Table of Contents
Maintain a System of Recordkeeping
Even before applying for public financing, it is vital that candidates implement a good system of recordkeeping for all financial activity by their committee. Such records are necessary for the preparation of accurate and complete campaign statements and must be submitted in the event the candidate is audited.
Important Note: All publicly financed candidates are subject to mandatory audits. Whatever method is used to organize records should be consistently used from Day 1. It will be easier to maintain a consistent system throughout the election rather than create or implement a new system in the middle of a campaign.
Keeping good records from the start will also help candidates in applying for public financing because, as described below, candidates must submit supporting documentation for each contribution that is included in a public financing submission. Candidates and treasurers are required to retain records related to all reported campaign activity for four years from the date of filing campaign statements, regardless of whether or not they seek or receive public funds.
Types of Records to Maintain
The list below outlines some of the types of documents and records committees are expected to maintain:
- Records related to contributions (i.e., deposit slips/receipts, copies of contribution checks, documentation of credit card contributions);
- Banking records (statements, check registers, A/R reports);
- Completed contributor cards and correspondence with contributors related to reported information;
- Letters, emails, texts, or other records describing nonmonetary contribution and how the value was determined;
- Documentation for all expenditures (canceled checks, electronic payments, invoices, receipts, bills, and payment authorizations);
- Petty cash register and related receipts;
- Copies of mass mailings and similar communication .
For more information regarding recordkeeping requirements, candidates may refer to FPPC Manual 2, Chapter 4 of the FPPC Political Reform Act, and the Ethics Commission’s Records Required for Audit and Guidelines for Organizing Records.
See Cal. Gov’t Code § 84104, 2 Cal. Code of Regs. § 18401, S.F. C&GC Code § 1.109, and SFEC Regulations § 1.142-3.
Supporting Documentation
While the specific types of records submitted can vary depending on your own record keeping practices, the supporting documents you submit with your contributions should demonstrate the following: (1) the contribution was received by the committee; (2) the contribution was deposited into the committee’s campaign account; (3) the contribution was received from an individual who is a San Francisco resident.
Each contribution included in a public financing submission must be accompanied by supporting documentation. Supporting records should be organized by deposit dates/batches and attached to the corresponding contribution (not as one single file). Committees may not rely on supporting documentation (e.g. deposit records) that were filed with a prior submission, but not included in the current submission. You are encouraged to contact Commission staff if you have questions about your supporting documents before submitting your Qualifying Request.
Contributions Made by Check
Receipt
To prove that a check contribution was received, provide a copy of the check attached to the contribution entry in the public financing submission.
Deposit
To demonstrate that a check contribution was deposited into the committee’s bank account, provide a document produced by the committee’s bank showing the deposit and a “deposit batch list” that includes all contributions included in that deposit. The bank document verifying deposit can be a bank statement or a deposit receipt. (See “Deposit Batch Lists & Batch Numbers” below for instructions on how to create a batch list.) The deposit record and batch list must be attached to at least one contribution from that deposit, however, Committees are encouraged to attach deposit records to each contribution included in every Qualifying or Matching Request.
Residency
If the contributor’s correct name and current San Francisco residential address are pre-printed on the check, the Commission will accept the information as proof of San Francisco residency. If the address is not pre-printed on the check or is out-of-date, candidates must provide separate proof of residency, as described in detail under “Supporting Documentation for Proving San Francisco Residency” below.
Special Considerations for Check Contributions
One Check from Two Accountholders: If a check contribution is drawn from an account with two accountholders (i.e., a check with two names on it), the accountholder who signs the check is considered the “contributor” and 100% of the contribution should be attributed to the signee. If the contribution is intended to be divided between both accountholders, either: a) both accountholders should sign the check and the contribution is attributed 50/50; or b) the accountholders must provide a signed statement identifying how the contribution should be attributed.
See 2 Cal. Code of Regs § 18533.
Checks Drawn on Business Accounts: Checks drawn on business accounts, including “sole proprietorship” entities, are not eligible for matching funds and cannot be included in a Qualifying or Matching Request. All qualifying contributions must be donated from an individual’s personal account, not from business accounts.
