March 9, 2026
I. Introduction
This Audit Report summarizes the audit results for the committee Mark Farrell for Mayor 2024, FPPC ID # 1466726 (the “Committee”), for the period January 1, 2024, through December 31, 2024. The audit was conducted by Ethics Commission audit staff to determine whether the Committee materially complied with applicable state and local campaign finance laws during the November 2024 election.
II. Audit Authority
San Francisco Charter Section C3.699-11 authorizes the Ethics Commission (the “Commission”) to “audit campaign statements and other relevant documents” of campaign committees that file with the Commission. San Francisco Campaign and Governmental Conduct Code (“C&GCC”) Section 1.150(a) requires the Commission to audit all committees of candidates who have received public financing and authorizes the Commission to initiate targeted audits of other committees at its discretion.
III. Objective and Scope
The objective of the audit was to reasonably determine whether the Committee materially complied with requirements of the San Francisco Campaign Finance Reform Ordinance (C&GCC Section 1.100, et seq., and supporting regulations) and the California Political Reform Act (California Government Code Section 81000, et seq., and supporting regulations).
The audit was conducted based on an analysis of the Committee’s filings and support documentation obtained from the Committee. A complete summary of the audit’s objectives and the methods used to address those objectives appears in Appendix A.
IV. Committee Information
The Committee qualified as a committee on February 13, 2024, as a candidate-controlled committee supporting the election of Mark Farrell (the “Candidate”) to the office of Mayor in the November 5, 2024, election. The Committee remains active as of January 2026.
Roy Herrera was listed as the Committee’s treasurer for the full period covered by the audit. However, The Money Wheel, LLC (the “Treasurer”) provided treasurer services to the Committee during the audit period and represented themselves as the Committee’s treasurer during the audit process. Shantal Sutherland, Senior Compliance Specialist at The Money Wheel, served as the primary audit contact for the Committee during the audit. Auditors also noted that Margaux Kelly was listed as a principal officer of the Committee on its Form 410 Statement of Organization in effect between October 11, 2024, and January 30, 2025. In an amended Form 410 dated January 30, 2025, the Candidate was named as the Committee’s treasurer.
For the period covered by the audit, the Committee reported receiving $2,616,230—including $981,701 in monetary contributions, $5,383 in nonmonetary contributions, $1,200,000 in public financing, and $429,146 in miscellaneous increases to cash—and making or incurring $2,647,568 in expenditures.
Approximately 95% of the net reported miscellaneous increases to cash concern “shared expense reimbursements” paid by, or refunded to, the committee Mayor Mark Farrell for Yes on Prop D (FPPC ID #1467847). On November 8, 2024, the Commission approved a stipulation with parties, including the Committee and the Candidate, finding that $192,216 of these reimbursements amounted to prohibited contributions to the Committee. This Audit Report does not discuss these transactions previously found by the Commission to have violated the law. The approved stipulation, in the matter of “Mayor Mark Farrell for Yes on Prop D, Mark Farrell for Mayor 2024, Mark Farrell, and Roy Herrera, Complaint No. 24-817,” is available on the Commission’s website at sfethics.org.
V. Material Audit Findings
Auditors identified the following material findings during the audit. These findings represent instances of noncompliance that Auditors determined to be significant based on the frequency of occurrence within a representative sample, or based on the significance of the dollar amount, the percentage of total activity, or the importance of the item to the purposes of state or local law.
Finding V-1. The Committee did not disclose reportable subvendor expenditures
Applicable Law
Committees are required to report expenditures made by an agent or independent contractor of a committee of $500 or greater, other than expenditures for the agent’s or independent contractor’s overhead and normal operating expenses, as if the expenditures were made directly by the committee. Gov’t Code § 84303(a). A subvendor who provides goods or services to or for the benefit of a committee must make known to the agent or independent contractor all of the information required to be reported by this section, who in turn must make that information known to the committee. Id. § 84303(b).
For each person to whom a committee has made an expenditure of $100 or more, the committee must disclose the full name and street address of the payee, amount of each expenditure, and a brief description of the consideration received. Id. § 84211(k). Local law additionally requires a committee to report the date of each expenditure required to be disclosed. C&GCC § 1.112(a)(4).
All reports and statements filed pursuant to the Political Reform Act must include a verification, which must be signed by the filer stating that the filer has used “all reasonable diligence in its preparation” of the filing. Gov’t Code § 81004(a).
State regulation requires additional reporting and recordkeeping for itemized expenditures for a meal not related to travel. A committee must disclose the date of the meal, the number of individuals for whom the expenditure was paid, and whether those individuals included the candidate, a member of the candidate’s household, or an individual with authority to approve expenditures of the committee’s funds. 2 CCR § 18421.7(a)(2). The original source documentation must include a dated memorandum, or other dated written record, containing the information required to be reported under Regulation 18421.7(a)(2) and the names of all individuals in attendance. Id. § 18401(a)(5).
Analysis
Auditors reviewed a sample of 133 expenditures totaling $1,296,861 and identified 16 transactions (12.0% of the sample) totaling $698,476 (53.9% of the sampled amount) for which support records demonstrated that subvendor expenditures greater than $500 had been made, or for which support records appeared to be incomplete and likely did not list subvendor payments greater than $500. The Committee did not report any of the identified subvendor expenditures on Schedule G (Payments Made by an Agent). Auditors note that for the duration of the audit period, the Committee reported only three subvendor expenditures on Schedule G, consisting of three payments made by the law firm Herrera Arellano to the Treasurer totaling $55,471.
For six expenditures to Margaux Kelly and Jadelinn Tu, campaign employees submitted expenses for reimbursement and included support documentation that clearly indicated payments to subvendors of greater than $500. While the Committee reported each expenditure on Schedule E (Payments Made) and indicated in the description that the expenditure was a reimbursement, the Committee did not disclose the subvendor information required to be reported by Sections 84303(a) and 84211(k). Schedule G of the Form 460 is intended for this purpose.
Additionally, for the $589 expenditure by Jadelinn Tu to Supreme Pot for a campaign team dinner, the more stringent meal reporting and recordkeeping requirements applied. Support records consisted of a dated and itemized receipt indicating a sit-down meal for nine guests. Accordingly, the Committee should have not only reported this expenditure on Schedule G, but additionally reported the number of individuals in attendance and whether the attendees included the Candidate or an individual with authority to approve expenditures, as required by Regulation 18421.7(a)(2), and maintained a list of the names of all individuals in attendance, as required by Regulation 18401(a)(5).
The table below summarizes the expenditures for which support records list payments to subvendors of greater than $500:
| Payee | Amount Paid to Subvendor | Date Per Support | Subvendor |
|---|---|---|---|
| Margaux Kelly | $784 | 5/6/2024 | Constant Contact |
| $822 | 5/24/2024 | Staples | |
| $800 | 8/28/2024 | Sing Tao Daily | |
| $4,732 | 10/30/2024 | Pacific Printing | |
| $4,313 | 11/3/2024 | Scale to Win | |
| $3,131 | 11/3/2024 | ||
| $2,051 | 11/2/2024 | ||
| Jadelinn Tu | $589 | 8/2/2024 | Supreme Pot |
For a further 11 expenditures to Blue Nation Strategies (“Blue Nation”) and Canal Partners Media (“Canal Partners”), the vendor did not make known any subvendor payment information to the Committee, but Auditors concluded based on the supporting invoices and the nature of the vendors that subvendor payments had likely been made.
