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Lobbyists on Behalf of the City Reporting Requirements

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Reporting Requirements

Lobbyists on Behalf of the City, referred to here as filers, must file a Quarterly Report of Lobbyist on Behalf of the City each quarter in which they meet the qualifying threshold.

Filers must report:

  • the total payments received from the City during the reporting period in exchange for lobbyist services;
  • a description of each local, state, regional, or national legislative or administrative action supported or opposed;
  • the names of officials contacted for each action; and
  • expenses incurred or payments made during the reporting period in connection with lobbying activities, called activity expenses.

Reporting Payments Received

Filers must report all payments received during the filing period from the City and County of San Francisco in consideration for lobbying on the City’s behalf. Reportable payments include, but are not limited to:

  • fees;
  • retainers; and
  • reimbursements.

Reporting Activity Expenses

An activity expense is any expense incurred or payment made by a filer that benefits any local, state, regional, or national official whom the filer contacted during the quarter.

Activity expenses include:

  • gifts, such as food, beverages, candy, flowers, or tickets to a ballgame;
  • compensation, such as consulting fees or salaries; and
  • other forms of economic consideration benefiting officials.
Example

On February 5, a filer pays $100 for a luncheon for ten people, or $10 per person. Luncheon attendees include two officials, Official A and Official B. On March 1, the filer contacts Official A in an effort to influence legislative or administrative action. The filer does not contact Official B during the quarter.

The activity expense would be reported as follows:

Date of ExpenseDescription of ExpenseOfficial Benefited (name, title, agency/department)Amount of Expense
Feb. 5, 2000Luncheon at Capitol GrillOfficial A, Assistant Secretary, Department of Commerce$10

The filer does not need to report the $10 expense that benefited Official B because the filer did not contact Official B during the quarter. The filer reports only the amount that benefited Official A, not the total luncheon cost.

Miscellaneous Filing Information

1. Filing deadlines

The quarterly reporting periods and deadlines are:

Reporting PeriodFiling Deadline
February 1 to April 30May 15
May 1 to July 31August 15
August 1 to October 31November 15
November 1 to January 31February 15

Electronic quarterly reports must be received by the Ethics Commission no later than 11:59 p.m. PST on the filing deadline.  Filings that are due to the Commission on a Saturday, Sunday, or City-recognized holiday but filed no later than the next business day will not be assessed late filing fees.  

2. Filing under penalty of perjury

Filers must verify, under penalty of perjury, the accuracy and completeness of the information required to be filed with the Ethics Commission.

3. Filing amended forms

If a filer submits a report to the Ethics Commission that contains an error or omission, the filer must amend the report. The Quarterly Report form includes a box that filers may use to indicate they are amending a form previously filed.

4. Review of filings by the Ethics Commission

The Ethics Commission reviews all filed forms for timeliness, completeness, and content. The Ethics Commission will ask filers to amend forms that are incomplete or lack sufficient detail.

5. Recordkeeping

Filers are encouraged to maintain a recordkeeping system to ensure the accuracy and reliability of all information connected with lobbying activities on behalf of the City.

6. Lobbyist filings are public documents

All reports filed with the Ethics Commission are public records and are available to the public for review and copying. See S.F. Admin. Code Section 67.29-4(a). Filings are posted within minutes of receipt to the Ethics Commission’s website.

Penalties for Violation of the Sunshine Ordinance

Failure to file a quarterly report with the required disclosures is a violation of the Sunshine Ordinance and may subject the filer to administrative fines, civil suit, and the payment of attorney fees if a private action is necessary to compel filing of the report.

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