Examples:
See SFEC Regulations 1.104-1, 1.104-2.
Contributions Made by Credit Card
Receipt
To show a credit card contribution was received, in addition to any other supporting documentation (e.g. transaction receipt), committees must provide a transaction report from their credit card processing vendor listing all transactions processed. Vendor reports must be sent directly to the Ethics Commission (ethics.commission@sfgov.org) and should not be included as an attachment to the submission. The “vendor report” must include the following:
- Contributor’s full name
- Amount of and processing date for contribution
- Contributor’s address
- Card type, expiration date, and last-4 digits
- Date of transfer to committee and either transaction number (for electronic payments) or check number (for check payments)
- All credit card refunds processed by the vendor
Candidates or their committees may contact the Ethics Commission to review whether their credit card vendor report fulfills supporting documentation requirements prior to submitting a Qualifying Request or Matching Request.
Deposit
To prove that a credit card contribution was deposited into the committee’s bank account, provide:
- the vendor report described above showing that the contribution was transferred to the committee by check or electronic transfer and identifying the date of transfer (and any identifying information such as check number, transaction ID);
- a statement or receipt from the committee’s bank indicating that the check or electronic transfer from the credit card vendor was deposited into the committee’s account; and
- if the credit card contribution was transferred to the committee by the vendor through a check, a copy of the check.
If credit card contributions are electronically transferred to the committee, and the vendor report clearly identifies the transfer batches (i.e., the contributions included in each transfer, date of transfer, transfer ID/receipt number), a separate deposit batch list is not necessary. If the vendor report does not include this information, or funds are transferred by check, candidates will also need to submit a batch list indicating which contributions were included in the deposit.
Residency
In order to demonstrate a contributor is a San Francisco resident using the vendor report, the committee may rely on the AVS system if the following is true:
- AVS information in a vendor report confirms the address provided matches the billing address on file;
- City records show this address is a San Francisco residential address; and
- This address matches the contributor address listed in the Qualifying Request or Matching Request.
If an address is not verified by AVS, AVS information is not available, the AVS-confirmed billing address is not a residential address, or the confirmed address in the vendor report does not match the contributor address in the Qualifying Request or Matching Request, then the committee will be required to provide separate documentation to verify the contributor’s San Francisco residency. See “Supporting Documentation for Proving San Francisco Residency”.
Special Considerations for Credit Card Contributions
Address Verification Service (AVS): Though not required, committees are strongly encouraged to include the Address Verification Service (“AVS”) codes in the transaction report. The AVS system is used by credit card processors to verify that the address provided by a person using the credit card is the billing address listed for the credit card account and is used by Commission staff to verify a contributor’s residency status.
One Card Used for Multiple Contributions: If the transaction report indicates a single credit card (identified by last-4 digits and expiration date) was potentially used to process multiple contributions from different contributors, the committee may be asked to provide additional documentation demonstrating the source of funds used match the contributor identified. If the committee cannot reasonably demonstrate this, these contributions may not be approved.
Candidates are encouraged to contact the Ethics Commission with any questions regarding the committee’s process for accepting credit card contributions.
Contributions Made by Cash
Methods of payment that are considered “cash” include:
- Paper money/coins
- Money order
- Cashier’s or traveler’s check
- Postal money order
Receipt
To prove that a cash contribution was received, candidates must provide a contributor card that was completed, signed, and dated by the contributor at the time the contribution was made. Contributor cards are discussed in greater detail below. (Please note that a contributor card will only establish that the contribution was received.)
Deposit
To prove that a cash contribution was deposited into the committee’s bank account, candidates must submit both a deposit batch list and a document produced by the committee’s bank verifying the deposit of that batch. Refer to the instructions above for check contribution deposits, which explain the requirements regarding bank statements or receipts and batch lists. These requirements also apply to cash contributions. Also refer to the “Deposit Batch Lists & Batch Numbers” section below for more information about batch lists.
Residency
To prove the residency of a cash contributor, candidates should follow the instructions under “Supporting Documentation for Proving San Francisco Residency.”
