closed session is held, the Commission will initiate a closed session meeting with Labor Negotiators and will then reconvene in an open session. Finally, pursuant to Brown Act section 54957.1 and Sunshine Ordinance section 67.12, the Commission will then discuss and vote on a motion whether or not to disclose any action taken or discussion held in the closed session regarding labor negotiations.

There were no questions from Commissioners and no additional instructions from Shen.

No public comments were received.

Commissioner Chiu moved to meet in closed session under California Government Code Section 54957.6 and Sunshine Ordinance Section 67.10(e) to discuss labor negotiations. The Motion was seconded by Commissioner Romano and approved unanimously (5-0).

Motion 220225-01 (Chiu/Romano): Moved, seconded, and passed (5-0) to meet in closed session.

The Commission met in closed session from 11:27am to 12:50pm.

Upon resuming its meeting in open session, Commissioner Chiu moved to not disclose what was discussed in closed session. The motion was seconded by Commissioner Romano and approved unanimously (5-0).

Motion 220225-02 (Chiu/Romano): Moved, seconded, and passed (5-0) to not disclose what was discussed in closed session.

Item 5. Additional opportunity for public comment on matters appearing or not appearing on the agenda pursuant to Ethics Commission Bylaws Article VII Section 2.

No public comments were received.

Item 6. Adjournment.

The Commission adjourned at 3:04pm.

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