Draft Minutes of the Regular Meeting of
The San Francisco Ethics Commission
Friday, December 12, 2025
Hybrid meeting conducted in-person in City Hall Room 400, 1 Dr. Carlton B. Goodlett Place, San Francisco, and also held online as a Remote Meeting via WebEx and aired live on SFGovTV
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 http://sanfrancisco.granicus.com/ViewPublisher.php?view_id=142.
(Note: A complete recording of this meeting can be found on SFGovTv.)
COMMISSION MEMBERS PRESENT: With Chair Argemira Flórez Feng, Vice Chair Yaman Salahi, and Commissioners Karen Bell Francois and Kevin Yeh participating, a quorum was present. Commissioner David Tsai had an excused absence.
STAFF PRESENTING: Executive Secretary & Commission Clerk, Charlie Machado-Morrow; Executive Director, Patrick Ford; Policy & Legislative Affairs Manager Michael Canning; Senior Investigator, Emma O’Donnel; Senior Investigator, Bailey Bryant.
REPRESENTATIVES OF THE OFFICE OF THE CITY ATTORNEY PRESENT: Kathleen Radez, Deputy City Attorney.
MATERIALS DISTRIBUTED:
- Draft Minutes for November 14, 2025, Regular Meeting
- Executive Director’s report dated December 8, 2025
- Director of Enforcement’s report dated December 8, 2025
- Audit Manager’s report dated December 8, 2025
- Staff Memorandum on Item 7 – Discussion and Possible Action Regarding Proposed Stipulation, Decision and Order In the Matter of Sophia Andary, SFEC Case No. 25-1001
- Proposed Stipulation, Decision and Order In the Matter of Sophia Andary (SFEC Complaint No. 25-1001)
- Staff Memorandum on Preliminary Matters In the Matter of Charlie Chiem, SFEC Case No. 24-787
- Probable Cause Determination In the Matter of Charlie Chiem, SFEC Case No. 24-787
- Staff Memorandum on Item 9 – Presentation, Discussion, and Possible Action on Regulation Amendments Regarding the Required Timeline for Considering Post-Employment and Compensated Advocacy Waivers
- Draft Regulation Amendments Regarding San Francisco Campaign & Governmental Conduct Code Sections 3.224 and 3.234 – Noticed Publicly on 12/1/2025
- Staff Memorandum on Item 10 – Ethics Commission Regular Meeting Schedule for Calendar Year 2026
Item 1. Call to Order and Roll Call
Chair Argemira Flórez Feng called the meeting to order at 10:09am and stated that members of the public may participate in-person or remotely.
Commission Clerk Charlie Machado-Morrow summarized the procedures for participation by members of the public for the meeting.
Item 2. Public Comment on Matters not Appearing on the Agenda.
No public comment was received on the item.
CONSENT CALENDAR: Items 3, 4, 5, and 6.
Under its Consent Calendar, it provided the opportunity for public comment on all Consent Calendar items and voted 4-0 to adopt a motion by Commissioner Yeh and seconded by Vice Chair Salahi to approve the following consent calendar item that required action by the Commission:
- Item 3, Draft Minutes for November 14, 2025, Regular Meeting
The following Consent Calendar items were informational and required no action by the Commission, but the opportunity for public comment was provided.
- Item 4, Executive Director’s Report – Chair Flórez Feng pulled the Executive Director’s report for an update regarding the budget process and the budget instructions given for this year.
Executive Director Pat Ford reported on a budget briefing held earlier the same day with the Mayor’s Budget Office, which outlined a very negative fiscal outlook, including an estimated $1 billion structural deficit across the next two fiscal years. While some tax revenues, particularly gross receipts, are slightly higher than expected, these gains are far outweighed by anticipated losses in federal funding due to federal policy changes, significantly affecting social services administered by the City.
