analyst has a report that seems to conflict with what mr. ford just tells us about how many contributions it's going to take. we need to get a reconciliation to find out whose numbers are right, what the bla said was they compared the current program that we're putting forward and what would be the impact on a $500 donation and a $200 donation. we're all trying to empower small donors for sure. that's a good goal. we also are trying to make sure

that candidates aren't doing dialing for dollars because they need so many more contributions they spend all their time fundraising. nobody wants that, i presume. what they found was the number of donations between a $500 donation if that was matchable and $200 would go up from the current 200 donations you need. that is an increase in the donations candidates would need. if we had a $200 matchable level, if you go down to $150 or $100, candidates are going to need more contributions to meet the amount of public financing. we have to find the balance here. if we had a contribution amount of $166.66, that would be the exact amount you would need, the same amount as with a $500 donation in terms of how much

they would be worth. i'm about out of time and i haven't gotten through most of my points, so i'm just trying to say that we have to find the balance here. i think on this one, i would like to see us lean more towards 200, if we can. 150 is better than 100. 165 would be closer to the amount where the -- where the amount at 166.66 becomes equal to a $500 donation. >> thank you. >> why don't we go through public comment, and please hold additional questions for a particular commenter until the e end of public comment. >> fair enough. >> thank you for your time. >> good day, commissioners, thank you for entertaining all this and for your dedication to

changing democracy. so common cause, i'm helen. i'm the northern california organizer. i sent an e-mail to all of you this morning, and i just wanted to reiterate a few points. first of all, common cause has been supporting public financing since our inception. it's one of the founding principles of why we considered this cause in 1970. we did work to help institute the san francisco public financing system and we're here again today to be a voice of reason, we hope. so of the proposed changes, we support the maximum amount of public financing a candidate can receive -- this is in your e-mail. i won't go through all the details. the spending amounts, the match of the public fund system from 6:1 and the initial grant to be raised as well. as we've been speaking here today, there are two points that have -- do not have disagreements, and we would like to leave this to the wisdom of the commissioners for you to

sort this out with your staff and public comment, but i will make these two points. philosophically, small donors is the foundation of why we even want a public financing system. so erring on the side of smaller contributions has been philosophically the point of the system. emily's list -- and i come from the feminist movement myself -- it does help money rise. so once again, while you can discuss whether it's 142 or 282, i think -- and whether you do it now because you think there's been enough changes or whether you should do it later, we feel it's important to take a good look at what is the right start date to get this money and how will it make it competitive. yes, you can compare to other systems, but once again, san francisco can institute its own program because it's a very special city, county.

it's an anomaly frankly, but a good one. i've lived here for 17 years. thank you for your work. common cause continues moving forward on public financing to expand the program. thank you. >> thank you. >> good afternoon. thank you, commissioners. i'm don. i appreciate the opportunity to come speak to you today. i want to support this resolution. everything in it should be approved since the gut shot to american democracy by citizens united looking for ways to efficiently use our public funding is crucial and i'm glad to see san francisco setting a good example once again on that. that said, nothing i say from now on speaks against the resolution, you about , but i ld to the day we can down play a

candidate's importance to raise funds. as long as candidates are made to raise money, that opens up all kinds of doors for who they're getting the money from and everything like that, even with public -- you know, somebody might not have the wherewithal to raise $500 a shot. somebody might only want to give $25. so that's the one thing. my hope would be to see a way that -- the ability to operate a budget, to live within a budget, is more accented. if it were me, i would say there's a go line. here's the money. you've got this amount of money and this amounted of time to get elected. no fundraising. no more -- because, i mean, you know, if you're working on a budget and you have to make decisions about how to spend the money and that, if you're used to fundraising, you might say, let's just raise taxes again,

you know. that shouldn't be done. i think we need to have responsibility in the offices, not somebody that's shown to be a really good fundraiser but somebody that knows how to live within a budget, can make hard decisions about where money gets spent and all that stuff. but that's just my opinion right now. i want to speak totally in support of the resolution. thank you very much. >> thank you. >> good afternoon, commissioners. i'm a voting rights attorney at the aclu based here in san francisco. i'm here in strong support of the recommendations and ask that you please vote in favor of the proposedded ordinance. over the last couple years, the aclu foundation of northern california has been engaging different bay area organizations focused on organizing and building power among historically marginalized community and exploring publicly financed elections as an option

