hear or see any dishelicopter behavior boy an employee please report it to say whistle blower program more information and the whistle blower protections please seek >> chair chiu: since our last meeting in february, commissioner kopp resigned. lifelong public servant, i wish to thank him for his dedication and service to the city and people of san francisco. also for his service and contribution here on the ethics commission. second is hous housekeeping mat.

i like to note the change and date for the regularly scheduled meeting of the ethics commission next month. we usually meet on third friday. that is start of passover and good friday. we moved the meeting to april 12th. we'll be starting early in this room. we invite the public to come and make any comments that they wish to make. >> thank you commissioners. i'm a government social worker for the last 10 years. our union has more than 16,000 government employees. we are 52% of the workforce for public servant. i have been coming here almost

every month. i'm also director of public relations for the california association, san francisco chapter. as a public employee, i'm trained and practice good government practices. i'm here today as a resident of san francisco for the last 33 years. i have been coming to the ethics commission many times in 2016, 2017, 2018. in april, 2017 to april 7, 2017, i still remember, i brought up a lot of bribery and corruption cases. today i'm here ask you again to stop government corruptions. ethics commission department was set up to stop corruptions. the last time i was here, last. , february 5th. i reported to you that possible abuse of powers within some of

the elected offices who support criminal behaviors. such as sanctuary city and allowing recreational cannabis to drug people first and then tell people to go rehab. it is government waste and abuse. it has no form of government in san francisco. san francisco have been paid, bought, controlled by super pac action committee. we the public employees, residents and visitors have been suffering from election fraud. super pacs, illegal drugs, crimes and public abuse. people are dying on the streets. i was one of the eight candidates to run for mayor for the june 5, 2018 election.

i was not allowed to more than 20 male candidates to debate in public places such as city hall with public buildings, public libraries and parks. i found those gait debates that organized by the democratic parties and democratic related agents. it has been running by one party, democratic party. all democrats only nothing, no republican no libertarian and no independent and none partisan party. i'm here today to ask you to interpret, the law and follow the law. >> chair chiu: thank you. any other public comment. agenda item three.

>> good afternoon commission. i lived in san francisco 67 years. unfortunately, i have to be here today. due to the absence of larry bush, quentin kopp and peter king and it's necessary for me to come back to city hall. certain things need to be put on the record so later on there will be no reason why nobody knew what was going on to happen. that's the reason it's on the record. let's be honest. certain factions allow the local people to try to do what they wish.

obviously, when the locals can't get the job done and literally throw in the towel, then others have to step in. people like me have other duties mainly outside the united states but unfortunately, we have to help our hometown when necessary. the same example is it took a long time but eventually, al capone found his rightful home. if you can't get him in the front door, we will come through the backdoor and it looks like san francisco has to be treated like other cities like new york, chicago, new orleans. it may seem to local press that

the government is untouchable? unfortunately, in history, there used to be the untouchable. let's put it this way. when the locals can't get the job done, then people will step in, people will observe from far away and eventually somebody is going to make the decision to allow others to clean up the city. there's only so much that can be allowed to happen. maybe somebody from the national security administration, will give us permission to do what needs to be and they will no

longer laugh at us and make fun of people like me. thank you. >> chair chiu: chalk. any other public comment? agenda item 3, draft minutes of the ethics commission february 15, 2019 regular meeting. public comment on this item? i move to approve these minutes. second from commissioner smith. all in favor. aye. minutes are approved unanimously. item 4, informational presentation on report required by s.f.c. and government code section 1.156 on public financing in the 2018 election. >> thank you chair chiu. i'm pat ford senior policy

analyst. you want top introduce brian cox. lee ann -- leann will give you a full intro. i wanted to let you know who he was. >> chair chiu: welcome. >> talk about this agenda item. the report which i just handed to you in which is available on the table, public table for review is a report that the ethics commission must deliver to the board of supervisors and to the mayor after any election in which the city's public financing program is used. as you remember last year in 2018, we an election in june and in november and in both elections, there were races in which public financing was distributed to candidates. in june, there was a special election to fill the vacancy following the death of mayor ed lee and also to fill the vacancy in the district eight supervisor seat after scott weiner was