For the eight expenditures to Blue Nation, support records consisted of an invoice from Blue Nation that listed line items with a brief description, such as “print, postage, and shipping,” and did not list any component payments to subvendors. However, Blue Nation’s contract with the Committee indicates that Blue Nation uses subvendors for various services. For example, the contract notes that, “Blue Nation works exclusively with union printers and mail houses,” and references Blue Nation’s “fulfillment vendors.” The contract also notes that photo shoots include costs for “the photographer and one Blue Nation team member,” and Blue Nation’s website lists a photographer under “Our Partners” who appears not to be a Blue Nation employee. Based on this contract, the firm’s website, and on Auditors’ experience reviewing comparable purchases by candidate committees for various advertising services, Auditors conclude that the full cost of each invoice paid to Blue Nation likely comprised one or more payments to subvendors that exceeded $500.
For three expenditures to Canal Partners, the supporting invoices indicate that the vendor purchased television advertising on behalf of the Committee. On the homepage of its website, Canal Partners describes itself as a “political media buying firm,” and most of the staff listed on the website have the position title “Buyer.” Accordingly, Auditors conclude that the majority of the cost of each expenditure likely amounted to subvendor payments to television broadcasters or similar.
Auditors, therefore, concluded that Blue Nation and Canal Partners likely did not make known subvendor information to the Committee required by Section 84303(b). Consequently, Auditors were unable to assess the extent to which the Committee complied with the reporting requirements of Section 84303(a). With respect to the “reasonable diligence” provision of Section 81004(a), the Committee likely should have requested subvendor information from these vendors when none was made known.
The table below summarizes the expenditures that likely comprised subvendor payments:
| Payee | Amount | Date Per Support | Description |
|---|---|---|---|
| Blue Nation Strategies | $8,770 | 2/16/2024 | Digital Launch Graphics; Launch Chum |
| $21,600 | 9/9/2024 | Print and overprint for field | |
| $24,374 | 9/26/2024 | Door hangers – two versions | |
| $10,514 | 10/2/2024 | Print and shipping | |
| $20,264 | 10/11/2024 | Print, postage, and shipping | |
| $20,264 | 10/11/2024 | Print, postage, and shipping | |
| $20,764 | 10/16/2024 | Print, postage, and shipping | |
| $999 | 7/31/2024 | Photographer, Travel | |
| Canal Partners Media | $354,450 | 10/7/2024 | San Francisco – TV; San Francisco – Cable |
| $163,860 | 10/21/2024 | San Francisco – TV; San Francisco – Cable | |
| $38,000 | 11/4/2024 | San Francisco – TV |
Committee Response to Finding
The Treasurer provided the following comment:
“The Committee interpreted the subvendor reporting requirement as applying to contracted vendors only, rather than to all reimbursed expenditures made by agents of the Committee.
The Committee promptly initiated outreach to both Canal Partners and Blue Nation Strategies to request the relevant subvendor disclosure information. The responsive data made available by those vendors is as follows.”
Auditors’ note: The data provided by the Committee in response to this finding can be found in Appendix C to this report.
Finding V-2. The Committee did not maintain or provide any support records for several expenditures
Applicable Law
Committees must maintain detailed accounts, records, bills, receipts, and other original source documentation as necessary to prepare financial statements for a period of four years. 2 CCR § 18401(b); C&GCC § 1.109(a).
For each expenditure made of $25 or more, or a series of payments for a single product or service totaling $25 or more, committees must maintain records containing the date and amount of the expenditure, the full name and street address of the payee, and a description of the goods or services received, as well as source documentation including cancelled checks, wire transfers, credit card charge slips, bills, receipts, invoices, statements, or vouchers. 2 CCR § 18401(a)(4)(A)-(B).
Analysis
Auditors reviewed a sample of 133 expenditures and identified 12 transactions (9.0% of the sample) for which the Committee did not maintain, or did not provide, any support records to substantiate the reported expenditure information. After submitting an initial request for records in January 2025, Auditors sent follow-up requests to the Treasurer during the course of the audit as supporting records were found to be missing. For the expenditures discussed in this finding, the Committee did not provide any records required to be maintained by Regulation 18401.
The table below summarizes the expenditures discussed in this finding:
| Payee | Amount | Reporting Period End Date |
|---|---|---|
| Michael Siracusa | $2,892 | 6/30/2024 |
| Berline & Associates | $200 | 6/30/2024 |
| The Waterfront Restaurant | $121 | 6/30/2024 |
| Holbrook House | $102 | 6/30/2024 |
| Grand Palace Restaurant | $980 | 9/21/2024 |
| Starbucks | $123 | 9/21/2024 |
| Amazon | $730 | 10/19/2024 |
| LPH Shipping | $475 | 10/19/2024 |
| Jewish Community Federation | $360 | 10/19/2024 |
| White Cap | $126 | 10/19/2024 |
| Philosopher’s Club | $163 | 10/30/2024 |
| Constant Contact | $626 | 12/31/2024 |
Committee Response to Finding
The Treasurer provided the following comment: “The Committee maintained and supplied support records in the audit for the vast majority of expenditures identified in the audit sample. Many of the expenditures for which support records are missing were for relatively minor expenditures that are substantiated with contemporaneous bank statements and which may be corroborated through a comparison with bank statements.
For the aforementioned reasons and because the audit finding did not result in any deprivation of information to the public, we believe Finding V-2 is more appropriate for Section VI (Other Identified Findings) than for Section V (Material Audit Findings).”
Auditor Comment
Auditors note that while a majority of the sampled expenditures had supporting documentation, 9.0% of the sampled transactions lacked such documentation. Auditors consider this finding to be material based on a general materiality threshold of 5%. Because Auditors reviewed a statistically significant and representative sample, Auditors extrapolate the identified error percentage to conclude that about 9.0% of the total population of expenditures likely had missing documentation. Auditors also note that beyond allowing Auditors to verify that a transaction occurred, the support documentation required by Regulation 18401 allows Auditors to verify the campaign related purpose of an expenditure.
Finding V-3. The Committee reported contributor information that did not comply with reporting requirements
Applicable Law
For each individual from whom a committee has received cumulative contributions of $100 or more, the committee must disclose the contributor’s full name, street address, occupation, employer, or, if self-employed, the name of the business, the date and amount of the contribution, and the cumulative amount of contributions received. Gov’t Code § 84211(f). A “street address” means a real property’s street name, building number, city, state, and zip code. 2 CCR § 18250(a).
Fair Political Practices Commission (“FPPC”) Advice Letter I-07-152 provides guidance about the sufficiency of reported contributor information. As relevant to this finding, reporting occupations such as “philanthropist”, “business person”, “entrepreneur”, and “investor” are not acceptable as they are not sufficiently descriptive of a contributor’s occupation. The advice letter also notes that an acronym may not be used in place of a full name of an employer because Section 84211(f) requires that the full name be reported, and that a P.O. box does not qualify as a “street address.”
Advice Letter I-07-152 also notes that “self-employed” may be used as a description for an employer so long as the description also indicates the name of the contributor’s business. If a contributor is self-employed and has no formal name for their business, the employer may be described as “same name” or the contributor’s name.
When reporting a committee as a contributor pursuant to Section 84211(f), the number assigned to that committee by the Secretary of State (“FPPC ID”) must also be reported. Gov’t Code § 84211(m).
