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Notice of Individual Expenditure Ceiling Adjustment(s) for One or More Publicly Financed Candidates – Mayor


Date: June 27, 2024

Based on candidate filings and third-party expenditures reported to the Ethics Commission, the Commission determined today that an adjustment to the Individual Expenditure Ceiling (IEC) of one or more publicly financed candidates in the November 5, 2024, election for Mayor is required. The table below indicates the previous and new IEC limit as determined for each candidate in this race.

Candidate NamePrevious IEC LimitNew IEC Limit
Breed, London$1,700,000$2,200,000
Safai, Ahsha$1,700,000$2,200,000

Under the City’s public financing laws, Candidates who seek public funds must agree to limit their spending to the applicable IEC. The IEC for candidates for the Board of Supervisors starts at $350,000 and may be raised in increments of $50,000. For candidates for Mayor, the IEC starts at $1,700,000 and may be raised in increments of $250,000. While the Ethics Commission can raise a candidate’s IEC, it cannot be reduced or removed, and the candidate is bound by their IEC throughout the election. Because expenditure ceilings are reviewed and adjusted on a candidate-by-candidate basis, it is possible for candidates in the same race to have different IEC limits or have their IEC adjusted at different times/intervals. 

As provided in Campaign and Governmental Conduct Code Sec. 1.143, the Executive Director shall adjust the Individual Expenditure Ceiling for any candidate when the Total Opposition Spending against that candidate combined with the highest level of Total Supportive Funds for any opponent in that race equals or exceeds the candidates current Individual Expenditure Ceiling.

Total Supportive Funds (TSF) is the sum of all funds (including monetary contributions, loans, in-kind contributions and public funds) received by a candidate, up to an amount equal to that candidate’s current IEC, plus any expenditures made or expenses incurred by any person for the purpose of making independent expenditures, electioneering communications or member communications to support that candidate.

Total Opposition Spending (TOS) is the sum of all expenditures made or incurred by any person for the purpose of making independent expenditures, electioneering communications or member communications to oppose a specific candidate. Total opposition spending does not include spending by a candidate to support himself or herself or to oppose his or her opponents in the same election.

Pursuant to Campaign and Governmental Conduct Code sec. 1.104, a candidate’s Total Supportive Funds cannot exceed that candidate’s current IEC, and any additional funds received above this amount are not counted. Therefore, when a candidate’s IEC is increased, the amount of funds received that count towards the candidate’s Total Supportive Funds will increase. This in turn can trigger a series of successive adjustments for one or more candidates in the same race. The table below details the Total Supportive Funds and Total Opposition Spending and final IEC limit calculated for each candidate.

Important Note: Candidates who are not certified to receive public financing are not bound by an IEC (designated by “N/A” in the table below).

Candidate NameIEC before analysisCandidate Supportive Funds3rd party Supportive FundsTotal Supportive Funds (TSF)Highest Opponent TSF in RaceTotal Opposition Spending (TOS)Opponent’s TSF + TOSIEC after analysis
Breed, London$1,700,000$1,665,284$247,899$1,913,183$2,057,605$0$2,057,605$2,200,000
Farrell, MarkN/A$283,078$0$283,078$2,057,605$0$2,057,605N/A
Lurie, DanielN/A$1,184,126$873,480$2,057,605$1,913,183$0$1,913,183N/A
Peskin, AaronN/A$50,481$0$50,481$2,057,605$0$2,057,605N/A
Safai, Ahsha$1,700,000$50,568$0$50,568$2,057,605$0$2,057,605$2,200,000

Additional information regarding the determination process for adjustments, current candidate individual expenditure ceilings and third party spending can be found on the “Expenditure Ceilings and Third-Party Spending” page of the Commission’s website. A summary of public funds disbursed to qualified candidates is available on the Ethics Commission’s campaign finance data dashboards.

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The Ethics Commission, established in November 1993, serves the public, City employees and officials and candidates for public office through education and enforcement of ethics laws, including the assessment of fines through its administrative enforcement authority. Its duties include: filing and auditing of campaign finance disclosure statements, lobbyist and campaign consultant registration and regulation, administration of the public financing program, whistleblower program, conflict of interest reporting, investigations and enforcement, education and training, advice giving and statistical reporting. We invite you to follow our work at

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