elected to state office. those occurred in june, candidates sought and received public financing in both races. in november, regularly scheduled election happened in which all of the even numbered supervisorial seats were up. certain candidates received public financing. ceqa requires that we report on how the public financing was used. we sought to include other information that we thought would give folks the mayor, board of supervisors, also anyone else reading this report, would give them an idea of kind of the bird's eye view what happened with distribution of funds. to be clear, this report is not part of the commission ongoing review of the public financing program. this is separate item. this is really meant to describe

or just provide numbers and information. it's not really meant to analyze a program or to make recommendations. we're doing that through the separate review process. you wanted to tee this up. that's what this is. i know you haven't had time to look at this, what aisl i'll doy is quickly go through the tables. we tried to represent the data in text but also in tables and charts. brian is going to go through the report and he'll go up on the screen. you can also follow along if you have a hard copy. in the report, we give overview how the program is set up. what it takes to qualify and what kind of funding candidates get under the program and then we also talk about how the program is funded through the election campaign fund.

first we addressed june and then secondly november. first table gives you an idea how many candidates ran in these two races. how many mayoral candidates there were and how many supervisorial. there were 11 candidates, 6 applied for public financing and 5 were certified and received funds under the program. next we talked about the public funds that the candidates got through the program. for here, you can see this is the mayoral race. you can see the candidates that ran three candidates that got public financing, how much they got under the program is in the first program. you can see that two of the candidates got the maximum

amount of funds. that's $975,000. in total there was about $2.6 million distributed to mayoral candidate. we showed for all of the candidates in the race, the level of contributions that they received. that's from private contributors, more than $500 a piece. adding together public funds for those candidates that received public funds to the private contributions received that gives you the candidate's total funds. you can see that the mayoral candidates together had about $5.8 million in funds when you combine contributions and public financing. for the public finance candidates, we gave percentage of looking at all of their funds. what percentage of their funds were made up of public funds they received through the program. it's hovering around 50% roughly for those candidates. lastly, we gave the number for

at the timthe expenditures the s gave. the data within this report reflects 460s that the candidates filed. the 460 data runs through end of the calendar year. for the june election, it's probably all these candidates will report. it's possible that for november, they may file 460 for the first half of 2019, could report some more activity. this report will most likely be everything, all the activity for these candidates. there could be another report in the future. moving on from the basic numbers about the candidate's funds for the mayoral race, here's for the district 8 race. this is the same information provided for these three candidates. you can see that two of the three received public financing. both of those candidates

received the maximum amount of funds available under the program. that's different for the two because one was an incumbent and get $152,500. he was able to get little bit more. those candidates contributions, they are felt funds when you add contributions and public financing. their public financings made up just under 50% of their total funds. you can see how much those candidates spent during the campaign. we additionally wanted to provide some information about spending limits. candidates have to agree to abide by spending limit in order to participate in the program. this is special condition for receiving public funds. however, the spending limit is adjustable. it will be changed if certain

events occurred. that is contributions received by an opponent in the race or spending by third parties. either to support the candidate's opponent or to attack that candidate. you add them together, if that exceeds the candidate spending limit, the commission must adjust that candidate spending upwards. we wanted to give some statistics about spending limits before they started where they were razeed to and etcetera -- raised to etcetera. that's an important part of the program. in the top table, you can see the three publicly financed mayoral candidates when they began to experience increases to their spending limits and how many spending limit increases they had. there were a total of 30 increases you can see which candidates received them. you can see the highest level to can the candidate's spending limits were raised.