Analysis
The Committee reported a total of 2,822 contributions from 2,412 individual contributors on Schedule A (Monetary Contributions Received) of the Form 460 during the audit period. Auditors reviewed filing data for all reported contributions and identified a total of 215 contributions (7.6% of the population) from 188 contributors for which one or more elements required to be reported by Section 84211(f) did not comply with all applicable requirements.
For the 11 contributions summarized in the table below, the Committee did not report the contributor’s full name as required by Section 84211(f), but instead reported an initial or an abbreviation consisting only of consonants.
| Contributor First Name | Contributor Last Name | Date | Amount |
|---|---|---|---|
| W. | Koch | 2/25/2024 | $500 |
| Mj | Brenaman | 3/14/2024 | $500 |
| Jch | Webster | 4/14/2024 | $100 |
| Jp | Coghlan | 6/17/2024 | $500 |
| KC | Stone | 6/30/2024 | $500 |
| Rj | Lang | 9/5/2024 | $250 |
| M. | Thomas | 9/8/2024 | $100 |
| T. | Cecchin | 9/10/2024 | $250 |
| B. | H | 9/24/2024 | $200 |
| C. | Moran | 10/13/2024 | $500 |
| R. | Dicoccio | 10/28/2024 | $500 |
As summarized in Table B-1 of Appendix B to this report, Auditors identified 79 contributions (2.8% of total) from 72 contributors for which the Committee did not report a complete employer name. Four contributions had “Information Requested” reported, and 75 had “Self Employed” reported. Pursuant to Section 84211(f) and Advice Letter I-07-152, if a contributor is self-employed, a committee must report the name of their business, or if none, indicate such by reporting “same name” or similar.
As summarized in Table B-2 of Appendix B, Auditors identified 36 contributions (1.3% of total) from 28 contributors for which the Committee reported an acronym in place of a full employer name. Advice Letter I-07-152 notes that an acronym does not meet the reporting requirements of Section 84211(f).
As summarized in Table B-3 of Appendix B, Auditors identified 64 contributions (2.3% of total) from 59 contributors for which the Committee reported occupations were insufficient per Advice Letter I-07-152. “Entrepreneur” and “Investor” are explicitly described as insufficient in the Advice Letter.
As summarized in Table B-4 of Appendix B, Auditors identified 43 contributions (1.5% of total) from 35 contributors for which the Committee did not report a proper street address. For 40 of these contributions, the Committee reported a P.O. Box, which is not a street address as defined by Regulation 18250(a) and as clarified by Advice Letter I-07-152. The remaining three contributions listed only “Information Requested,” “San Francisco,” and “Unit 2.”
Finally, Auditors identified 35 contributions made by other committees, of which 11 transactions (31.4%) were reported without an FPPC ID as required by Section 84211(m). Auditors also noted that several of the contributor names were misspelled or did not accurately reflect the name of the committee as reported on its campaign filings. Especially when the committees’ FPPC IDs are missing, these errors inhibit the public’s ability to search for these committees’ campaign finance activity.
| Contributor | Date | Amount |
|---|---|---|
| San Francisco Building & Construction Trades PAC | 7/2/2024 | $500 |
| International Association of Heat and Frost Insulators and Allied Workers | 8/13/2024 | $500 |
| Bricklayers & Allied Crafworkers [sic] Local 3 | 9/25/2024 | $250 |
| San Francisco Marin Medical Socity [sic] PAC | 10/2/2024 | $500 |
| IBEW 332 Education Fund | 10/16/2024 | $500 |
| IBEW 302 Community Candidates PAC | 10/24/2024 | $500 |
| International Brotherhood Eletrical [sic] Workers Local 595 | 10/24/2024 | $500 |
| International Brotherhood Eletrical [sic] Workers Local 551 | 10/24/2024 | $500 |
| International Brotherhood Eletrical [sic] Workers Local 617 | 10/24/2024 | $500 |
| California Machinist Non Partisan Political League | 11/19/2024 | $500 |
| Sign Pictorial & Display | 11/20/2024 | $500 |
Committee Response to Finding
The Treasurer provided the following comment: “The information reported by the Committee reflects the information the donor originally entered into our online fundraising page (ActBlue) at the time they executed the contribution. In order to ensure accurate and complete information on the Committee’s contributors, we pursued several mechanisms to verify and correct contributor information. First, when possible, we review and correct any discrepancies before uploading the data into NGP. Second, if we are unable to locate the donor in our records, we work with the campaign to determine if they have additional information. Third, if the campaign is unable to provide additional information on the donor, we conduct additional research using publicly available resources to attempt to verify the donor’s full name, address, employer, and occupation. While we maintain careful review procedures, occasional discrepancies may still occur due to human error.
Please note that the .cal file containing the missing FPPC IDs was uploaded into NetFile and no error notice was generated. The Committee believes NetFile should flag this issue. The Committee has communicated this to NGP but has not received a response as of March 9, 2026.”
Finding V-4. The Committee did not properly report accrued expenses
Applicable Law
Committees must report an accrued expense as of the date on which the goods or services are received, and must report outstanding accrued expenses on each campaign statement until extinguished. 2 CCR § 18421.6(a)-(b). Regularly recurring administrative overhead expenses, such as for rent, utilities, or salaries, are not required to be reported as an accrued expense before the payment due date. Id.
Local law requires a committee to report the date of each expenditure required to be disclosed. C&GCC § 1.112(a)(4). For purposes of this section, an expense is incurred on the date the payment is made or the date consideration is received or performed, whichever is earlier, and an accrued expense is incurred on the date the debt or obligation is contracted. C&GCC Reg. § 1.112-1(a)-(b).
Analysis
Auditors reviewed a sample of 133 expenditures and identified 11 transactions (8.3% of the sample) for which the purchased goods or services had been incurred or received in a reporting period prior to the one in which they were paid, none of which the Committee correctly reported on Schedule F (Accrued Expenses) of the Form 460.
For the nine expenditures summarized in the table below, the Committee did not report an incurred expense on Schedule F as required by Regulation 18421.6. In each instance, the Committee reported the expenditure on Schedule E (Payments Made) for the reporting period in which it paid the vendor, but supporting invoices show that the expense had been incurred in a previous reporting period. For expenditures to Herrera Arellano, LLP and Nielsen Merksamer for legal services, the supporting invoices listed dated services that occurred in multiple previous reporting periods.
| Payee | Amount | Date(s) Expense Incurred | Period(s) Incurred | Period Reported |
|---|---|---|---|---|
| Herrera Arellano, LLP | $65,756 | 1/5/2024 – 8/23/2024 | 1/1/2024 – 6/30/2024 & 7/1/2024 – 9/21/2024 | 9/22/2024 – 10/19/2024 |
| Impact Research, Inc. | $67,300 | 6/10/2024 | 1/1/2024 – 6/30/2024 | 7/1/2024 – 9/21/2024 |
| Spotlight Printing | $21,508 | 6/28/2024 | 1/1/2024 – 6/30/2024 | 7/1/2024 – 9/21/2024 |
| $15,642 | 9/18/2024 | 7/1/2024 – 9/21/2024 | 9/22/2024 – 10/19/2024 | |
| Margaux Kelly | $800 | 8/28/2024 | 7/1/2024 – 9/21/2024 | 9/22/2024 – 10/19/2024 |
| $4,732 | 10/29/2024 | 10/20/2024 – 10/30/2024 | 10/31/2024 – 12/31/2024 | |
| Acres | $17,000 | 10/9/2024 | 9/22/2024 – 10/19/2024 | 10/20/2024 – 10/30/2024 |
| Nielsen Merksamer | $23,889 | 10/15/2024 – 10/30/2024 | 9/22/2024 – 10/19/2024 & 10/20/2024 – 10/30/2024 | 10/31/2024 – 12/31/2024 |
| Blue Nation Strategies | $20,764 | 10/16/2024 | 9/22/2024 – 10/19/2024 | 10/20/2024 – 10/30/2024 |
For the additional two expenditures summarized in the table below, the Committee reported the initial accrual of the expenses on Schedule F for the reporting period in which they were incurred, but did not carry forward the reporting of those expenses on Schedule F in the next reporting period, nor did they report the expense as extinguished when they were paid. Auditors noted that this same error was repeated for all six expenses reported by the Committee on Schedule F during the audit period. The Committee reported each expense in a single filing when it was incurred, but did not report the outstanding balance on each subsequent campaign statement until extinguished, as required by 18421.6.
