CITY AND COUNTY OF SAN FRANCISCO
Campaign Finance Audit Report
FPPC ID #: 1422604
January 1, 2019 – December 31, 2020
Introduction
To promote campaign compliance with laws and regulations, the San Francisco Ethics Commission (hereinafter the “Commission”) engaged Macias Gini & O’Connell LLP (MGO) to assist in assessing election committees’ compliance with applicable requirements. This report summarizes the audit results on the Avalos for Supervisor 2020 #1422604 committee (hereinafter “the Committee”) covering the period of January 1, 2019 through December 31, 2020.
Authority
The Commission has a duty and responsibility under San Francisco Charter Sec. C3.699-11(4) to audit campaign statements and other relevant documents that are filed with the Commission to ensure compliance with applicable state and campaign finance laws and regulations. Under SFC&GCC Sec. 1.150(a), all candidate committees whose candidates have received public financing must be audited and committee that have not received public financing may be randomly selected for audit at the discretion of the Executive Director of the Commission.
Objectives and Scope
The objective of the audit was to reasonably determine whether the Committee substantially complied with requirements of the Political Reform Act Sec. 81000 et. Seq. and supporting regulations, and the San Francisco Campaign Finance Reform Ordinance Sec 1.100 et. Seq. and supporting regulations. The audit was performed based on a review of the Committee’s filing and records covered by the review period to determine, among other things:
- Compliance with campaign activity disclosure and record-keeping requirements, and
- Compliance with applicable campaign activity limits, restrictions, and prohibitions.
As a recipient of public financing, the Committee was subject to mandatory audit.
Nothing in this report shall be interpreted to prevent an enforcement action by the Commission or another appropriate agency for conduct in violation of the law, whether or not that conduct is covered in this report.
The report will be forwarded to the Commission’s Enforcement Division for review to determine whether any further action may be warranted.
Committee Information
Background
The Committee’s primary purpose was to support the election of John Avalos to the Board of Supervisors, District 11, of the City and County of San Francisco (“City”) in the November 3, 2020 election. During the period covered by the audit, the Committee’s Treasurer was Albany Aroyan. The Committee is ongoing and was established on November 15, 2019.
Committee Reported Activity
| Total Funds Raised | Total Expenditures Made | |
| Private Contributions | $124,032 | $358,555 |
| Public Funds Received | $254,430 |
The Committee activity totals were taken from disclosure statements filed with the Commission covering the period January 1, 2019 through December 31, 2020.
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 Committee.
Albany Aroyan
584 Castro Street #2230
San Francisco, CA 94114
Audit Results
The CA Gov. Code Sec. 81000 et. Seq and supporting regulations, and SFC&GCC Sec. 1.100 et. Sec and supporting regulations, require campaign committees to timely disclose information about election campaign activity and adhere to applicable campaign activity limits, restrictions, and prohibitions.
The following findings were noted during the audit:
- Under CA Gov. Code Sec. 84211(a), committees are required to report the total amount of contributions received from all persons during a reporting period. CA Gov. Code Sec. 84211(f) further states that if the cumulative amount received from any one source is $100 or more, committees must also disclose, in addition to the date and amount, the full name, street address, and occupation/employer information of the contributor.
Out of 64 contributions examined, the occupation and employer information disclosed for 3 contributors did not match source documentation.
| Contributor | Disclosed Occupation | Occupation per Source Documentation | Disclosed Employer | Employer per Source Documentation |
| Vivian Araullo | Executive Director | Union Representative | West Bay Multi Service Center | Individual |
| Cesar Espinoza | Assistant Work Coordinator | Unemployed | Dolores Street Community Services | N/A |
| Jeanelle Laberinto | Coordinator | Consultant | SOMA Pilipinas | Self-Employed |
Campaign Disclosure Statements
- Under SFC&GCC Sec. 1.152(a)(1) and Regulation1.152-1(a), candidate committees are required to file Form SFEC-152: Threshold Notice with the Commission disclosing when they have received contributions or made expenditures that equal or exceed $10,000 within 24 hours of reaching or exceeding that amount.
The SFEC 152 Form required to be filed at the initial $10,000 threshold was filed 64 days late.
| Threshold Level | Date Reached | Date Filed | Days Late |
| $10,000 | 12/2/2019 | 2/5/2020 | 64 |
Conclusion
Except as indicated in the Audit Findings section above, and in our opinion, the Committee substantially complied with the requirements of the Political Reform Act Sec. 81000 et seq. and supporting regulations, and the San Francisco Campaign Finance Reform Ordinance Sec. 1.100 et seq. and supporting regulations.
Auditee response
Audit Respondent did not provide a response to the audit findings.