then at the time they experienced final spending limit increase, that last column shows you the level of funds that the candidate had at that time. you can kind of compare where they were in terms of their funds versus what they were allowed to spend. the same information is provided for the district 8 race. it's not too dissimilar. it's pretty much the statement pattern. there are multiple increases, the candidates get up to much larger number than where they started and the level of spending limit is little bit above the amount of funds that they had had. lastly for the june election, we gave some information about third party spending. this is, of course, spending by groups other than the candidates own committee. this can be to support a candidate or oppose a candidate. it could be an independent

expenditure where the communication is expressly advocating for or against a candidate. it could be a member communication where it's expressly advocating but only to a particular subset of people. like members of a political association or a union. it can be an election communication. essentially, saying something about the candidate. we assign whether or not it's positive or negative and we count that for purposes of spending limit adjustment. all of those are together here. >> chair chiu: can you refresh my recollection the timing on the filing requirement the for the third party spending. from the time that the money is spent, what the requirement for the filing? >> you're within the 90 days

before the election. it's called the late reporting period. within that period, you have to report within 24 hours of the distribution of the communication. it's a pretty quick turn around. additionally, these committees that are making these expenditures, they may also have to file as a committee and then this will be filing a 460. we'll be getting a full picture of that committee activity. as you seen through tyler field's presentation about dashboards, we pulled together all of those. this data will reflect any activity whether it of koss through the 460 or it comes through these more limited in scope, 24-hour reports. this data is comprehensive of that. >> chair chiu: thank you. this tabl >> this table is separated by two seats. first we listed the third party

spending in support of those candidates. you can see there's about $2.1 million in support of spending. right around $2 million, third party spending in support of a candidate. opposition spending was less. it's about just under $400,000. then adding that all together for the two races, there was about $2.5 million of third party spending. we also broke this down visually. we included a pie chart here that shows you supportive versus in opposition spending. the vast majorities of third party accidenteddin -- spendingt rather than oppose. lot of the discussion about independent expenditures, revolves around whether or not they support or attack. there's a lot of criticism of negative third party spending.

third party spending can also be a way to support a candidate without giving to their campaign. we think it's relevant. we parsed them out separately here in this chart. i will quickly go through november but the format and type of information provided here is the same. it's little bit different because we only had supervisorial districts. we would list them here. there were five seats in the midterm election. we list the candidates, how many candidates appeared. in total there were 22 candidates. most of those candidates, 9 received public financing in the program. we provided the same kind of data for the candidates that received public funds. we show how much they received

and for all candidates, level of contributions, their total funds, how much of their funds represented by public funds and then their total expenditures. we proud five different tables - we provided five different tables here one for each race. we provided the same kind of information as in june about spending limits. this shows all of the candidates publicly financed because only publicly financed candidates has spending limits. other candidates don't. this is all of the publicly financed candidates shows you when they begin to experience spending limit adjustments, how many adjustments they had in

total, there were 122 adjustments. i think there are 43 in june. that makes 165 total spending limit adjustments last year. you see what their highest spending limits were. how high they got. i should have said this, it starts at $250,000 for supervisorial candidates. you can see the funding that each had at the time. but their spending limit was raised for the last time. we provided a chart for this information too. we provided contrast between their final spending limit adjustment and the level of funds that they had. it's little bit easier to compare rather than looking at the numbers. you can look at the chart. we thought this was important to parse out because it kind of

demonstrates where the candidates were in terms of the funds that he had to run their campaign. that's shown in orange. that's the candidate's total funds. in gray, what they are spending limit was. you can think of spending limit as a proxy for what the candidate is up against. it represents the fundraising of the candidates highest funded opponent, independent spending in support of that opponent as well as third party spending in opposition to the candidate. add all three together that's what the gray bar is. you can see for some candidates they're pretty close. for other candidates they're far away. we thought that was relevant and interesting look to parse out. we also provided information about third party spending for the supervisorial ideas. broken down by supportive opposition and then total third party spending.

