Date: July 1, 2026
To: Members of the Ethics Commission
From: Jeffrey Zumwalt, Acting Director of Enforcement
Re: AGENDA ITEM 5: Quarterly Enforcement Report
Summary and Action Requested
This report provides general programmatic updates and data about the cases handled by the Commission’s Enforcement Division.
No action is required by the Commission, as this item is for informational purposes only.
Cases Resolved
Fiscal Year 2026
So far in Fiscal Year 2026 (July 1, 2025 – July 1, 2026), the Enforcement Division has completed a total of 105 enforcement matters. One additional matter is expected to be presented to the Commission as a stipulation under agenda item 10 at the July 10, 2026 Commission meeting.
Of the 105 completed matters, nine resulted in settlements and one resulted in a default order approved by the Commission. Collectively, these matters resulted in $26,113 in penalties.
Cases In Progress
So far in Fiscal Year 2026, 136 enforcement matters have been initiated. Of these, 91 matters originated from complaints received from the public. 45 matters were initiated by the Division based on media reports, observations in public disclosures, independent research, findings from audit reports, and interactions with regulated persons. Nine matters were initiated based on referrals from the Controller’s Whistleblower Program, and one matter was initiated based on a referral from the Sunshine Ordinance Task Force.
A total of 38 matters are currently in progress, including 27 matters initiated during Fiscal Year 2026, seven matters initiated during Fiscal Year 2025, and four matters initiated during Fiscal Year 2024. Of these matters, 13 are in preliminary review and 25 are open investigations.
Of the four matters initiated during Fiscal Year 2024, three remain under active investigation, and one is pending the assigned Commissioner’s order of determination regarding the parties’ motion to stay the administrative enforcement proceedings, subject to the limitations proposed by the Enforcement Division.
The current cases in progress are broken down by program area in Charts 1 and 2 below.
Matters in Preliminary Review
Chart 1 – Matters in Preliminary Review by Program Area: 13
Chart 2 – Open Investigations by Case Category: 25
Enforcement Regulations Review Project Update
In late 2024, Staff initiated a comprehensive review of the Enforcement Regulations to identify gaps, clarify ambiguities, and strengthen provisions governing the enforcement process. The objective is to ensure the regulations clearly inform the Commission, respondents, staff, and the public regarding the rules governing enforcement, and to support a process that is transparent, efficient, and fair for all parties.
In March and May 2025, Staff conducted a total of four interested persons meetings and incorporated stakeholder input into the proposed amendments.
On June 13 and July 11, 2025, Staff presented the proposed amendments to the Commission. On August 8, 2025, the Commission identified three substantive issues requiring further refinement and continued the matter for revisions consistent with Commission direction.
On August 13, 2025, MEA requested that the Department of Human Resources’ Employee Relations Division (“ERD”) meet and confer regarding the proposed amendments to the Enforcement Regulations on the grounds that they could affect represented employees.
Staff and ERD subsequently engaged in the meet-and-confer process over approximately nine months. The process included multiple in-person meetings, several rounds of written correspondence, and responses to two public records requests submitted by MEA. Throughout this process, Staff and ERD considered and responded to MEA’s proposals.
On May 29, 2026, ERD issued a close-out memorandum stating its determination that MEA had not identified any negotiable impacts arising from the proposed amendments, and that ERD considered its review of the meet-and-confer process with MEA complete. The memorandum further noted that MEA’s proposals concern the Commission’s statutory discretion and legal duties and do not constitute negotiable terms or conditions of employment subject to mandatory bargaining.
Accordingly, Staff will return to the Commission to seek approval of the finalized proposed amendments of the Enforcement Regulations, which are presented as agenda item 11 at the July 10, 2026 Commission meeting.
Form 700 Non-Filer Program
In early 2026, Staff collaborated across divisions to build new protocols for its Statement of Economic Interests (Form 700) non-filer program. This project included a new partnership with the Mayor’s Office to increase compliance from Commissioners and Board members, resulting in over 99% compliance rates as of June 1 from ethics filers.
The project also included a set of new, integrated communications systems across multiple divisions, coordinating and aligning the way the Division interacts with the regulated community. Finally, the project adopted a set of revised evaluation metrics governing the selection and handling of enforcement matters under the non-filer program. Staff used these new measures to select and open nine non-filer cases in early June.
In the coming months, Staff will be conducting a post-filing review of these new protocols, and will continue refining and improving them in the years to come.