| Payee | Amount | Date Expense Incurred | Period Incurred | Period Expense Paid |
|---|---|---|---|---|
| Saving San Francisco Voter Guide | $10,000 | 10/17/2024 | 9/22/2024 – 10/19/2024 | 10/31/2024 – 12/31/2024 |
| Vy Photography | $800 | 10/19/2024 | 9/22/2024 – 10/19/2024 | 10/31/2024 – 12/31/2024 |
Committee Response to Finding
The Treasurer provided the following comment: “The Committee reported accrued expenses based on invoice information available as of each reporting deadline. In several instances, invoices had not been received in time to report accruals in the period in which expenses were incurred. Given the corrective action taken, the fact that the Committee reported accrued expenses for the vast majority of expenditures and nearly every time the Committee had received information to enable the reporting of accrued expenses, we believe Finding V-4 is more appropriate for Section VI (Other Identified Findings) than for Section V (Material Audit Findings).”
Auditor Comment
Auditors consider this finding to be material based on a general 5% materiality threshold, and Auditors found 8.3% of the sampled expenditures did not conform to accrual reporting standards. While the Treasurer provided corrected accrual date information in response to a draft of this report, it is Auditors’ practice to consider a reporting error non-reportable or non-material on the basis of corrective action only if a committee amended its Form 460 filings to report corrected information prior to Auditors’ discovery of the error. Auditors note that if the Committee consistently received vendor information after the respective reporting deadlines, the Committee could amend previous campaign statements at any time during the campaign, which Auditors would consider to be timely corrective action.
Finding V-5. The Committee did not appropriately report street addresses for several expenditures
Applicable Law
For each person to whom a committee has made an expenditure of $100 or more, the committee must disclose the full name and street address of the payee, the amount of each expenditure, and a brief description of the consideration received. Gov’t Code § 84211(k). A “street address” means a real property’s street name, building number, city, state, and zip code. 2 CCR § 18250(a).
Analysis
Based on a review of filing data for Schedule E (Payments Made) of the Committee’s filed Form 460s, Auditors determined that the Committee reported 282 unique payees, of which 19 payees (6.7%) were reported without an appropriate street address. The Committee reported 11 payees without entering any information into the address field. For seven payees, the Committee reported a P.O. Box, which is not a street address as defined by Regulation 18250(a). Finally, the Committee reported “Information Requested” for an expenditure to Artist Construction.
The table below summarizes the expenditures discussed in this finding:
| Payee | Reported in lieu of Street Address |
|---|---|
| Chinese American Democratic Club PAC | [Blank] |
| Clarke & Sampson | |
| Constant Contact | |
| Grand Palace Restaurant | |
| Headquarters | |
| Lai Hong Lounge | |
| LPH Shipping | |
| PDI | |
| Recology | |
| San Francisco Firefighters | |
| White Cap | |
| Artist Construction | Information Requested |
| Acres | [P.O. Box] |
| Comcast | |
| Gensler | |
| Netfile Inc | |
| Paul Armstrong | |
| Starbucks | |
| Susan Anderson-Norby |
Committee Response to Finding
The Treasurer provided the following comment: “The Committee was committed to full transparency and proper disclosure practices throughout the election cycle. While the Committee accepts responsibility for these omissions, it notes that the NetFile system does not currently flag missing address fields upon .cal file upload, which would help prevent such errors in future filings.”
Finding V-6. The Committee likely reported inaccurate dates for contributions made by check
Applicable Law
For each individual from whom a committee has received cumulative contributions of $100 or more, the committee must disclose the contributor’s full name, street address, occupation, employer, or, if self-employed, the name of the business, the date and amount of the contribution, and the cumulative amount of contributions received. Gov’t Code § 84211(f), C&GCC § 1.114.5(a).
A monetary contribution is received on the date that the candidate or committee, or an agent of the candidate or committee, obtains possession or control of the check or other instrument by which the contribution was made. 2 CCR § 18421.1(c).
Analysis
Auditors reviewed a sample of 135 contributions, of which 14 transactions (10.4% of the sample) were made by check. For each check contribution, the Committee provided Auditors with an individual file containing a copy of the check. Each file name contained a date that agreed with the reported date for the respective contribution on Schedule A (Monetary Contributions Received) of the Committee’s Form 460s. These dates appeared to be in batches that roughly corresponded to check deposit dates found in the Committee’s bank statements. The Treasurer confirmed to Auditors that the reported dates for all contributions made by check are the dates on which they were deposited into the bank account.
The Committee reported a total of 2,822 itemized contributions, of which Auditors determined about 280 contributions (9.9%) were made by check. These checks were deposited by the Committee in about 37 batches. Accordingly, the Committee reported these 280 contributions using 37 contribution dates. Auditors conclude that the reported contribution dates for all check contributions likely do not accurately reflect the dates that the Committee, or an agent of the Committee, obtained possession of each check, pursuant to Section 84211(f) and Regulation 18421(c).
To illustrate this issue, the table below summarizes one example of a check batch deposited on August 15, 2024. Auditors note that the date on the check is not necessarily the date that the Committee might have received it. Nevertheless, the check date is the best evidence available to Auditors to approximate the date on or around which the Committee received the contribution. Most relevantly, the table below demonstrates the wide variance of check dates contained in a single deposit batch, and for which the same contribution date was reported.
| Contributor | Amount | Check Date | Reported Date |
|---|---|---|---|
| Sprinkler Fitters United Association 709 PAC | $500 | 6/20/2024 | 8/15/2024 |
| Sprinkler Fitters & Apprentices Local 483 PAC | $500 | 7/12/2024 | |
| Diana Wild | $250 | 7/22/2024 | |
| Joanne McIntosh Hickman | $500 | 7/31/2024 | |
| Rachel Kassabian | $500 | 7/31/2024 | |
| Joseph Wineroth III | $500 | 8/1/2024 | |
| Karen Dipaolo | $500 | 8/1/2024 | |
| Katherine Wineroth | $500 | 8/1/2024 | |
| Chris Mufarreh | $500 | 8/6/2024 | |
| Christine Carr | $500 | 8/6/2024 | |
| William Musgrave | $500 | 8/6/2024 | |
| Yi Zhang | $100 | 8/10/2024 | |
| Mearu Takatsu | $250 | 8/12/2024 | |
| John Chung | $250 | 8/14/2024 |
Committee Response to Finding
The Treasurer provided the following comment: “On 8/15/24, Shantal Sutherland received an email from Sylvia Liu outlining the contributions that the auditor has listed above, and noted that the Committee had received these contributions on 8/14/2024. Shantal mistakenly reported the contribution received date as the date she received the notice of contributions, 8/15/24, instead of the date the contributions were received by the committee 8/14/24. We believe this error caused no harm to the public.”
