January 17, 2025
For information: Michael Canning, Policy and Legislative Affairs Manager (415) 252-3100
At its regular monthly meeting on Friday, January 17, 2025, the San Francisco Ethics Commission approved three separate settlement agreements that levied a total of $3,100 in penalties against three respondents for unrelated violations of conflict of interest, lobbyist, and campaign finance laws.
Violations of Ethics and Personal Financial Disclosure (Form 700) Laws
In the Matter of Randy Collins – The Commission unanimously approved $600 in penalties through a Stipulation with former Member of the Board of Examiners, Randy Collins for one count of failure to timely file the Annual Statement of Economic Interests (“Form 700”), one count for failure to disclose reportable sources of income on Form 700s, and one count for failure to file a Certificate of Ethics Training and an Annual Sunshine Ordinance Declaration.
Every elected official or public employee involved in making a decision is required to submit a Statement of Economic Interest by filing the Form 700. It also serves as a reminder to public officials of potential conflicts of interests so that officials can avoid making or influencing any governmental decisions that are deemed conflicts of interest. Failure to file deprives the public of seeing what a City official’s personal financial interests are and ensuring that decisions are made in the best interest of the public. Here, the Commission assessed a lower penalty amount because of the unique mitigating circumstance. Respondent’s Board never met during the relevant period in which Respondent failed to comply with the law. Thus, as the Stipulation notes, Respondent engaged in no official duties during the period in question and did not have a practical opportunity to influence government actions.
Violations of Lobbyist Contribution Disclosure Laws
In the Matter of Bert Polacci – The Commission unanimously approved a $2,000 penalty through a Stipulation with registered contact lobbyist, Bert Polacci for one count of failure to publicly disclose on his monthly lobbyist disclosure report one campaign contribution totaling $10,000 that Mr. Polacci acted as an intermediary between the contributor and the recipient campaign committee. This matter was resolved through the Commission’s Streamlined Administrative Resolution Program (SARP), which is designed to encourage timely engagement. Matters resolved under SARP will generally result in a penalty that is less severe, and in a description of the violation and surrounding events that is less detailed, in comparison to matters resolved through the Commission’s regular administrative enforcement process. Eligibility for the program is determined by the severity of the conduct at issue and timelines of resolution of the enforcement matter. Here, Mr. Polacci took remedial action to disclose the contribution on the relevant lobbyist report within 30 days of contact by the Enforcement Division and timely signed and returned the stipulation.
Public disclosure of the identity and extent of efforts of lobbyists to influence governmental and administrative matters is essential to protect public confidence and to avoid corruption or any appearance of corruption. The law specifically restricts gifts, campaign contributions, and bundled campaign contributions from lobbyists to City officers so 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.
Violations of Campaign Advertisement Disclaimer Laws
In the Matter of Julio Ramos and Julio Ramos for College Board 2024 – The Commission unanimously approved a $500 penalty through a Stipulation with former Member of the Community College District Board of Trustees, Julio Ramos and his candidate-controlled committee for one count of failure to include the committee’s proper name and financial disclosure language as required on campaign communications. This matter was resolved through SARP. Here, Mr. Ramos took remedial action to include proper campaign communication disclaimer language within 30 days of contact by the Enforcement Division and timely signed and returned the stipulation.
Campaign advertisement disclaimer laws are essential to assist voters in making informed electoral decisions regarding the sources of campaign contributions and how those contributions through advertisements. They are also necessary to upholding the integrity of the election process and require accuracy of information and claims made on campaign advertisements. Compliance with these laws help ensure fairness and transparency in the electoral process.
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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.