The Mayor’s Office plans to prioritize addressing this shortfall by closely reviewing departmental operations and strategically reducing services, rather than applying uniform percentage cuts, with an overall goal of approximately a 15% reduction in citywide General Fund support. The Budget Director acknowledged that smaller departments may not be able to absorb cuts at the same rate as larger ones, particularly those with substantial non-staff or contracting budgets, which differs from this department’s staff-heavy budget.
As for next steps, departments will complete a worksheet for the Mayor’s Office describing their core mission and related operations; the Ethics Commission department is well prepared for this process, with strong KPIs and performance data. Director Ford expressed intent to work closely with the Chair, Vice Chair, and Commissioners on messaging and strategy and welcomed further input from Commissioners in upcoming discussions.
- Item 5, Enforcement Report
- Item 6, Audit’s Update Report
Public Comment:
No public comment was received on the item.
REGULAR CALENDAR
Item 7. Discussion and Possible Action Regarding Proposed Stipulation, Decision and Order In the Matter of Sophia Andary, SFEC Case No. 25-1001.
Emma O’Donnell, senior investigator with the Enforcement Division, presented a stipulated agreement between commission staff and respondent Sophia Andary. Ms. Andary, a commissioner on the Commission on the Status of Women since 2019, received a prohibited $1,000 honorarium from Ignite National on April 19, 2024, after presenting a workshop at an Ignite event within the prior 12 months, and had previously voted to approve a grant involving Ignite in her role as vice president of the commission. Staff proposed penalties totaling $1,000, consisting of $750 for compensation from a prohibited source and $250 for an honorarium from a prohibited source, and invited questions from the commission.
Chair Flórez Feng asked if the SF Standard article that came out in March of 2025 prompted Andary to reach out to the Ethics Commission and if the Commission on the Status of Women reported the fact that they gave her the honorarium?
Ms. O’Donnell responded no, because it was Ignite National who paid her the honorarium, not the Commission on the Status of Women, though they funded the event, which is inappropriate.
Commissioner Yeh asked if there was any information about why the summit budget approval went from $200,000 to $700,000 as it seems like a dramatic increase. Ms. O’Donnell responded that the budget is something the Enforcement Division is aware of and noted in their investigation but was separate from this case.
Director of Enforcement, Bisi Matthews, clarified that the budget information in this case is out of scope for this particular matter because the issue at hand is the honorarium payment Commissioner Andary received.
Commissioner Yeh stated it seems like an appropriate outcome; however, he noted that the actions she took remain relevant to whether there may have been a conflict. Commissioner Yeh added that, for example, if she were accused of making a decision or receiving compensation in connection with a significant budget increase, that would be a relevant consideration.
Director of Enforcement, Bisi Matthews, stated that if Ms. Andary had made those decisions after receiving the compensation, it would have triggered the conflict-of-interest rules in this case. She noted that the events did not occur in that order but emphasized that the concern is valid and that the way the situation unfolded is problematic, which is why the matter is under review.
Commissioner Yeh questioned whether other facilitators or panel moderators at the summit also received honoraria. Ms. O’Donnell confirmed that they did, and that the amounts were comparable; however, those individuals were not City officers or employees. It was further clarified that approval of the budget increase from $200,000 to $700,000 occurred before she was offered the opportunity to speak at the workshop, which is why that decision was not considered a factor in the investigation.
Commissioner Yeh also asked if the $1,000 payment had been repaid. It was confirmed that the amount was $1,000 and that it was not repaid, although she did attempt to return the funds and reached out to find a way to do so. There was no practical mechanism available for returning the payment. Commissioner Yeh expressed concern that this should be reflected in the stipulation, noting that she effectively retained the $1,000 while also being fined $1,000, and suggested that the fine should be imposed in addition to disgorgement of the payment.
Ms. O’Donnell noted that mitigating factors were considered, including that the violation was inadvertent and isolated, as determined through the investigation. It was also noted that she had led a breakout session the prior year in a non-City capacity and did not receive any compensation at that time, and that she was not aware she would receive compensation when she was offered the opportunity to present the workshop.