looks there was about $2.1 million of third party spending in november election. at least for these particular races. we're only addressing races that are eligible for public financing. we broke this information down into this chart. this shows you how much third party spending was done for each separate candidate. how much of that spending was in support of the candidate versus in opposition. as in june, the same was true in november that the vast majority of spending was done in support of a candidate. you can see there's a pretty big disparity between the third party spending done in regards to the different candidates. there's quite a bit. some had very little or none. this pie chart just breaks down

how much support versus opposition spending there was. we concluded the report with an overview of the commission's review of the public financing program. we talked about phase one where we looked more procedural or administrative side. tried to identify places where the program was creating burden on candidat candidates. we tried to identify those as we ways we could increase participation and increase impacts. you approved an ordinance that is pending at the board of supervisors. we talk about that. i think this will be helpful for folks on the board who maybe considering this to see the context and seeing how the program is administers and this review is part of the commission's overall administration of that program. secondly, we talk about the

ongoing phase, phase 2. we're looking at the most fundamental aspects of the programming like how much funds can get under the program, what it takes to qualify, what the matching ratio is, when the candidates received the funds, etcetera. i can give you little bit more details on what we've done since last meeting. this just gives little overview to the board and the mayor about that project. i'll be glad to any questions you have. i know this is dropped on you now. lot of information to process. you can reach out any time in the future if you wanted to discuss any of it. also just i wanted to highlight this was a real offic office-wie effort. brian worked closely with me on it and our audits division

provided lot of this data. it's a real collaborative effort. this will be on our website as well. for folks watching at home, you can access it online. >> chair chiu: thank you this is a lot of information and thank you pat and brian and amy and everyone else in the office who put in the work to pull this report together. it's a lot of information to take in. open it up to my fellow commissioners if you have questions? anythincommissioner lee.

>> commissioner lee: i have quick question, it's nice to hear opposition funding is really a very small amount compared to what public perception is in in the city, -- do you think that has some impact over the amount of opposition funding compared to other cities? is that a factor? >> i'm not sure. i would have to really dig into that and compare. i know that that's certainly one of the stated purposes of choice voting. it's intended to encourage coalition building rather than just one on one trading punches between candidates. i would like to think this is a feature of rain choice voting. i was surprised by the ratio of support to oppositional. you usually hear about attacks. it's things that the candidates

does not want to do or say. they rely on the independent spending to do that. that was not the typical model in last year's elections. >> commissioner lee: i thought you had extra support. i would love to see data to show if there's any correlation between one choice and one voting versus the opposition funding. that will be policy discussion to have. that will be policy discussio >> chair chiu: i have a question, the 2018 election was unusual. we mayoral election in june and november. sorry in june. the amount of public funds spent in the mayoral was was almost

$3 million. the board of supervisors was someone else $.2 million. i have to look at my numbers again. the overall fund is about $7 million. is that right for public financing? >> the fund has an annual appropriation that's on a resident basis. it comes out to about $2.3 million per year. it's $2.50 per resident. on top of that, there are certain mechanisms in the balance is not enough, it can be brought up to that level. i think $7 million is in the ballpark when you have a special mayoral election, there needs to be that much in the fund thinking being that's how much it takes to assure sufficient balance to provide enough candidates enough support to run viable campaigns. it's not necessarily the case

that there's $7 million at all times. >> chair chiu: i would u would be curious to know what the trend has been in terms of the amount of funds that were used to support public financing. in the corporate world, if you didn't use it, you would lose it. i would hate for that to happen here in the ethics commission context. what can we do in order to make people more aware of the public financing program and to encourage greater or broad participation to allow candidates to make use of these funds. i know this is getting into policy discussions and another agenda item. that will be at a focus of an interest of mine. >> great.