Auditor Comment
Auditors note that the dates of concern in this finding are the dates appearing on the copies of the checks themselves, which indicate that the contributors wrote the checks over the span of several months. Because a monetary contribution is considered received on the date that the Committee, or an agent of the Committee, obtained possession of the check, Auditors identified a risk that these checks may have been collected or received by an individual or entity before being passed on to the committee, which Auditors would consider to be “received” by an agent of the Committee on a prior date.
Finding V-7. The Committee did not report the required dates for any expenditures
Applicable Law
The Ethics Commission requires committees primarily formed to support or oppose a candidate for City elective office to file disclosure statements or reports in an electronic format prescribed by the Commission. C&GCC § 1.112(a)-(b), C&GCC Reg. § 1.112-3.
For any report required to be filed under Section 1.112, local law requires a committee to report the date of each expenditure required to be disclosed. C&GCC § 1.112(a)(4).
Analysis
Auditors examined filing data for Schedule E (Payments Made) of the Committee’s filed Form 460s and determined that the Committee did not report a date for any of the 1,420 expenditures reported during the audit period as required by Section 1.112(a). While the standard Form 460 does not include a date field on Schedule E, NetFile—the Commission’s vendor that maintains the filing system via which committees active in San Francisco file their campaign forms—provides a field for the entry of expenditure dates, which are then made public as data available on the Commission’s website.
| Reporting period | Number of contributions reported without a date |
|---|---|
| 1/1/2024 – 12/31/2024 | 1,420 |
Committee Response to Finding
The Treasurer provided the following comment: “Form 460, Schedule E does not contain a date field, and public disclosures filed by other mayoral candidate committees likewise do not reflect transaction dates on Schedule E.
Although disbursements were entered into NGP with transaction dates, those dates, along with FPPC ID numbers, were excluded from the .cal file generated by NGP. We notified NGP of this issue on February 11, 2026, and were advised that the matter had been escalated to the Office of Campaign Finance. We followed up on February 18 and again on February 23, 2026, and have received only one response indicating that the Office of Campaign Finance is ‘working on the case.’
In our effort to diligently comply with the statute, our team engaged in numerous email exchanges and phone calls with the SF Ethics team. At no time was the absence of Schedule E transaction dates raised as an issue. Additionally, when the .cal file containing the missing disbursement dates was uploaded into NetFile, no error notice was generated. Again, the Committee [sic]
Further, the public disclosures of other candidate committees, which we reviewed for consistency, reflect the standard Form 460 format and similarly do not include transaction dates on Schedule E. For the aforementioned reasons, we believe Finding V-7 is more appropriate for Section VI (Other Identified Findings) than for Section V (Material Audit Findings).
The Committee made substantial and diligent efforts to comply with the requirements of applicable law throughout the audited period. We respectfully request that the Commission consult with its Campaign Finance and Matching Funds Division staff regarding any findings in this report. Those staff members can attest to the extensive communications that took place between the Commission and the Committee in a shared effort to ensure proper compliance with the statute.”
Auditor Comment
Auditors note that while the paper or PDF version of the Form 460 does not have a field for expenditure dates, the aforementioned local law requires expenditure dates to be reported for any report required to be filed electronically under Section 1.112. While Auditors acknowledge that no PDF copy of any other candidate committee’s campaign filings includes expenditure dates, such information is available when campaign filing data is downloaded in Excel or CSV format, as is made publicly available on the Ethics Commission’s website. Auditors also note that while Commission staff provided guidance to the Treasurer on multiple areas in response to the Committee’s inquiries, the reporting of expenditure dates was not raised, and this issue was identified through the audit.
VI. Other Identified Findings
Auditors identified the following non-material findings during the audit. These findings represent instances of noncompliance discovered through review of the Committee’s filings and support documentation and through testing of sampled transactions that were determined not to be material in terms of frequency or dollar amount. This information is reported for the awareness of committees and treasurers and to facilitate the tracking of trends across audit reports.
Finding VI-1. The Committee did not file copies of mass mailings
Applicable Law
Under City law, each time a committee pays for a mass mailing, defined as 200 or more substantially similar pieces of mail that advocates for or against one or more candidates for City elective office, it must file a copy of the mailing and an itemized disclosure statement with the Ethics Commission within 5 business days after the date of the mailing, or within 48 hours if the date of the mailing is within 16 days before the election. C&GCC §§ 1.161(b)(3)(A)-(B), 1.104, incorporating Gov’t Code § 82041.5. Committees comply with this requirement by filing Form SFEC-161. C&GCC Reg. § 1.161-1(a).
Analysis
During the audit period, the Committee filed five Form SFEC-161s in connection with expenditures for mass mailings. NetFile allows committees to upload an attachment for each Form SFEC-161 filing, which is intended to be a copy of the mailed advertisement. However, for each filed SFEC-161, the Committee included an invoice from the vendor as an attachment, rather than a copy of the mailing as required by Section 1.161(b).
Additionally, as related to Finding V-1 above, each Form 161 for the four mass mailings associated with expenditures to Blue Nation Strategies did not include itemized costs, but rather reported only a single payment to Blue Nation Strategies.
The table below summarizes the mass mailing expenditures discussed in the finding:
| Payee | Date of Mailing | Amount |
|---|---|---|
| TogetherSF Action | 9/26/2024 | $29,500 |
| Blue Nation Strategies | 10/3/2024 | $10,514 |
| 10/9/2024 | $20,264 | |
| 10/16/2024 | $20,264 | |
| 10/25/2024 | $20,264 |
Committee Response to Finding
The Treasurer provided the following comment: “The Committee anticipated that Together SF Action would file a copy of the communication, and thus that the communication would be available to the public.”
Finding VI-2. The Committee received contributions that were likely prohibited under the City’s contractor contribution prohibition
Applicable Law
Under local law, no City contractor or affiliate of a City contractor may make any contribution to a candidate for an office for which the individual holding that office, or the board on which such an individual serves, must approve the contractor’s contract, for a period of 12 months after the date of contract approval. C&GCC § 1.126(b)-(c).
An individual holding City elective office, or the clerk of the board on which such an individual serves, must notify the Ethics Commission by filing Form SFEC-126 within five business days of the approval of each contract by the relevant officer or board. Id. § 1.126(f)(4), C&GCC Reg. § 1.126-4(a)-(b).
Pursuant to the contribution ban in Section 1.126, a committee will meet due diligence requirements if the contributor certifies under penalty of perjury, in writing, including in an electronic format, that the contributor does not meet the aforementioned criteria in Section 1.126. C&GCC Reg. § 1.126-7.
Analysis
Utilizing Form SFEC-126 filing data made publicly available on the Ethics Commission’s website, Auditors compared the affiliates and subcontractors reported by the Mayor’s Office to the contributors disclosed by the Committee. Auditors identified 11 contributors who appeared to be listed as either affiliates or subcontractors to contracts that were approved by the Mayor’s Office. Because the Candidate was a candidate for the office of Mayor, these contributions appear to have been prohibited by the City’s contractor contribution prohibition.
Notwithstanding, Auditors verified that the Committee included the language specified in Regulation 1.126-7 on contributor cards and its online contribution landing platform, and the Committee thereby likely met the due diligence requirement of Regulation 1.126-7.