Vice Chair Salahi questioned the fact that the other panelists received the same amount, along with the timing of the payment, reduces any implication of an actual quid pro quo, and this was considered one of the mitigating factors to which Ms. Donnell agreed.
Chair Flórez Feng asked if Ignite National had to disclose how much they were giving everyone and staff’s response was no.
Vice Chair Salahi stated that he generally shares Commissioner Yeh’s preference that, in situations like this, penalties should include disgorgement or account for disgorgement plus an additional penalty. However, he expressed comfort with proceeding with the proposed sanction in this case due to the absence of any indication of intent to violate the applicable ethics rules, the lack of evidence of a quid pro quo, and the steps taken by Ms. Andary to cooperate with the Ethics Commission’s investigation after the concerns were raised.
Commissioner Francois asked how long Ms. Andary has been a Commissioner and was informed that she has served since 2019. Commissioner Francois then questioned why she was raising concerns about the process, noting that as a commissioner for approximately six years she would have been aware that accepting funds is prohibited. To which staff agreed and stated she should have been aware.
Director Matthews stated that the recommended penalty was considered appropriate in part because Ms. Andary sought guidance from the department’s executive director, was told the arrangement was permissible, and reasonably relied on that advice. She noted agreement with the concerns raised, adding that in a different case the Commission likely would have recommended a higher penalty.
Public Comment:
Sophia Andary called in and stated that at a March 29, 2024 meeting she was informed she would receive a stipend for the workshop and immediately indicated she was willing to forgo compensation if it created a conflict of interest, and was advised at the time that no conflict existed. She noted this was the only discussion of compensation and that no specific amount was mentioned.
She received the $1,000 stipend on April 29, 2024, disclosed it on her 2024 Form 700, and, after it was publicly reported as a potential conflict, promptly contacted the Ethics Commission to seek guidance, clarify the timeline, and offer to return the funds. She stated that she sought advice from the City Attorney and the Mayor’s Chief of Staff, cooperated fully with the Ethics Commission’s investigation, and accepted the stipulation in the interest of transparency and accountability, reiterating that she intended to return the funds once she learned they could present a conflict.
Motion 251212-02 (Salahi / Flórez-Feng): Moved, seconded, and approved unanimously (4-0) to approve the Proposed Stipulation, Decision and Order In the Matter of Sophia Andary, SFEC Case No. 25-1001.
Item 8. Discussion and Possible Action Regarding Preliminary Matters In the Matter of Charlie Chiem, SFEC Case No. 24-787
Bailey Bryant, Senior Investigator and Legal Analyst with the Enforcement Division, presented Agenda Item 8 concerning preliminary procedural matters in the case against Charlie Chan. She noted that a memorandum had been provided in advance and that the matter concerned procedure rather than the merits. She explained that the case involves 20 alleged violations, for which the Commission ratified a probable cause determination in July, and that while settlement remains possible, the Enforcement Division intends to proceed to a hearing on the merits.
Staff described the steps taken to notify the respondent of the hearing process and his opportunity to raise preliminary matters, noting that no response was received and that Enforcement does not intend to raise any preliminary issues. Accordingly, staff recommended that the Commission disregard action items one through three in the memorandum and proceed with action items four and five, which address who will preside over the hearing and the process for issuing a final order.
The Enforcement Division recommended that the full Commission preside over the hearing and that, following the hearing, the Enforcement Director submit a proposed order and hearing brief for the Commission’s deliberation and adoption. It was noted that there is no required procedural timeline and that the Commission may act on these items at this meeting or a future meeting.
