words 500 or more within a 98. europe to disclose the donors that you use their phones. so there are -- the regulatory regime is different at the local level. the need quite frankly a lot of these nonprofit groups that have acts. they use the tax to disclose the donors. then as a general matter, what we say in the memo is, this is different than -- there is prof. durkin who said that came up with this idea obviously much smarter than me but -- there are certainly very smart people who disagree with us. including the number of local -- national figures who say, look, this is different than saying top donors. because top donors serve as a key for people to say, that the person. oh, you know what, maybe i like them made i dislike them. if a shortcut. saying somebody is not disclosing their donors that's a criticism i agree with

-- that's a fact but there's a direct implication in a way that donor disclosure doesn't have a map which is you're not disclosing your donors and you should be. and you're trying to get around letting us know who it is. that's a negative statement which quite frankly is not clear that the government should be having somebody say by implication. so, to me it's a couple things. one, it's a need for it in terms of the law a need for it in terms of the fact and whether it's actually wise policy. so that's what we put >> let me ask you a practical question and i'm looking again in example 3 from --. if my top two major funding donors are anonymous, which would put there right now? under the proposal >> this wouldn't apply if they were anonymous >> so that life would be like? this would be a four line disclosure or five line disclosure? >> it wouldn't be any

disclosure. >> there would be anything? >> yes >> i get this to the first point that -- made. this paul's policy from purpose of prof. durkin and others it's much more applicable to federal elections not local elections in california. local elections in california major donor for the purpose of this threshold $20,000 threshold will not remain anonymous. >> so you are saying you could not -- every disclosure is going to disclose their major top two major donors by law recently? >> yes. if they're an independent expenditure [inaudible] >> where is the hondo just adding the term anonymous? you given a good all-encompassing argument saying we've got it covered. it's taken care of. why do we put in specifically the word, anonymous.? i don't see how that in any way isn't a

problem? you haven't told us that adding of that term is really a problem. unless i missed something. >> i think he is saying and >> i may be mistaken >> i may be too. >> i'm not the brightest -- >> i'm struggling myself. i think what he is saying you could never in the situation within ie have major funding by an anonymous donor donor because you have to include the names of the top donors. >> right good soda spots to commissioner kean's question, this is certainly technical stuff. i think jesse's greatest of, but certainly beyond -- circumstances. >> [inaudible] >> yes. theoretically you can ever provision in here that dealt with anonymous donors and

those anonymous donors were major funders which obviously people really want to know about. but the problem is, as people to exist and to be subject to disclaimer requirement they would've needed to already violated state law. so we would have a provision that is hearsay, look, if you already violated a state law that you need to disclose than requiring to put the disclosure statement on here. i guess jewish >> what we lose by that? >> you could do that but that's the situation. >> we obviously have a concern on the part of our citizenry about civil grand jury in regard to it. if we concede we don't lose anything let's put it in. >> i think if a civil grand jury is requesting a little bit different. i think they are saying anytime there's an anonymous donor that paid for any portion of the hangar, for example. not necessarily one of the top donors, then you put on this statement that it was paid

for and funded by an anonymous donors. so, it wouldn't be the top -- to them i say now? it would necessarily say the top two but anyone with anonymous then you would add a line here that says, basically some of the donors from this were anonymous. do i have that? >> autism was really -- >> the 503 sixes and so forth. with the committee for justice or whenever and we don't disclose on that >> so i mean this committee's name you would see and maybe they're generating to another committee but what's behind that you just don't know. maybe you find out later. >> okay but you heard mr. shannon say the situation in which the top two donors are anonymous for an ie could never happen because lbm mission

validation violation of state law. >> people have gotten very creative and when you start changing a lot of entities together chaining a lot of vanities together the money slide one to the other it can take a year two or three to unravel all that. the ads are running in real time. >> what i'm hearing -- -- >> at the federal level at the rack last cycle they really contributed to just an awful environment for people turning on their tv sets and listening to this kind of trash all the time. at some level you want to say, let's get that this course under control and little bit and get it back to some civilized discourse. when with anonymous feeling there's really no checks and balances

>> thank you. okay. were back on the anonymous? >> i'm thinking are from a different angle. it feels that were encouraging -- we are creating a provision for them in some kind of way. i just don't understand why we would? -- >> eucharist when this better price than others. >> [inaudible] >> could try to cut to the quick. there is no way in san francisco were in california that anonymous people will be funding [inaudible] expenditure that all those forms we talked about in provision .2, [inaudible] expenditure that all those forms we talked about in provision .2, within 2424 hrs. of the miller being mailed, and be able to go on that website and see every

contribution of $100 or more that was used to fund that mail appeared within 24 hours. so, to mr. commissioner kean's point to what the downside, the downside is not true it's inaccurate. it would make a mailer seem as if some anonymous people are funding that [inaudible] records in the possession which disclose every donor who's contributed. >> anonymous people could be funding it they did not meet the threshold. >> the threshold for anonymous donations, i think it's 25 or $99 >> certainly, there's an agreement saying were going to -- it's one dollar. if there is an agreement, under california state law that you have to disclose those donors any iffy samba radio check and use it for , curator trade association i want to send out a mail piece. as soon as i write that check and there's an agreement,

that's disposable at that moment. what's not disposable -- well, the threshold of $50,000 threshold a year is if there's a nonprofit that is sitting there that decides the bid adieu and ie and basically have a store of money and they're not taking it from anyone but the cumulative funds over the course of the year. they decide we are going to weigh in to send a mailer out. so, they can send a mailer out they have to disclose that they sent it out that they spent money on it and there's a $50,000 threshold at that point. after they meet $50,000, they have to go to some accounting to kind of figure out how they're going to attribute it to all these various funders they've had over the course of the last four years. but, -- so i can say not right. >> yes. but you know, the example which jonathan referred to, the -- change was a very

