Lobbyist ID: SFO-153949
January 1, 2021 – December 31, 2021
Lobbyist-Sarjapur-FINALAuditReport
Introduction
Public disclosure of the identity and extent of efforts of lobbyists to influence decision-making regarding local legislative and administrative matters is essential to protect public confidence in the responsiveness and representative nature of government officials and institutions. The San Francisco Lobbyist Ordinance (San Francisco Campaign & Governmental Conduct Code [SFC&GCC] Section [Sec.] 2.100 et seq.) was established to impose reasonable registration and disclosure requirements to reveal information about lobbyists’ efforts to influence decision-making regarding local legislative and administrative matters. By restricting gifts, campaign contributions, and bundled campaign contributions by lobbyists, the law is designed to increase public confidence that governmental decisions are not, and do not appear to be, influenced by the giving of personal benefits to City officers by lobbyists, or by lobbyists’ financial support of City officers’ political interests.
To promote lobbyists’ compliance with the law, the San Francisco Ethics Commission conducted an audit of Melinda Sarjapur: SFO-153949 (hereinafter “the Lobbyist”) covering the audit period January 1, 2021, through December 31, 2021. This Audit Report summarizes the results for the audit.
Authority
Under SFC&GCC Sec. 2.135(c), the Executive Director of the Commission shall initiate audits of one or more lobbyists selected at random on an annual basis and undertake any other audits or investigations of a lobbyist authorized by law or regulation.
Objectives and Scope
The objective of the audit was to reasonably determine whether the Lobbyist substantially complied with requirements of SFC&GCC Sec. 2.100 et seq. and supporting regulations. The audit was performed based on a review of the Lobbyist’s filings and records covered by the audit period to determine, among other things:
- Compliance with disclosure and record-keeping requirements pertaining to lobbyist registration, monthly disclosure reporting, and training; and
- Compliance with applicable restrictions on lobbyist activity.
The Lobbyist was randomly selected for audit from a population of registered lobbyists who filed disclosure statements with the Ethics Commission for the period January 1, 2021, through December 31, 2021.
Nothing in this report shall be interpreted to prevent an enforcement action by the Ethics Commission or another appropriate agency for conduct in violation of the law, whether or not that conduct is covered by this report.
This report will be posted to the Commission’s website and forwarded to the Commission’s Enforcement Division for review to determine whether any further action may be warranted.
Auditee Information
Background
At all times relevant to the audit, the Lobbyist was a contact lobbyist employed by Reuben, Junius & Rose, LLP, a full-service real estate law firm. The Lobbyist engaged in both permit consulting (as defined in SFC&GCC Sec. 3.405) and lobbying (as defined in SFC&GCC Sec. 2.105 and Regulation 2.105-3) services on behalf of clients of Reuben, Junius & Rose, LLP. The Lobbyist contacted public officials regarding matters related to planning and building permits. The Lobbyist renewed their registration for the 2021 calendar year on December 21, 2020.
Lobbyist Reported Activity
| Total Number of Contacts | 1,081 |
| Total Payments Promised | $115,892 |
| Total Activity Expenses | $0 |
| Total Contributions | $0 |
The lobbyist activity totals were taken from disclosure statements filed with the San Francisco Ethics Commission for the period January 1, 2021, through December 31, 2021. These totals reflect activity for both permit consulting services and lobbying services. As the scope of the audit pertained to only lobbying related activity, all identified permit consulting activity was excluded from review. Activity reviewed during the audit is summarized in the table below.
| Total Number of Contacts | 127 |
| Total Payments Promised | $9,480 |
| Total Activity Expenses | $0 |
| Total Contributions | $0 |
Audit Respondent
The Audit Respondent identified below was the primary audit contact during the audit and responded to audit inquiries and requests on behalf of the Lobbyist.
Philip Le, Legal Assistant
Reuben, Junius & Rose, LLP
One Bush Street, Suite 600
San Francisco, CA 94104
Audit Findings
Under SFC&GCC Sec. 2.110(c)(1), contact lobbyists shall report to the Ethics Commission for each calendar month information regarding contact activity to influence local legislative or administrative action and economic consideration received or expected, among other things, no later than the fifteenth calendar day following the end of the month. Under SFC&GCC Sec. 2.110(d), lobbyists shall amend any information submitted to the Ethics Commission through registration and monthly disclosures within five days of the changed circumstances that require correction or updating of such information.