>> commissioner lee: [indisc erni ble] >> i don't know specifically how they get that number. that's something that we have to rely on them for. they are the ones that -- they handle the appropriation. >> chair chiu: was this report submitted to the mayor and board of supervisors? >> no, we'll submit it on monday. >> chair chiu: any other questions for mr. ford or mr. cox. >> commissioner lee: if i can follow up on the census number. if the calculations based on the census number is the next cens census, we'll lose actual number of residents because of certain questions being asked and citizenship question, that may scare off some of the san francisco residents from participating. that would drop off the public

finance funding. the number of san francisco residents based on the census, would have been reduced. right? if the federal government were able to ask the citizenship question, scaring off -- not scaring off but discouraging a sizeable number of san francisco residents from participating in that the census, then the public financing pot would have been reduced based on the new census numbers.

>> if it is the case but the comptroller relies on census information, then any drop would have that impact on fundings of the program. i'm not certain that's what they do. i don't know. they may relying on city data. they may have other sources of data that other city departments keep about how many people live in the city. i'm glad to do that as part of the phase 2. >> commissioner lee: i would like to know. >> we'll look in greater depth, election campaign fund and how it's funded to get it exactly who you were talking about. what is the capacity of this fund? what can it fund and what happen arwhat are wecurrently using ans ram for growth without greater appropriation.

i think that's part of that discussion. we can talk with the comptroller office to learn how they determine that residency number when they make the appropriations, how they do the math. it's definitely a great interest to us. >> chair chiu: a point of information for this most recent years estimate -- >> comptroller used most recent census bureau population estimate that was available as of july 1, 2016. they did have some information. ly to pat pointing we can do that research. >> chair chiu: thank you. any other questions from the commissioners? any public comment? no public comment.

general item 5, discussion of the monthly staff policy report. >> thanks commissioners. item 5 is the monthly policy report. i think the main item i wanted to highlight for you as you mentioned was that, we've been working on the second phase of the review, public financing program. we had two interested persons meetings at 25 van ness. first one was on monday last week and second was on friday last week. we heard from folks who have been active in the first phase of the review and it was great to hear their thoughts on more of the second phase things. what do they think about candidate qualification requirements, what do they think about the funding the candidates able to get. is it enough? what are the features of the program they like to see the commission look at?

it's very helpful to hear them talk about that. it's helping us to scope this phase and look at specifically we want to dig into and get data about and following those meetings, we've been working with the electronic disclosure data analysis team, especially in the data analysis side to dig into that data and see what kind of experiments we can run. what does that mean for viable campaign. what do successful candidates have to do. at this point, we're shooting to bring our findings and preliminary relate recommendatio you at the next meeting. this will be kind of similar process to in phase one, in october of last year, we brought

a report that detailed our process of how we reviewed those more procedural or administrative aspects of the program and gave you staff's recommendations about how to change those in order to boost participation and increase the impact that the program has for those candidates. likewide, next month, we like to bring similar scope to you that would detail our review process, how we look to the data and how we talk to candidates what the stakeholders communicated to us and basedden that, give you a list of recommendations. those may bear on things like the matching ratio or the amount of funds candidates can receive or the maximum amount of a contribution that can be matched. right now the full $500 can be

matched. things like that is what we would recommend.

it would go through and fix places where the regs are not in line with the code. we wanted to rectify those places. also just respond to areas where we've been getting lot of questions that need some clarification in the law. it's kind of omnibus overall improvement project that i've been wanting to bring to you for quite some time and had not had the capacity to get if before you. now we have mr. cox on staff, he's really doing lot of already on the public financing review project. i think that will free me up more to bring you these regulations. that's my goal to bring those to action items to you next month.