Limits on Accepting Cash Contributions
Cash contributions of $100 are prohibited under City law. Committees may not give change to a contributor who donates $100 in cash or “refund” any amount over the limit on cash contributions (i.e., give $5 back in exchange for a $100 cashier’s check). Committees may also not accept smaller cash contributions that, in aggregate, equal or exceed $100 (e.g., five separate cash contributions of $20 each would violate the law).
Contributor Cards
A contributor card is a form that an individual fills out to provide the committee required contributor information. Contributor cards are mandatory for all cash contributions, however, candidates are encouraged to obtain a contributor card whenever possible (e.g., check or credit card contributions). Important Note: If any portion of the contributor card is completed by a representative of the committee, the committee should note which portions were completed and how that information was obtained.
The committee may use any style or format for a contributor card, but at a minimum the form must clearly identify the committee’s full name and FPPC ID number. Additional information regarding the solicitation of contributions and a sample contributor card is available on the Commission’s website. Committees are encouraged to contact the Ethics Commission with questions regarding their contributor information cards.
Supporting Documentation for Proving San Francisco Residency
Only contributions from City residents may be used to receive public funds. Therefore, in addition to providing supporting documentation regarding the receipt and deposit of contributions, candidates must also provide documentation demonstrating that contributors are residents of San Francisco. The committee can provide of any of the following to demonstrate residency:
- Contributor uses a San Francisco residential address as the address on any bank account or any account with a financial institution, through the submission of copies of recent bank statements, personal checks, or Address Verification Service information listing the account holder’s address;
- Contributor uses a San Francisco residential address as a billing address, through the submission of copies of recent credit card or utility bills;
- Contributor lives at a San Francisco address, through the submission of copies of a current deed or lease;
- Contributor uses a San Francisco residential address as a mailing address, through the submission of copies of recent mail received by the contributor;
- Contributor is currently registered to vote in San Francisco;
- Contributor has represented to a government agency that he or she lives at a San Francisco address, through the submission of copies of a driver’s license, passport, government-issued identification card, or tax returns.
Addresses that are post office box facilities, office/business addresses, or any other non-residential address will not be accepted even if these addresses were listed in one of the documents from above. Supporting documentation for residency must show the contributor’s name and primary residential address and must be current and valid at the time of the contribution (e.g., an expired driver’s license or utility bill from 4 months after the date of contribution will not be accepted). In the case of voter registration, candidates must provide the contributor’s unique San Francisco voter ID (the number assigned by the Department of Elections to registered voters). The Ethics Commission is unable to verify voter registration information on file with the Secretary of State or other agency.
Please note: All contributor information included in the Contributor List (e.g., residential address, contributor name) must match the supporting documentation provided. Any discrepancies or inconsistencies may result in the contribution not being approved for public funds.
See SFEC Regulations 1.142-3.
Helpful Tips
Collecting residency documentation such as leases, credit card bills, or driver’s licenses can be difficult and time consuming if requested after the contribution has been made. Try to ensure that, at the time a contribution is received, documentation to prove the contributor’s San Francisco residency is collected. To help, here are some methods for proving residency:
- For credit card contributions, check the credit card processor’s vendor report frequently and check to see if the AVS check shows a confirmed San Francisco residential address. If it does not, follow up with the contributor right away to seek one of the other forms of proof of residency listed above.
- For check contributions, confirm if a San Francisco address is pre-printed on the check. If it is not, ask the contributor at that time to provide the committee with another form of proof of residency.
- For any contribution that is not (a) a credit card contribution with an AVS-confirmed address, or (b) a check contribution with a pre-printed address, ask if they are registered to vote in San Francisco. If so, obtain the contributor’s voter registration number and include it in the Qualifying Request.
- AVS address confirmation, pre-printed addresses on checks, and voter registration are the most common ways to prove contributor residency.
Example
On August 8, Larry contributes $75 in cash. Because this is a cash contribution, Larry must provide a signed and dated contributor card that includes his name, address, date and amount of contribution, and any other information the committee is required to maintain. For proof of San Francisco residency, Larry provides a San Francisco voter registration number. In the public financing submission that includes Larry’s contribution, supporting documentation must include Larry’s completed contributor card, voter registration information, and proof of deposit (e.g., bank deposit receipt and deposit batch list).