to address political inequality. we believe that small donors, a 6:1 matching system is a critical tool to empower underrepresented communities. we applaud the commission and local advocates efforts to carefully craft a proposal that will work for san francisco and be effective and ensuring the participation and competitiveness of community based candidates who would otherwise not have a viable opportunity. we urge you to support this important reform. thank you. >> thank you. >> good afternoon, commissioner. i'm nancy tongue. i have been for the last 18 years a public prosecutor, 11 of those years in the san francisco district attorney's office. i come to you as a private citizen. i'moff work at this point. as a first time candidate for the district attorney's office,

one of the first things that people said to me when i thought about running office is money equals viability. it wasn't experience or knowledge. it was money. san francisco does done a good job at trying to mitigate the force of money in terms of what it does to our political system. but as you know, with the influence of special interest, pacs, the ability of people who are nontraditional candidates and people of color have been diminished in our political system. so i know that these reforms will not affect my race. i encourage the commission to support these reforms by increasing the maximum amount of public financing, increasing spending limits, increasing the match of public financing funds and increasing the initial grant given to candidates because when we can start to change the

dialogue, when we can start to give opportunities to people who would not otherwise be part of an entrenched political machine or have access to wealthy donors or a number of people who would support them, but people who are really from the community and people who know the issues and who would speak for people who are disenfranchised, we will begin to really support our democracy in a way that i think the founders envisioned and expanding public financing will increase a greater representation for all people in san francisco. so i encourage you to adopt these reforms and consider expanding the reforms to other citywide races such as the district attorney's office in the future. thank you. >> thank you. >> thank you.

my name is edward wright. i'm here speaking on behalf of supervisor gordon mar. yesterday, we sent over a letter from supervisor mar detailing his strong support for the proposed ordinance, alongside his recommendation for two amendments to it. i will speak towards those specific amendments in a moment, but first, i want to acknowledge that this has been a very long process. it has been also a very collaborative process. i think the process that's led us to this point and to these recommendations being considered by this body speak very much to the principles that these reforms seek to enact and expand on. i just want to express my gratitude to this staff and to the commission and to all the community advocates that have worked collaboratively to get us to this point. we should be proud of the process that led us here. in addition to that, the two things i wanted to touch on have been already addressed, but the

first is recommendation number one, the amount of a particular contribution that should be matched. as you know, our office originally proposed matching up to $200 of a contribution, and the staff recommended $100. the commission directed the staff to look further at $150. i do think it's important to consider what kind of policy rationales can inform the exact number we land on, understanding that i think we all share the same goal of trying to further amplify the role of smaller donations and instance identify candidate -- intensify folksto . we don't think a goal of these reforms should be to decrease the value of a matched contribution under public financing, understanding that the public financing program is not the totality of the funds it impacts in election. in certain races, not the

majority of the funds when we consider the role that independent expenditures display. we would suggest matching $165. as mr. hill referenced, we would need to match up to 166.66. 165 gets us close. it's a rounder number. and then the other point for the initial grant distribution date, i also just want to highlight a policy consideration which is we feel strongly that we need to align the filing deadline for a race with the date at which candidates in that race can begin to receive public money understanding that the considerations that play into a candidate's decision to stay in a race and how funding can have an impact on that and also we think it's in the public's interest to not have public money impacting the race until the field has been set. thank you. >> thank you.

>> hello. i'm the senior policy coordinator. i'm here to offer comments and feedbacks on the plan. we're generally supportive of the plan. a little bit about us. we believe that a healthy democracy relies on every citizen have rights to a vote that contribute to equal representation. one of our platform issues is choice. we've done a lot in the community. as you are aware, it eliminates the need to have a second run-off election which is often seen as a barrier for a lot of candidates. san francisco removed that barrier. since then, we've seen a lot more women and women of color win. we're really proud of that. fair vote supports passing the bulk of the reforms here. however, we wish to highlight

one area of the commission's plan that causes us concern, namely the proposed change to the initial grant for public funds. according to the report, the staff recommends 284th day. san francisco has one of the earliest grant dates which is twice as early as other cities. further, seattle recently changed it by 35 days because voters found it was too early. they were losing their vouchers. that said, note the general election date. all the other cities in that chart note the primary date except for san francisco. so that's something that i think could be reflected. and something that should be considered during a change to this. that said, because it's initial grant date was already moved from february to june in 2011, 2012 ethics era, we don't want

to repeat of the past where we had to reduce our match ratio and change around things again because of public outcry. so we think that the set of reforms are going to be really impactful. we should wait and see how these reforms play out, and then consider changing the date at a later time when we've had the ability and staff has the band with to look at how these things can work in tandem and conjunction with each other. we admire the commission and staff's seriousness by which they have approached a lot of these reforms. so we really are hoping to see a package come out of here without the initial dispersement date consideration of elevating the 150 to 165 as mentioned in the bulk of the reform. let's get this thing passed. thank you so much for your time.