then thirdly, i wanted to point out with the online political communications i'm trying to have our deliverable on that done which is -- i would like to provide a better way for people to see political ads on the internet to find information from us. one was panels was about political ads on the internet. ethics commission need to have really good, forward or public of facing interphases for folks to access who don't understand ethics laws who don't understand campaign finance when they see

something on twitter feed or facebook. they can navigate to our website and they can find information. what is this? what does this disclaimer mean? we're seeking to have -- if our current communications aren't achieving this to improve that, people can come to our website, they can basically get an idea whether or not to have a disclaimer, if it does have a disclaimer, how do they use that information to find out who paid for that ad. those the two main things people ask us about. seeking to give people, easier access information about that. it would do a lot to make some progress in this arena. >> chair chiu: if we can go back to the public financing fees. is there an update on whether or

not supervisor mar introduced the ordinance that the commission approved last month? you said you were going to introduce it at the march 12th? >> he did. it was introduced. >> chair chiu: to the full board? >> yes. at this point it has to go through the process going through committee. usually at it point it comes to commission. but the commission already approved it. andrew can comment on the city hall side mechanics. it's just kind of going through the board side process. it will go to committee and then hopefully with positive recommendation it will go to the full board. >> chair chiu: it will be great to give us update on that next meeting. >> you i'll be glad to. other than the commissions identified policy projects i included updates here about

other things that we're tracking. one of the initiative also responserresponsored by supervi. it's dark money initiative. it provided quick break down what's contained in nap those are things that will impact our operation if they become law. some of these things already approved by the commission. some of the thingsing that have never been before the commission before. i wanted to make sure you saw that and knew what was in this initiative ordinance. >> commissioner lee: i'm interested in that initiative. i know you said that the staff is reviewing the implications of the changes to city law,

etcetera. it you will be submitting written comment for the hearing, the board's hearing. would the commission have an opportunity to submit -- [indiscernible] prior to that to be included in the staff? >> yes, more than happy to work with you or any of the commissioners to make sure that your concerns and questions are incorporated into that. what's challenging about this process, we don't know when it will happen. it's kind of hard. it's something i will move expeditiously on. i can be in touch with you to talk about this. >> commissioner lee: thank you.

>> because this is a ballot measure, there were restriction option the role of the commission can take and commenting. i'm sure the staff is aware. i'm presuming that you work with the city attorney's office to make sure they are specific and not policy oriented. >> you wanted top respond judge smith question. there will be at least one required hearing before the november election. you don't have to wait for the hearing to be scheduled or agendized before you prepare your comments. i don't see any reason why we go ahead sooner than that. that could be sent to the sponsors at any point. subject to the rules that commissioner ambrose just

mentioned. >> chair chiu: i like to discuss some of my concerns that i have and questions that i have on this. >> assure, i'l -- sure, i'll reh out and we can figure it out. another thing i wanted to highlight here is that the statute that was enacted last year that created disclosure requirements for certain trustee election is now in effect. this is something that our office is now working to implement. this creates disclosure requirements now for individuals running for the retirement board, health service board and the retiree healthcare trust fund board. previously those candidaters were outside the scope of the political pac. they didn't have to form committees, not file

disclosures. that is now different. if you spend money to influence the outcome of such an election, you have to disclose that expenditure. this is done or was done outside of the scope of our code. these are not candidates within cfro. light of the requirements are similar. we work with the sponsors, supervisor cohen to get these requirements to align as much as possible so the candidates wouldn't have to learn a different set of rules and be subject to different laws. there are still some differences. we will be creating materials and conducting training that are specific to these candidates. that's something that our office is actively working on now. another project is kind of in the pipeline that will hopefully be before you some time soon,

within this year, is a move towards efiling for all filers. right now only elected, appointed, officials and department heads file their forms 700 electronically. meaning actually through an online interphase. lot people file them electronically meaning on a pdf. that's not true electronic filing. you're using a hard copy. we're moving out to have all filers file electronically. i look forward to sharing those with you. you wanted to know, this is something we're working on. kind of scoping out what that project would look like. >> for the efiling for all, would that require meet and confirm with bargaining units? >> it will require meet age

discuss. -- and discuss. >> great. >> i think those are the main highlights i wanted to share with you today. i'll be glad to answer any question us might have. >> you have your final item here on the acao implementation. i'm assuming that the forms that you've been working on up and ready to go for the november election? >> yes. those will be ready to go. we're also working on getting these provisions into the candidate guides and any other written materials so that it's all out there >> chair chiu: any other questions for mr. ford? public comment?

