Table of Contents
Submitting Supporting Documentation
Candidate committees submitting contributions as part of a Qualifying or Matching Request for public funds must provide supporting documentation that demonstrates the following for each contribution included in the submission:
- The contribution was received by the committee;
- The contribution was deposited into the committee’s campaign account; and
- The contribution was received from an individual who is a San Francisco resident.
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. Candidates are encouraged to contact Commission staff with any questions about supporting documentation before submitting a Qualifying Request.
Online Records Portal
After a candidate has filed a Form 142(a) – Statement of Participation indicating an intent to participate in the Public Financing Program, Commission staff will provide the candidate’s committee with a unique records upload link. The committee will use this link to submit supporting documentation for all public financing requests. Supporting records for each request must be submitted via the online records portal no later than the end of the day on the date the request was filed.
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 any of the following to demonstrate residency:
- Contributor is currently registered to vote in San Francisco. Commission staff will automatically search the name and address of each submitted contributor in a current version of San Francisco’s Master Voter File. If a contributor is registered to vote in the City, Commission staff are often able to confirm residency without any additional supporting documentation;
- 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 (AVS) 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 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).
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.
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.
Guidance for Common Types of Contributions
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. These “vendor reports” must be sent directly to the Ethics Commission (ethics.commission@sfgov.org) by the vendor and should not be uploaded to the Records Portal. The vendor report must include the following:
- Contributor’s full name
- Amount of contribution
- Contribution processing date
- Contributor’s address
- Card type, expiration date, and last 4 digits
- Date of transfer to committee
- Transaction number
- 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 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, etc.);
- 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 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 or Matching Request, then the committee will be required to provide separate documentation to verify the contributor’s 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.
Contributions Made by Check
Receipt
To prove that a check contribution was received, provide a copy of the check as part of 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 uploaded to the Records Portal should clearly identify the submitted contributions.
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 under “Proving San Francisco Residency” above.
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.
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:
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
Limits on Accepting Cash Contributions
Cash contributions of $100 or more are prohibited under state 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).
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 “Proving San Francisco Residency.”
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, though 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 Contribution Limits and Restrictions page of the Commission’s website. Committees are encouraged to contact the Ethics Commission with questions regarding their contributor information cards.
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 or Matching Request, batch number “2019.06.06” must be included with the contribution information.
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 |
Examples
Example 1
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).