>> good afternoon. i've been a campaign worker since 1985. i carefully choose my candidates and what thing bring to our city in terms ever values, determination, and insight. and then their chances of getting elected are threatened when their opponents amount war chests to be used to slam us. these donations not only are designed to affect the outcome of the election, but are designed to exert undue influence on the policies of our opponents. a striking example was mayor breed who in obvious deference to our donors who would be taxed under proposition c did not support the strong source of revenue that was what her donors wanted. yet then, she turned around and said her priority was homeless services and lamented that we need money for that.

donations have a loud voice and can shout down candidates who have the moral integrity to refuse to do the same in return. we need your support for the package of public financing campaign reform to give admirable candidates a fighting chance to run successful campaigns get moneyed interests seeking control of elections and elected officials. thank you. >> hi. thank you. i am a small donor, resident of san francisco in the district four. i urge you to pass these reforms with the amendments as proposed. these are dark times for deckocracy. in the most recent elections that many of us were involved id

my $50 there -- dark money came in and just blew it out of the water. so we need to get these reforms happening to strengthen our democracy and have san francisco be in the forefront of that. thank you very much. >> thank you. >> hi. esther marks speaking as an individual. so i'll make it brief. i think everyone is in agreement that it's very -- that the public finance program involves public funds and so there is a trust in allocation or how that money is used. i didn't know about the change in 2012 that prior to 2012, the initial grant was awarded 284

days before the election. it was steve hill's analysis that brought it to my attention. so in my mind, though, what's absolutely critical is the information that when we did have the 284 days initial grant date before the election, 27.8% of the candidates who received public funds only got -- got less than 5% of the votes. i mean, that's like -- the people should not have run. so to me, you know, with not a good use of public dollars, now looking at after 2012, though, where it's 142 days, which is what it is currently, only 2.4% of the public campaign finance recipients had, you know, a voting record of less than 5%. in my mind, that is a better use

of the public dollars. just as, you know, we talked about when the -- who qualifies for public finance program, you want them to meet a certain contribution criteria, certain number of san francisco supporters before they're considered legitimate candidates. also, in another section, you're pointing out that for incumbents who are running unopposed, we don't allocate -- we don't allow them to participate in public finance program for good reason, again. we want to use the funds wisely. so i'm totally at this point against having, you know, the initial grant awarded 284 days before the election just because, you know, from history, it has shown that you're going to get candidates who really have no business running for public office. >> thank you.

>> commissioners. on a number of previous occasions, i referred to the activities of this commission as, quote, rearranging deck chairs on the titanic, e end qu. after observing this for a decade, all i've seen is a never ending process of simply rewriting and rewriting again and again campaign finance laws. again, quoting former commissioner hop, i don't think anyone is afraid of the ethics commission who is in competitive political light in san francisco. the lobbyists have acclimated themselves to it over a period of 25 years, and so have the candidates. the talking about the small candidate campaign funds is all well and good except for the fact that you have no power at all to control the ethics of the

election process itself. all you have to do is look at how this commission dealt with former supervisor mark farrell. that was the biggest circus i've ever seen. this is how all the big candidates, all the incumbents with dealt with. they can pull money in the dark web -- off the dark web or from campaign finances, and you have absolutely no power to stop them. number one, the only thing that this commission can do is if you find somebody violated, you can ask the body that they belong to to punish them; which they don't. the only thing you've done one time on the sunshine ordinance is the commission sent a recommendation to mayerle that he remove former library commission president jewel gomez because of her public dealings -- dealings with the public, and the mayor just ignored it. i'll be honest with you. i think any recommendations you

make to the board of supervisors, they will look at, if it doesn't appeal to them or meet their interests, they will send it back to you. i've been coming here for a dozen years now, and it seems like you're always rewriting and rewriting and rewriting and rewriting the law and failing to take into account the people who these laws affect are, a. the people who have the power to decide whether or not it will become a law and b, the people who appoint you. it's the same reason you don't enforce the sunshine ordinance. all the people on my 36 orders of determination are the people who appoint you to the chairs you're sitting in. and you don't bited the hand that feeds you. sitting around and -- i don't know. playing around with public finance doesn't do anything until you get to the point where you have the ability to do anything to make our