agenda item 6 discussion of monthly staff enforcement report including an update on various programmatic and operational highlights of the enforcement program activities. >> i like to highlight the training that we held last thursday the public library in the court auditorium. we had 40 city officers and employees from various departments. mostly from the larger agencies across the city attend training that we hosted in which our counterparts from the state labor commissioner's office came to present on legal issues and investigative methods in the context of whistleblower protection. we had a legal counsel and an

investigator who call deputy labor commissioner. state labor commissioner office entity within the california department than receives and investigate complaints of retaliation from across the employment context within the state of california both public sector and private sector. they enforce various provisions of the labor code. some of which overlap with the whistleblower protection that city office and city employees enjoy here in san francisco. that training gave the enforcement division an opportunity to highlight four h.r. professionals across the city. some of the amendments that you sent to the board of supervisors a year ago in which became law on january 20th of this year, the bulk of that training

consisted of our counterparts from the state describing to participants the statutory framework for their retaliation. some of the legal issueses that affect that work like what whaa prima fascia case looks like. what protected activities constitutes the state level. they described in some detail how they make a showing of causation between protected activity and the employment action. they also present on best practices how to go about investigating retaliation.

we folks from the whistleblower program from the city attorney public integrity unit, like i mentioned h.r. staff and department of public health, public works, port, rec and park. our staff, the enforcement division will seek opportunities to implement in our own retaliation context. some insight includes looking for opportunities where it might be possible for city of san francisco to assert more expansive view of jurisdiction over whistleblower retaliation. what we saw was that, at the state level in the osha context, the state entertained claims of what is called anticipatory

retaliation. where employer takes adverse employment action against an employee who has not yet engaged in protected activity and historically the city reviewed protected activity as a jurisdictional prerequisite. if the retaliation happens before the protective activity, the state entertained claims of that nature, federal government has entertained claims of associational retaliation such that the adverse employment action is taken not against the individual who engaged in protected activity but in a family member of that individual or a close associate of that individual.

i would point you also in our report to the monthly review of the matter before the bureau delinquent revenue. there's not much movement. in the case of gwinnett suite, city of san francisco is eagerly waiting in line as these bankruptcy proceedings unfold. like i mentioned at the february meeting, the commission is preparing a number of potential referrals of additional delinquent filers to the bureau of delinquent revenue. currently working directly with filers who have outstanding late fees. if the threat of referral is not

enough, sub convenien subsequeng you're likely to see longer list. i'll turn to the enforcement statistics that we report to you every month. you'll see that the number of complaints in the preliminary review has come down in march of this year. we have now 82 whereas a month ago we had 9. that occurs despite having received 70 new complaints in the last month. because investigators managed to dismiss 15. we had fewer matters under investigation from 90 down to 84. while it's true that the amount of time that it takes us to conduct that preliminary review has gone up by a notch in the last month what you see is that

hopefully, the amount of time that take us to get through investigations is leveling off around 15 months and with added diligence and some reforms to process, we'll see those numbers come back down. >> i'm curious, if you have any insight into the increase from march? lyme i'increase from march 20185 to year later to 91. was that increase of 46 due to increase number of matters that come in after the election? >> that would be my guess. we did see -- i don't have the statistics. these statistics reflect specifically the number of complaints for which staff has yet to conduct preliminary review as opposed to the number of complaints that walk through the door in a given month. it's true that in 2018, we had

elections in both june and november in 2017 there were no elections. the number that you see in march of 2018, 45 complaints not yet reviewed is a reflection of potentially complaints that the commission had received going back to 2017. we had in overall, in 2016, the commission received fewer than 10100 complaints. in 2017 commission received just over 100 complaints. in 2018 the commission received 160 complaints. so 60% increase that we stacoming throug-- wesaw coming. >> are you currently fully