Refer to the table below for more details on the contributions discussed above.
| Contributor/Affiliate Name | Contractor Name | Contract Approval Date | Contribution Date | Contribution Amount |
| John Saia | Catholic Charities CYO of the Archdiocese of San Francisco | 9/21/2023 | 2/14/2024 | $500 |
| James Sangiacomo | 101 South Van Ness, LLC | 5/4/2023 | 2/18/2024 | $500 |
| Maryanne Sangiacomo | 101 South Van Ness, LLC | 5/4/2023 | 2/18/2024 | $500 |
| William Oberndorf | University of California, San Francisco | 11/11/2023 | 2/27/2024 | $500 |
| Lee Hsu | Richmond Area Multi-Services | 11/8/2023 | 2/29/2024 | $500 |
| John Hamilton | CSG Advisors | 6/28/2023 | 3/25/2024 | $500 |
| Philip Kearney | Catholic Charities CYO of the Archdiocese of San Francisco | 9/21/2023 | 4/24/2024 | $250 |
| Bruce Callander | Boys & Girls Clubs of San Francisco | 2/12/2024 | 8/6/2024 | $500 |
| Bora Ozturk | Costanoan LLC | 10/18/2023 | 8/29/2024 | $500 |
| Yola Ozturk | Costanoan LLC | 10/18/2023 | 8/29/2024 | $500 |
| Tommy Chan | Chinatown Community Development Center, Inc. | 10/17/2023 | 9/10/2024 | $100 |
Committee Response to Finding
The Treasurer provided the following comment: “The Committee implemented procedures to help prevent the acceptance of prohibited contributions. They included language in fundraising emails reminding donors that City contractors were prohibited from contributing to the committee. Additionally, Jessica Burdge and other members of the finance team reviewed donor information to identify individuals who might be prohibited based on their listed occupation or employer.”
VII. Conclusion
Except as noted in the audit findings sections above, and based on the evidence obtained, Auditors conclude that the Committee substantially complied with the requirements of the California Political Reform Act and the San Francisco Campaign and Governmental Conduct Code. The Committee was provided a copy of this report and an opportunity to respond. The Committee’s comments are included in this report alongside the relevant finding.
This report and the support documentation on which it is based will be forwarded to the Commission’s Enforcement Division for further investigation and/or enforcement action as warranted. The scope of the audit is not exhaustive of all conduct of the Committee during the audit period, and any subsequent enforcement action may include conduct not covered in this report.
This Audit Report is intended to provide information about the Committee’s activities and its compliance with campaign finance requirements to the Commission, the Committee and its Treasurer, and San Francisco voters. This report, and all Audit Reports prepared by the Commission, will be posted to the Commission’s website at sfethics.org.
Appendix A
Objectives and Methodology
Audit Objective 1
Determine whether disclosed campaign finance activity materially agrees with activity in the Committee’s bank account.
Methodology:
- Calculated total reported contributions and expenditures in the Committee’s filings and total reported credits and debits in the Committee’s bank statements.
- Applied adjustments as needed to account for variations in transaction reporting between sources.
Audit Objective 2
Determine whether the Committee accepted contributions from allowable sources and in accordance with limits, appropriately disclosed those contributions, and maintained required contribution records.
Methodology:
- Reviewed contributions submitted for public funds matching for compliance with limits and accuracy of contributor information.
- Selected a statistically significant sample at a 95% confidence level and a 3.5%margin of error based on the total number of reported contribution transactions. Selected samples for testing from a range of periods, sources, and payment methods.
- Reviewed each sampled transaction for compliance with state and local requirements regarding contribution restrictions, disclosure, and recordkeeping.
- Performed additional targeted testing of contributions identified through analysis of filing data and support records.
- Utilized automated procedures to analyze data extracted from the Committee’s filings. Identified contributions from prohibited sources and late-reported transactions. Verified identified noncompliance against support records.
Audit Objective 3
Determine whether the Committee made expenditures for allowable purposes, appropriately disclosed those expenditures, and maintained required expenditure records.
Methodology:
- Selected a statistically significant sample at a 95% confidence level and a 3.5%margin of error based on the total number of reported expenditure transactions. Selected samples for testing from a range of periods, sources, amounts, vendors, and agents.
- Reviewed each sampled transaction for compliance with state and local requirements regarding expenditure restrictions, disclosure, and recordkeeping, including any expenditures made to subvendors by agents or contractors of the committee.
- Performed additional targeted testing of expenditures identified through analysis of filing data and support records.
- Utilized automated procedures to analyze data extracted from the Committee’s filings. Identified late-reported transactions and verified identified noncompliance against support records.
Audit Objective 4
Identify any other evidence of potential noncompliance for inclusion in the audit report or referral for further investigation.
Methodology:
- Analyzed data extracted from the Committee’s filings.
- Analyzed support records obtained from the Committee.
Appendix B
Supplemental Tables to Finding V-4
Table B-1. Contributions for which the reported employer information was incomplete.
| Contributor | Date | Amount | Reported Employer |
|---|---|---|---|
| Elizabeth Callander | 9/17/2024 | $500 | Information Requested |
| Zoe Sun | 9/17/2024 | $500 | |
| Shannon Tobin | 10/22/2024 | $500 | |
| Andrew Ho | 10/28/2024 | $200 | |
| Vikram Gupta | 2/13/2024 3/28/2024 | $100 (refunded) $500 | Self Employed |
| Tim Houts | 2/13/2024 | $500 | |
| Allison Johnson | 2/13/2024 | $500 | |
| Jenny Moore | 2/13/2024 | $500 | |
| Kevin Birmingham | 2/14/2024 | $500 | |
| Tom Coates | 2/14/2024 2/20/2024 | $500 $500 (refunded) | |
| Mary Edwards | 2/14/2024 6/17/2024 | $500 $100 (refunded) | |
| Linda Coates | 2/15/2024 2/20/2024 | $500 $500 (refunded) | |
| Brian Graham | 2/15/2024 | $250 | |
| Jim Hughes | 2/15/2024 | $500 | |
| James Lind | 2/15/2024 | $150 | |