elections actually fair. >> thank you. any other public comment on item four? okay. so then i would propose a motion. if you turn to page 14. as follows: to approve the recommendations set forth 1a, to provide for the first $150 matched at a 6:1 ratio, increase the grant to $60,000 and $300,000. to increase the maximum funding a candidate can receive in a supervisor race for $255,000, non-invasiv,252,000 and for canr mayor, 1.2 million, non-invasive

couple bent and 1.185 million for incumbent. and four, increase the initial iec to $350,000 for supervisor races and 1.7 million in mayor races. item number five, allow initial grants to be distributed on the 142nd day to retain the -- there would be no change to the current law. number six, align the qualification fundraising period for supervisor candidates with that of mayor candidates by including the 70th day before the election and 7, require that supervisor candidates file threshold reports upon raising or spending $10,000. then i would add an ace item to the motion would be to add an operative date of january 1st,

2020. >> so for the motion, there was a recommendation on item five that was to change the 142nd day to the 284th day, but i'm choosing not to adopt that recommendation but retain the 142nd day so we wouldn't have to include that in the motion. is that right? >> that's correct. >> okay. so i would amend my prior motion to delete item five. >> right, not to make that change. >> yeah. is that motion clear for record keeping purposes and also for commissioners? >> yeah. i think we understand the motion. i think it's good for the record. i think we need a second. >> as amended as opposed to deleted, suggestion five, i second the motion as to the amended version. >> yes. thank you. >> second. >> i have just one question

before we vote. this doesn't have to be answered right now, but that -- the board's legislative analyst report not coming to the same conclusions that your analysis, i don't know if they also use the higher match since that wasn't -- that's a fairly dramatic distinction between our saying in practice, the real candidates would have had to come up with slightly fewer contributions as opposed to considerably more. so if you can just follow up on that just for our education and as we track these changes going forward and how they're being realized in the world, i would like to have that reconciled and find out what the impact really is because i do agree. i think it's important to

encourage small do not ar smallt involved, but i think it's important not to have people spend all their time talking about how much money they need to raise as opposed to what they're going to do once they get her. >> i'm sorry. there's a -- i'll be happen tee ashappy toask you a question ife an answer to that. >> yeah. just to speak on that briefly, i believe the daily report, which to clarify is still a draft report did use a different methodology. it was lik looking at a differet matching rate, but it was looking at averages as opposed to maximum contributions. it is our intention to have that report issued prior to this package, this draft ordinance being considered by the board of supervisors if you decide to approve it today. >> then in that case, i would ask you if you could put mr. ford in touch with the

budget analyst person on this so that we don't just add confusion when this same set goes over to the board. that would be helpful. >> yes, absolutely. i would be happy to meet with you. >> and mr. wright, if possible, if the final report could be shared with us, that would be helpful as well. >> yes. absolutely. >> thanks. >> commissioner lee, did you have another question? >> i do agree that this is a really good piece of proposal that needs to be supported. i do want to -- i don't want to hold, you know, this up, but at the same time, i do want to re-emphasize the whole idea of public financing is to really bring in the disenfranchised to make sure that their voice will be heard and their participation

would be included. i continue to struggle with 100 versus 150. again, i'm not going to hold this vote up. i was just reminded a couple weeks ago by a couple of neighbors that 30% of san francisco's population are older persons who live in fixed -- who live on fixed income, yet majority of them consistently involve themselves in the electoral process where there's voters, campaign volunteers, donors. they're the ones who are probably included in this report that, you know, many grassroots community based candidates, they

receive small donations under $100. i have a feeling those are the people who are included in your assessment. has been said about the seattle voucher system, but i think a central point that my seattle friends had consistently wanted me to remember is the whole idea of the seattle program is to make sure that the power, the political power, is returned to the residents. therefore, the vouchers are on the hand that they can determine the future of the city. those vouchers are not that much expensive. they're in increments of $25 or what have you. but because of that change, it's changed a whole concept of how candidates run the campaign, how voters voices are being