Chair Flórez Feng questioned the respondent’s lack of response and noted that, while he typically communicates by email, recent outreach efforts did not receive a reply. Ms. Bryant explained that the lack of response was not due to an inability to reach the respondent, as investigators have been able to leave voicemails and have previously communicated with him regularly by phone and email. Rather, staff indicated that discussions appeared to stall because the respondent was not amenable to the settlement offers under consideration. Given the nature of the case, the history of communication, and the respondent’s familiarity with the process and his rights, staff stated that it was prudent to proceed rather than delay further.
Vice Chair Salahi had a question regarding whether notice of the merits hearing must be provided in a manner other than email. Staff responded that service by email is sufficient under the applicable regulations so long as the respondent has been receiving communications by email, and that an alternative method of service would be required only if the respondent affirmatively requested it. Vice Chair Salahi noted his concern to ensure proper notice is provided and to avoid any future challenge to the adequacy of service, and staff confirmed that the current approach complies with the rules.
Public Comment:
An unidentified caller offered comments questioning whether enforcement matters should be decided by the Commission or by members of the public, suggesting that a jury-style process involving community members could be more impartial. The speaker emphasized a general belief that decisions should rest with the public rather than the Commission and framed the remarks as a personal opinion.
Motion 251212-03 (Yeh / Salahi): Moved, seconded, and approved unanimously (4-0) to approve the recommended action items 4-5 regarding Preliminary Matters In the Matter of Charlie Chiem.
Item 9. Presentation, Discussion, and Possible Action on Regulation Amendments Regarding the Required Timeline for Considering Post-Employment and Compensated Advocacy Waivers
Policy and Legislative Affairs Manager, Michael Canning, presented the proposed regulation amendments concerning the timelines for Commission consideration of waiver requests under the post-employment and compensated advocacy rules. He explained that current regulations require waiver requests submitted within two weeks of a Commission meeting to be heard at the next meeting, which can leave staff insufficient time to conduct a thorough review and prepare recommendations.
The proposed amendments would allow waiver requests to be considered at either of the Commission’s next two meetings, ensuring staff has adequate time for analysis while still requiring that requests be heard within a reasonable timeframe. Staff recommended that the Commission approve the proposed amendments to provide greater flexibility and support timely and well-prepared consideration of waiver requests.
Chair Flórez Feng commented that the proposed amendments appeared reasonable and would allow staff to conduct more thorough and credible analysis. She also asked whether staff had received any public comment or pushback expressing concern that the extended timelines could cause undue delays, particularly given the impact of waiver decisions on individuals’ employment and livelihoods.
Mr. Canning responded that no pushback or public concern had been received regarding potential delays. He noted that the Department of Human Resources viewed the change as a minor, ministerial matter not requiring notice to bargaining units, and explained that the proposed amendments would allow staff to better account for time-sensitive requests, such as those involving pending job offers, whereas the current rules require all requests to be heard immediately regardless of urgency.
Public Comment:
No public comment was received on this item.
Item 10. Ethics Commission Regular Meeting Schedule for Calendar Year 2026
Executive Director, Pat Ford, presented the item and noted that the Commission approves its meeting schedule annually and recommended continuing the current schedule, with meetings held on the same day, time, and location, as it has proven effective for attendance and is difficult to change due to room availability.
Public Comment:
No public comment was received on this item.
Motion 251212-05 (Yeh / Salahi): Moved, seconded, and approved unanimously (4-0) to approve the proposed Ethics Commission Regular Meeting Schedule for Calendar Year 2026.
Item 11. Items for Future Meetings (Discussion)
No comments were made by the Commission or Staff regarding future agenda items.
Public Comment:
No public comment was received on this item.
Item 12. Additional Opportunity for General Public Comment
An unidentified caller expressed support for greater community involvement in decisions related to discipline and ethics enforcement, including suggesting that Ethics Commissioners be elected rather than appointed. The speaker emphasized the importance of public participation, accountability, and thorough investigation of matters involving taxpayer funds, framing the remarks as personal views.
Item 13. Adjournment
The Commission adjourned at 11:33am.