| Jade Civitello | 2/18/2024 6/25/2024 | $500 $100 (refunded) | |
| Tom Klein | 2/18/2024 | $500 | |
| Cynthia Oneill | 2/18/2024 | $500 | |
| Robert Pedrero | 2/20/2024 | $500 | |
| Keith Denkler | 2/22/2024 | $100 | |
| Anthony Hay | 2/22/2024 | $500 | |
| W. Koch | 2/25/2024 | $500 | |
| Jennifer Battat | 2/26/2024 | $500 | |
| Rebecca Lee | 2/27/2024 | $500 | |
| Desiree Miles | 2/29/2024 4/8/2024 | $500 $100 (refunded) | |
| Dennis Ryan | 3/4/2024 | $500 | |
| Deirdre Burke | 3/6/2024 | $500 | |
| Russell Long | 3/14/2024 3/28/2024 | $50 $500 | |
| Sara Downs | 3/14/2024 | $500 | |
| Al Ghamgosar | 3/20/2024 | $100 | |
| Caroline Pacula | 3/21/2024 | $500 | |
| John Hamilton | 3/25/2024 | $500 | Self Employed |
| Kelley Myerberg | 3/26/2024 | $350 | |
| Karla Ellis-Davis | 4/4/2024 | $500 | |
| Vladislav Okel | 4/7/2024 | $500 | |
| Ellen Heneghan | 4/8/2024 | $500 | |
| Christopher Panizzon | 4/16/2024 | $200 | |
| Matthew Cook | 4/17/2024 | $500 | |
| Oliver Browne | 4/18/2024 | $200 | |
| Kathy Chan | 5/1/2024 | $500 | |
| Maria Lukens | 5/2/2024 | $500 | |
| William Mandel | 5/16/2024 | $500 | |
| Pedro Marques | 5/16/2024 | $500 | |
| Camilla Field | 6/4/2024 | $500 | |
| Anne Oliva | 6/10/2024 | $500 | |
| John Marshall | 6/12/2024 | $100 | |
| Sean Begley | 6/18/2024 | $500 | |
| Lin Lee | 6/18/2024 | $100 | |
| Daniel O?Aoneill | 6/25/2024 | $500 | |
| Renata Kiefer | 6/27/2024 | $100 | |
| Kathleen Martin-McKeon | 6/27/2024 | $150 | |
| Rachel Duarte | 6/30/2024 | $250 | |
| Robert Ho | 7/1/2024 | $500 | |
| Norm Fung | 7/2/2024 | $250 | |
| Nanette Gordon | 9/25/2024 | $500 | |
| Junjie Huang | 9/25/2024 | $288 | |
| Brian Spiers | 9/25/2024 | $500 | |
| Matthew Kemner | 10/1/2024 | $100 | |
| Alexis Woods | 10/1/2024 | $500 | |
| Eric Tilenius | 10/2/2024 | $50 | |
| Gordon Rubenstein | 10/6/2024 | $250 | |
| Tomer Maymon | 10/6/2024 | $180 | |
| Teresa Shaw | 10/6/2024 | $500 | |
| Simi Chehrazi | 10/8/2024 | $500 | |
| Suzette Clarke | 10/21/2024 | $500 | |
| Laney Thornton | 10/21/2024 | $500 | |
| Pasha Thornton | 10/21/2024 | $500 | |
| David Hagerman | 10/22/2024 | $500 | |
| Kenneth Loveless | 10/22/2024 | $500 | |
| Mary Hartley | 10/24/2024 | $500 | |
| John Warda | 10/24/2024 | $500 | |
| Suzanne Lo | 11/6/2024 | $500 |
Table B-2. Contributions for which the reported employer name was an acronym.
| Contributor | Contributor Employer | Date | Amount |
|---|---|---|---|
| David Becher | SFPA | 2/13/2024 | $500 |
| Kathleen Daly | OEL | 2/13/2024 | $500 |
| Michael Carrington | HTD | 2/13/2024 | $500 |
| Suril Shah | KRL | 2/13/2024 | $500 |
| Robert Anderson | NNI | 2/18/2024 3/12/2024 4/8/2024 6/25/2024 | $100 $100 $100 $200 |
| Andrew Kronk | GNE | 2/27/2024 | $250 |
| Eugenia Corrales | NNIO, Inc. | 3/17/2024 | $100 |
| Josephine Battaglia-Ghamgosar | PFAC | 3/20/2024 | $500 |
| Mary McKeever | ADSF | 4/8/2024 | $100 |
| Anne Devereux-Mills | MFE | 5/2/2024 | $500 |
| Daniel Ross | ICC | 5/14/2024 | $500 |
| Matthew McLeod | Gac | 5/15/2024 7/17/2024 | $100 $250 |
| Anne Ryan | KCM | 5/30/2024 | $500 |
| Jack Edwards | JMP | 6/27/2024 | $500 |
| Alexander Efron | THP | 8/1/2024 9/8/2024 | $200 $100 |
| Dorka Keehn | Koa | 8/1/2024 | $150 |
| Bilques Smith | IC | 8/18/2024 | $250 |
| Robert Matkin | NMI | 8/18/2024 10/15/2024 | $100 $100 |
| Sarah Beach | OHS | 8/27/2024 | $100 |
| Paul Stephens | BCAP | 9/11/2024 | $500 |
| George Lam | CFG | 9/17/2024 11/4/2024 | $500 $500 (refunded) |
| Henry Lam | CFG | 9/17/2024 11/4/2024 | $500 $500 (refunded) |
| Vincent Budhai | FSG | 9/17/2024 | $250 |
| Daniel Goldberg | LMPP | 9/19/2024 | $100 |
| Marshall Boyd | IEC | 9/19/2024 | $500 |
| Jamie Bauer | Asp | 10/13/2024 | $500 |
| Stewart McDowell | Gcc | 10/13/2024 | $500 |
| Callaghan Fritz-Cope | FPG | 10/31/2024 | $500 |
Table B-3. Contributions for which the reported occupation information was insufficient.
| Contributor | Date | Amount | Reported Occupation |
|---|---|---|---|
| Shannon Davis | 2/13/2024 | $500 | Entrepreneur |
| Dariush Pouraghabagher | 2/13/2024 | $500 | |
| Russell Long | 3/14/2024 3/28/2024 | $50 $500 | |
| Alex Tonelli | 9/10/2024 | $500 | |
| Harrison Dillon | 9/12/2024 | $500 | |
| Nathan Sharp | 9/16/2024 | $250 | |
| Joju Mangalam | 9/22/2024 10/7/2024 | $50 $50 | |
| Gordon Rubenstein | 10/6/2024 | $250 | Entrepreneur/Investor |
| Elizabeth Callander | 9/17/2024 | $500 | Information Requested |
| Zoe Sun | 9/17/2024 | $500 | |
| Shannon Tobin | 10/22/2024 | $500 | |
| Gail Goldyne | 6/30/2024 | $250 | Investments |
| Chris Ehrlich | 2/13/2024 | $500 | Investor |
| Bob Ghoorah | 2/13/2024 | $500 | |
| Suril Shah | 2/13/2024 | $500 | |
| Paul Wythes Jr. | 2/13/2024 | $200 | |
| Akshay Goyal | 2/19/2024 | $200 | |
| Emily Paxhia | 2/28/2024 9/22/2024 | $500 $500 (refunded) | |
| Tullio Purtill | 2/28/2024 | $500 | |
| Beverly Hayes | 3/6/2024 | $100 | |
| Stuart McLaughlin | 3/21/2024 | $500 | |
| Richard Price | 3/28/2024 | $500 | |
| Lindsay Bolton | 4/21/2024 | $500 | |
| James Shapiro | 4/28/2024 | $500 | |
| Kathy Chan | 5/1/2024 | $500 | |
| Matthew Buchwald | 5/22/2024 | $100 | |
| Peter Nanula | 6/17/2024 | $500 | |
| Alexander Rosen | 6/30/2024 9/15/2024 | $150 $500 (refunded) | |
| Alexander Efron | 8/1/2024 9/8/2024 | $200 $100 | |
| Vivian Wu | 8/4/2024 | $500 | |
| Brian Singerman | 8/20/2024 | $500 | |
| Matthew Ebbel | 8/26/2024 | $500 | |
| Daniel Robinson | 8/27/2024 | $500 | |
| Michael Cohen | 9/10/2024 | $250 | |
| Michael Kerns | 9/10/2024 | $500 | |
| Michael Feldman | 9/16/2024 | $500 | Investor |
| Nicholas Shalek | 9/17/2024 | $500 | |
| Mark Conroe | 9/19/2024 | $500 | |
| Marshall Boyd | 9/19/2024 | $500 | |
| Zachary Rosen | 10/1/2024 | $180 | |
| Jefferson Steele | 10/8/2024 | $500 | |
| Amit Kumar | 10/16/2024 | $350 | |
| Vishal Lugani | 10/16/2024 | $295 | |
| Suzette Clarke | 10/21/2024 | $500 | |
| Mary Hartley | 10/24/2024 | $500 | |
| Mark Whiting | 10/28/2024 | $500 | |
| Lee Wittlinger | 11/3/2024 | $350 | |
| Rachel Duarte | 6/30/2024 | $250 | Philanthropist |
| Frank Billante | 2/27/2024 | $500 | Self Employed |
| Jason Cheng | 2/18/2024 | $250 | |
| Sunny Chu | 2/13/2024 | $500 | |
| Matthew Hyman | 6/19/2024 | $500 | |
| Shannon King | 6/9/2024 | $500 | |
| Jae Park | 2/13/2024 | $500 | |
| Dang Pham | 5/2/2024 | $100 | |
| Hui Li | 9/25/2024 | $250 | Worker |
| Jeff Su | 9/27/2024 | $500 | |
| Mun Zeto | 10/2/2024 | $200 | |
| Francis Zhang | 10/14/2024 | $100 |
Table B-4. Contributions for which a street address was not reported.