considered and respected. people now, candidates now have to earn those $25 or $100. so i have -- i understand it's really tough to run campaigns, you know. i've seen first-time candidates standing on street corners, you know, trying to let people know who they are. that's why we have public financing, to support folks like that who truly are from the community who could truly respect the community's voices. so i still believe the $100 donation is not just a matter of process. it's a matter of the people writing the checks, whether they should be and could be and must be included when the candidate talks about policies and talks

about their platform. so, you know, again, the two things is the public finance system is supposed to support the residents who have very -- who have been marginalized and also to support candidates who do not come in with, you know, huge support base. but, you know, i understand the need to move forward, and i hope that once we put the new system in place, that we can revisit this and hopefully by then we will have more numbers. by then, we may see a new budget on campaign financing and hopefully we can revisit the $100 one because i really feel that population really needs to

be -- their voice really needs to be respected and honored. >> very well said. thank you, commissioner lee. so we have an amended motion that was seconded by commissioner lee. should we do a voice vote with the executive director, or would that be the best process? >> we can do a voice vote or a roll call. it's up to you. just a brief process reminder, we will need a unanimous vote on this amendment today. >> it was the amended motion was seconded by commissioner smith. so could you do a roll call vote, please, on the motion? >> on the motion -- >> amended motion. >> on the amended motion as proposed by commission chair

chiu and seconded by smith. >> aye. >> commissioner lee. >> aye. >> commissioner ambrose. >> aye. >> and chair chiu. >> aye. >> unanimous vote. thank you. >> thank you. well, thank you. i would like to echo mr. ford's comments and also mr. wright's, i think this has been a long process, but i think a worthwhile one. it's been a privilege to be part of it. i appreciate the dialogue, the partnership, the collaboration, and look forward to more great work like this in the future. i would like to direct staff to prepare this into the appropriate format to be able to send over to the board of supervisors and then maybe you can update us at the next

meeting on where we stand with all that and how things are going. thank you. >> okay. let's see. agenda item five, suggestion and possible action on proposed amendments to regulation related to article one chapter one and article three, chapters two and six of the campaign and governmental conduct code. >> thank you, chair chiu, commissioners. item five is a set of amendments to three articles of regulations or i should say regulations supporting three articles of our code. specifically those are the campaign finance reform ordinance which is article one,

chapter one of the campaign and government conduct code. article three, chapter two, which is known as the government ethics ordinance, the conflict of interest, subsequent conflict of interest rules and also article three, chapter 6, which are the code sections regarding the payment reporting. this set of regulations is in all three of those buckets. as you remember from last month, we brought these amendments to you to achieve three different purposes. one is to implement -- or help implement the new code sections created by the anti-correction and accountability ordinance. they are in effect now and these will help clarify the requirements and how regulated individuals are to comply with them. additionally, these regulation amendments would help to provide clarification about code sections in the campaign and

finance reform ordinance that are separate from the acao. preexisting provisions about law about staff might have given advice in the past and the regulations can now serve to codify that advice and give better clarification to folks. then lastly, a lot of amendments are in the form of clean-up. they are changes that were not previously caught, and as we've discussed at prior meetings, we now have processes in place to make sure it doesn't happen. case in point, we were doing the sets of regulations right now to implement the acao. so we're confident that that will not happen in the future. but in any event, these regulations will help to change parts that were not changed in the past when the code diverged. so that's the purpose of these. i would like to give you a little bit of an update from last month when these were before you. since then, we did notice these

regulations publicly on may 16th under the charter. there has to be public notice given 10 days in advance of a meeting in which regulations will be voted on. at the last meeting, we had not done that notice because the regulations were just offered for discussion purposes and to generate public comment. but at this meeting, we did do that notice. so you are able to vote on the regulation amendments today if you so choose. also, after we had these regulations at the last meeting, we got public comment from a number of folks, and that helped inform the set that's before you today, which is by and large quite similar to the set from april but does reflect a number of comments that we received. i would like to thank those who were involved. we got a lot of very helpful comments that i think make this a stronger set of amendments. some of those comments we got before the 10-day notice went

out that we were able to incorporate the changes into the version that's before you today, as agenda item five. it is identical to what we went out to the public notice on the 16th. however, we got some public comments after that notice had gone out, and because of that, there is a set of, i guess you would call them, supplemental amendments. it's a one-page sheet that you've received. it's on the public table that's titled agenda item five, staff's proposed amendments based on public comment. did each of the commissioners have that sheet? >> looking. >> we might need one.