The following findings were noted during the audit:
Registration
Fourteen new clients were not timely reported on amendments to the San Francisco Ethics Commission Contact Lobbyist Registration within the five-day deadline to disclose the changed circumstance. This number represented 100% of the new clients that were required to be disclosed during the audit period. These clients were reported on amendments filed between 14 and 59 days after required disclosure deadlines. See table below.
| Client Name | Client Start Date | Required Disclosure Date | Actual Disclosure Date | Days Late | |
|---|---|---|---|---|---|
| 1 | 3641 California Street LP | 1/27/2021 | 2/1/2021 | 2/15/2021 | 14 |
| 2 | C2 Education | 2/3/2021 | 2/8/2021 | 3/15/2021 | 35 |
| 3 | Vasati Nob Hill Residence LLC | 5/12/2021 | 5/17/2021 | 6/14/2021 | 28 |
| 4 | Foodcast, Inc. | 7/20/2021 | 7/25/2021 | 8/14/2021 | 20 |
| 5 | Potrero Hill Imaging LLC | 7/21/2021 | 7/26/2021 | 8/14/2021 | 19 |
| 6 | Align Real Estate LLC | 8/11/2021 | 8/16/2021 | 9/13/2021 | 28 |
| 7 | Farese/Bob & Nancy | 8/23/2021 | 8/28/2021 | 9/13/2021 | 16 |
| 8 | Graham/Amy | 9/02/2021 | 9/7/2021 | 10/15/2021 | 38 |
| 9 | Hourteillan/Heidi Nutters & Lore | 9/02/2021 | 9/7/2021 | 10/15/2021 | 38 |
| 10 | San Francisco Zen Center | 9/14/2021 | 9/19/2021 | 10/15/2021 | 26 |
| 11 | NOPA Heights Partners LLC | 10/13/2021 | 10/18/2021 | 11/13/2021 | 26 |
| 12 | 2700 Sloat Holdings LLC | 11/08/2021 | 11/13/2021 | 12/15/2021 | 32 |
| 13 | MMM Housing for Artists | 12/08/2021 | 12/13/2021 | 2/10/2022 | 59 |
| 14 | Chase Sandy Beach Developing LLC | 12/15/2021 | 12/20/2021 | 1/13/2022 | 24 |
Monthly Disclosure Statements
- The December 2021 San Francisco Ethics Commission Individual Lobbyist Statement was filed late on January 19, 2022. The Statement was required to be filed on January 18, 2022. A late filing fee of $50 was assessed and paid.
- Six contacts made with City Officers were not disclosed on monthly San Francisco Ethics Commission Individual Lobbyist Statements. See table below.
| Contact Date | Client | Issue / Project | Required Disclosure Deadline | |
|---|---|---|---|---|
| 1 | 7/12/2021 | Tishman Speyer Properties | Block 1 | 8/15/2021 |
| 2 | 7/20/2021 | Tishman Speyer Properties | Block 1 | 8/15/2021 |
| 3 | 9/2/2021 | Graham/Amy | 145 Bonview Street | 10/15/2021 |
| 4 | 10/7/2021 | Hourteillan/Heidi Nutters and Lore | 148 Ostego Avenue | 11/15/2021 |
| 5 | 10/18/2021 | Hourteillan/Heidi Nutters and Lore | 148 Ostego Avenue | 11/15/2021 |
| 6 | 10/21/2021 | Hourteillan/Heidi Nutters and Lore | 148 Ostego Avenue | 11/15/2021 |
Conclusion
Except as indicated in the Audit Findings section above, and in our opinion, the Lobbyist substantially complied with the requirements of SFC&GCC Sec. 2.100 et seq. and supporting regulations.
Auditee Response
In response to the finding pertaining to the non-disclosure of six contacts made with City Officers on monthly San Francisco Ethics Commission Individual Lobbyist Statements, the Audit Respondent indicated the following:
- “Contact #1 entailed responding to an email correspondence to which the City Official had been cc’d by another City Official. The other City Officials on that chain were reported as lobbyist contacts on our report for 7/12/21, but the referenced City Official was unintentionally omitted.
- Contact #2 entailed cc’ing the City Official on an email directed to other City Officials. The other City Officials on that email chain were reported as lobbyist contacts on our report for 7/20/21, but the referenced City contact was unintentionally omitted.
- Contact #3 entailed cc’ing the City Official on an email directed to other City Officials. The remaining City Officials on that email chain were reported as lobbyist contacts on our report for 9/12/21, but the referenced City Official was unintentionally omitted.
- Contacts #4-#5 were reported on my internal records but were unintentionally omitted from the October Lobbyist Report in error.”