Example 2
Jane contributes $50 on August 5 with a personal check that does not show her residential address. To prove that her current residential address is in San Francisco, she provides a copy of her driver’s license. When preparing a Qualifying Request or Matching Request that includes Jane’s contribution, supporting documentation must include a copy of the check, a copy of Jane’s driver’s license, and, to show that the contribution was deposited, proof of deposit (e.g., bank deposit receipt and deposit batch list).
Example 3
Peter contributes $100 with a personal check with a pre-printed address and a contributor card that indicates his current residential address is different from what is printed on his check. Peter provides a copy of a residential utility bill with a billing address that matches his contributor card. When preparing a Qualifying Request or Matching Request that includes Peter’s contribution, supporting documentation must include a copy of the check, the completed contributor card, and the utility bill. To show that the contribution was deposited, include proof of deposit (e.g., deposit receipt and batch list).
Deposit Batch Lists & Batch Numbers
Each time the committee deposits cash or checks into its bank account, the cumulative deposit is called a “batch.” Committees should assign each batch a unique “batch number,” and list the batch number for each contribution in the contribution list. Committees may use any batch numbering system as long as it is used consistently for all deposits. In addition to numbering deposit batches, committees must maintain itemized lists of all contributions in each deposit, regardless of whether the contribution(s) will be used for the public financing program.
For example, the committee deposits three checks and cash on June 6, 2019, and this batch is numbered “2019.06.06.” The deposit batch list may look like this:
Batch 2019.06.06 – Deposited June 6, 2019
| 1. | Bob Jones | $100.00 (check) |
| 2. | Joe Smith | $500.00 (check) |
| 3. | Jane Smith | $500.00 (check) |
| 4. | Tom Alvarez | $50.00 (cash) |
| Batch Total: | $1,150.00 |
If any of the contributions from this deposit batch are included in a Qualifying Request or Matching Request, batch number “2019.06.06” must be included with the contribution information. Additionally, committees must attach the batch list of all contributions that were included in this deposit batch.
If the committee accepts contributions through a credit card vendor, and funds are transferred to the committee either by a check received or electronic transfer, committees should record these contributions in numbered batches. It is recommended that a unique batch numbering sequence is used for electronic transfers to keep them separate from check/cash deposits. This will make it easier to quickly identify which types of contributions are included in each deposit.
Using the June 6, 2019 deposit example above, in addition to the individual contributions, the committee also received a check from the credit card vendor for three contributions totaling $1,500. This check can be included with the checks and cash listed above in a single batch. The deposit batch list might look like this:
Batch 2019.06.06 – Deposited June 6, 2019
| 1. | Bob Jones | $100.00 (check) |
| 2. | Joe Smith | $500.00 (check) |
| 3. | Jane Smith | $500.00 (check) |
| 4. | Tom Alvarez | $50.00 (cash) |
| 5. | Fred Lee | $500.00 (credit card) |
| 6. | Jose Rodriguez | $500.00 (credit card) |
| 7. | Alice Howard | $500.00 (credit card) |
| Batch Total: | $3,150.00 |
Statement of Participation
Prior to submitting their application, all candidates must electronically file a Statement of Participation or Non-Participation and indicate whether or not they wish to participate by checking the appropriate box. This form must be filed no later than the deadline for filing nomination papers (contact the Department of Elections to confirm the nomination deadline for the desired office). New or amended Statement of Participation forms will not be accepted after the deadline. Candidates are encouraged to file the Statement of Participation as early as possible to avoid any technical issues.
Supplier ID
To receive payments under the public financing program, all committees must be issued a supplier ID by the Controller’s Office. To receive a supplier ID, candidates must submit to the Ethics Commission a signed and dated IRS Form W-9 that contains the full name, address and EIN of the committee that will receive payments. Please note, the address provided will be used by the Controller’s Office to disburse payments. Candidates should obtain a supplier ID as soon as possible. All ID requests and IRS Form W-9s should be submitted by email to ethics.commission@sfgov.org. Please do not submit forms/requests directly to the Controller’s Office.