unique example which in the 14 year seven practicing political law was the first time someone really try to run the money through three different nonprofits and other large sum of money in to a campaign and you sell it happen. it basically cratered the opposition campaign. it was exposed within a matter of two weeks and a logout change to make sure never got happened again. i hope that was helpful. >> was that incident? >> it was with the gov. brown's proposition 30 campaign. i don't know the nonprofit. it was basically some nonprofit in virginia that funded a nonprofit in arizona which funded a political committee and then gave the political committee gave the money to an anti-opposition 30 committee. as a one through four states in four different nonprofits without disclosing the true source of where the money came

from. and it was litigated. it was dealt with at this green court of california before the election. within two weeks of the story breaking the supreme court dealt with it. it's a very serious issue. but i think our rules covered it. >> to what thank you >> okay, two other questions unrelated. so, we are also admitting the total cost of the mailing >> that's right for a mailer that's correct. >> why is that, just for because it's too much to put on a mailer? >> well, first of all because there's a distinct rule just for mailer so what were trying to do is streamline it and make

it a set of role for our alternate occasions. secondly, it's a question if particularly for referencing the ethics commission website will have a lot of not only just a campaign information but just the graphics. you know, we staff and in my experience have not found a lot of value in knowing how much the cost of that single mailer is. the value is knowing how much as a general matter a particular entity is spending. as opposed to on the one mailer that you get that's the pile like that. so, in the interest of making a standardized disclaimer, we said would just take out that is was the whole notice to voters. requirements. >> am i correct that, what you're doing oh, in terms of the type font, you're making the state requirement to be consistent whether san

francisco requirement to be consistent with the state? >> we are actually for members and for like small fires that sort of thing. were actually augmenting it a little bit because on the -- at the state level as 10 point font which is pretty -- is what it is. not that big. right now, for miller's ours is fort wayne 14 point font and you can see in exhibit it ends up taking a pretty substantial part of a mailer was sometimes quite small >> what is the state requirement for a mailer? >> 10 point font. >> i guess the question is we get all these things are coming on 14 point, why is that so significant? when we standardize it so that people know the state requirement they know the city requirement and we not have always coming in?

i should say not less than because clearly if they came in at 16 point you would in charge any violation. so it's not a mandatory font size. it's a minimum font size. it just seems to me just have one and let it go at that. >> certainly at the discretion of the commission >> i stop mr. bush is in my head but we dealt with this fort wayne point font issue and there seem to be a lot of concerns that tenant was too small and we went to 14 just to make sure that the people could see it. i'm not against going to 12. i think it's readable. i understand the concern that we have a lot of information on these mailers. but i'm a little concerned about going down to 10. >> any other comments or

questions than? on provision .3? >> i feel like i'm torturing everybody. >> no, this is very good. you did a fine job. >> is there a motion to adopt provision .3 or do we feel we need to do for this one? >> i will move it >> is there a second? >> second >> all in favor say aye. opposed. hearing on the motion passes five 5-0. thanks again to the public for your input was larry helpful as you could tell we could use some of the help he would.. excuse me provision .4.

>> position make for we cover the whole thing. i tried to these competence of as possible but there are little things like we moved one definition to a different section and this is just to say, okay, all these minor little technical things were approved as well. >> public comment? i'm going to take this as an opportunity to comment on provision .2. because this covers all the points. i did not discuss the vendor payment issue. i'm sorry that the vendor payment disclosure was going to be removed because knowing who the vendors are tells you about the relationship between a candidate were a committee and various community groups. so, let's say somebody wanted to pay friends the committee of ethics $100,000 through a mailer for them. there would no longer be disclosed not under this provision that says vendor disclosures will not be paid.

not be disclosed. so we strongly believe that vendors should not be removed from the law. >> perhaps we could add that to our augmented discussion for ? >> it's okay with me. >> to me, it's fine to adopt provision .4. i just ask that you be clear with us about what else, if anything, there was an identified. i understand it's a process that you later discovered by the let us know what is so that we are apprised. because what you're saying is there are things that you missed that are minor, mood, no matter unclear what you mean by persian board for. >> is just other very minor -- i might not have said, for

example, that we define district it in distribution to mean the day that the communication is viewed to read or heard which is like mentioned in the attachment but it's not any actual memo itself. so, things that are very sort of small but -- like we've done before >> yes >> this summarizes minor technical changes already presented to you. it's a classic labeling technique [inaudible] >> okay. is there a motion to adopt provision .4? >> so moved >> all in favor i'm not. opposed. hearing on it passes 5-0. commissioners, junior break? were going to adjourn for 5 min. [gavel]

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>> budget that we cut anything this coming year over the current year. there's a 1% contingency for the current year. in looking at what we are planning for staff in the long-term we determined that we want to enhance some of the responsibilities in campaign finance staff, given that a lot of our new electronic filing stuff, we have more data as the

three more sophisticated. we anticipate will continue to do so. so, we want to through changing some responsibilities with the lobbyist ordinance the campaign consultant ordinance responsibility summit enforcement staff to the campaign finance staff, were going to increase the level of as i said responsibility and with existing staff will see about getting some training and education to help them move up. when we hire new staff were going to alter the real comments of those positions so the more sophisticated to meet some of the needs that we expect in the future as we try to do more. additionally, we request would fund the bacon investigator position and we are hoping to get to new auditors. we do a certain amount of random audits every year and we [inaudible] public