| Contributor | Date | Amount | Reported Address |
| Rebecca Lee | 2/27/2024 | $500 | [P.O. Box] |
| Bartholomew Cronin | 2/13/2024 | $500 | |
| Paul Armstrong | 2/13/2024 3/13/2024 | $500 $500 (refunded) | |
| Deborah Lightfoot | 2/13/2024 | $500 | |
| David Baylor | 2/13/2024 | $500 | |
| Paul Tonelli | 2/13/2024 | $500 | |
| Donald St. Pierre | 2/14/2024 | $500 | |
| Ken Freeman | 2/18/2024 | $500 | |
| Robert Pedrero | 2/20/2024 | $500 | |
| Rebecca Kassekert | 2/22/2024 | $500 | |
| Marguerite Slavonia | 2/28/2024 | $500 | |
| John Lumpkin | 2/29/2024 | $500 | |
| Lee Hsu | 2/29/2024 | $500 | [P.O. Box] |
| Susan Anderson-Norby | 3/5/2024 4/7/2024 5/5/2024 6/5/2024 9/29/2024 | $125 $125 $125 $125 $500 (refunded) | |
| Charles Mader | 3/19/2024 | $100 | |
| Wendover Brown | 4/11/2024 | $100 | |
| Tony Price | 4/24/2024 | $125 | |
| Connie Price | 4/24/2024 | $125 | |
| Robert Enright | 6/10/2024 10/29/2024 | $250 $250 | |
| Fritz Lynn | 6/11/2024 | $100 | |
| Nancy Kivelson | 6/17/2024 | $500 | |
| Andy Stone | 6/23/2024 | $500 | |
| Daniel O?Aoneill [sic] | 6/25/2024 | $500 | |
| Gus Cano | 6/30/2024 9/11/2024 10/1/2024 | $150 $150 $200 | |
| Donna Jones | 8/6/2024 | $500 | |
| Curtis Woodman | 8/20/2024 | $500 | |
| Haley Zhao | 8/25/2024 | $100 | |
| Hannah Kellogg | 9/8/2024 | $500 | |
| Mark Conroe | 9/19/2024 | $500 | |
| Thomas Doudiet | 10/2/2024 | $500 | |
| Earl Rogers | 10/24/2024 | $500 | |
| Catherine Dean | 10/30/2024 | $500 | |
| Gregg Brockway | 8/20/2024 | $500 | SAN FRANCISCO |
| Artist Construction | 9/27/2024 | $250 | Information Requested |
| Dylan Boudraa | 10/13/2024 | $500 | Unit 2 |
Appendix C
Committee’s Response to Finding V-1
Table C-1. The Committee provided the following data as part of its response to Finding V-1:
| Vendor | Subvendor | Purpose | Address | City | State | Zip | Date | Amount |
| Canal Partners | KTVU | TV Ad Buy | 2 Jack London Sq | Oakland | CA | 94607 | 10/7/2024 | $71,665 |
| KRON | TV Ad Buy | 900 Front St, 3rd Fl | San Francisco | CA | 94111 | 10/7/2024 | $18,950 | |
| KPIX | TV Ad Buy | 855 Battery St | San Francisco | CA | 94111 | 10/7/2024 | $67,500 | |
| KNTV | TV Ad Buy | 2450 N. First St | San Jose | CA | 95131 | 10/7/2024 | $53,100 | |
| KGO | TV Ad Buy | 900 Front St, 3rd Fl | San Francisco | CA | 94111 | 10/7/2024 | $106,550 | |
| Ampersand Cable | TV Ad Buy | 151 West 42nd St 11th Fl | New York | NY | 10036 | 10/7/2024 | $28,018 | |
| Ampersand Cable | TV Ad Buy | 151 West 42nd St 11th Fl | New York | NY | 10036 | 10/7/2024 | $9,928 | |
| KTVU | TV Ad Buy | 2 Jack London Sq | Oakland | CA | 94607 | 10/21/2024 | $44,904 | |
| KRON | TV Ad Buy | 900 Front St, 3rd Fl | San Francisco | CA | 94111 | 10/21/2024 | $13,080 | |
| KPIX | TV Ad Buy | 855 Battery St | San Francisco | CA | 94111 | 10/21/2024 | $54,475 | |
| KNTV | TV Ad Buy | 2450 N. First St | San Jose | CA | 95131 | 10/21/2024 | $51,965 | |
| KGO | TV Ad Buy | 900 Front St, 3rd Fl | San Francisco | CA | 94111 | 10/21/2024 | $104,350 | |
| KTVU | TV Ad Buy | 2 Jack London Sq | Oakland | CA | 94607 | 11/4/2024 | $1,540 | |
| KRON | TV Ad Buy | 900 Front St, 3rd Fl | San Francisco | CA | 94111 | 11/4/2024 | $770 | |
| KPIX | TV Ad Buy | 855 Battery St | San Francisco | CA | 94111 | 11/4/2024 | $8,880 | |
| KNTV | TV Ad Buy | 2450 N. First St | San Jose | CA | 95131 | 11/4/2024 | $17,830 | |
| KGO | TV Ad Buy | 900 Front St, 3rd Fl | San Francisco | CA | 94111 | 11/4/2024 | $7,900 | |
| Blue Nation Strategies | Leah Jones | Account work | 4447 North Central Expressway, Ste 110 PMB #121 | Dallas | TX | 75205 | Information requested, but not received | Information requested, but not received |
| Blue Nation Strategies | Eli Turner | Photographer | 6 Granville Dr | Silver Spring | MD | 20901 | Information requested, but not received | Information requested, but not received |
| Kate Connolly | Designer | 4327 44th Street Northwest | Washington | DC | 20016 | Information requested, but not received | Information requested, but not received | |
| Sam Nitz | Targeting | 609 Longfellow St., NW | Washington | DC | 20011 | Information requested, but not received | Information requested, but not received | |
| Pacific Printing | Printing | 1445 Monterey Hwy | San Jose | CA | 95110 | Information requested, but not received | Information requested, but not received | |
| ProofRead Now.com | Proofers | P.O. Box 503 | Mont Vernon | NH | 3057 | Information requested, but not received | Information requested, but not received |