>> i have it. it's all right. >> great. again, these are changes that staff is proposing that these be amended into this larger set. these were comments we were not able to get into the draft because we had to send out that 10-day notice. >> so just to recap, these additional one and a half pages would be incorporated into what the regular agenda item? is. >> correct. yes. i would propose that those be amended into this larger set to be one set. since they were in written form and available to the public, mr. shen's confirmed that's okay. >> if we were to approve these, they would move to approve what you have attached and add this? >> correct. >> and that's enough -- okay from a process standpoint? >> and just to make things a little bit more complicated for

you, there are also two additional public comments that we received that are not reflected in this extra set that we think is important to include in this list. so i would like to show you where those are right now. the first one is on page 21, and that's the stamp at the bottom that says agenda item five, page 21. there are two page numbers on a lot of these pages. the bottom center. >> page 13 on the -- >> exactly. exactly. this is regulation 1.126-7 could not tributer information. the change that was pointed out to us is that in the first line, it says i am not -- i'm sorry. the first line of the underlined text. it's being changed to match what

the acao now says. i am not a city contractor or a director, officer, 10% shareholder. what should be there, instead of 10% shareholder is greater than 10% owner because the code actually does not cover 10% owners. it only covers those who own more than 10%. >> so the language you're proposing is to add greater than 10% and then keep 10% shareholder? >> i would -- >> or greater than -- what's the language that should be in the clause between officer or sub contractor. >> greater than 10% owner. >> not shar shareholder. >> owner would match closer. >> this is a conforming change to the code? is. >> correct. the code technically would not confer someone who owns 10% in a

contracting entity. you have to own more than 10%. that was pointed out, and that's correct. i think it's important that change be included. >> okay. so the change should read -- it should read greater than 10% owner. >> correct. second change that i would propose is on page 24, and this is language from regulation 1.142-5 in a. this pertains to the statement of participation or non-participation, the candidates file to state whether or not they will participate in public financing program. this regulation incorrectly states the deadline for filing nomination papers. it states that deadline is the 88th day prior to the

election. but as we actually discussed during the previous agenda item, it's 142nd day. so the change that mr. shen pointed out is that if the language starting on the third full sentence, which is on the third line, that says under state law, a candidate must file her or her nomination papers no later than the 8t 88th day prioo the election. if that were struck, that would make this sentence a complete sentence and it would make it accurate. the sentence would only read, unless the deadline to file nomination papers is extended pursuant to california elections code 10220. that doesn't make it a full sentence. >> no, that's not a full

sentence. >> if you combine that with the immediately preceding sentence and join them with a comma. it would say the candidate may not withdraw or amend his or her statement after the deadline for filing nomination papers, unless the deadline to file nomination is extended. >> you're deleting the cause under state law they must file no later than 88 days prior to the election? >> yes. >> deleting that. >> yes, because for the candidates who can participate in public financing, mayor and supervisor candidates, they have a different deadline than other

candidates. some candidates actually have an 88th day prior to the election deadline. but it's not the same across all races. so this regulation didn't capture that difference. this would be in the clean-up category. >> okay. >> so apologies for the many sources of these amendments. they're not all in one place. >> i'm sorry. i hate to do this, but can you read that sentence again? you must have struck something else because it's -- okay. thank you. got it. thanks. >> any other changes? >> no. that's all. the final thing i did want to

note, there are a lot of public comments that we incorporated. we thought a lot of them, including these, made a lot of sense and improved the regulations. there were a couple, though, that we declined to incorporate into these. i wanted to highlight those for your information. one of the comments that we heard was that the regulations should not state that candidates must file specific and distinct forms in order to comply with some of the new disclosure requirements that were created by the acao. specifically, the regulations say that in order to comply with section 1.114.5 -- i'll explain what those are -- that the candidates must file form 1.114.5, 125, and 124.

each of those requirements, staff would create a new form that the candidate -- i shouldn't say candidate -- filet candidates -- that the filer would file in order to comply with the filing requirement. what these filing requirements are, disclosure requirements, .114.5 says when a city receives a contribution made at the behest of an official, they have to disclose that contribution was behested by the official. 1.124 says that when a committee receives contribution of a certain amount from a business s entity. they have to state one officer and whether or not they have received a grant or contract recently from the city. 1.125 is the bundling disclosure. it says that when a candidate

controlled committee receives a certain number of contributions that were delivered or transmitted by someone other than the contributor, they have to disclose the identity of that bundler and list all of the contributions that were bundled by that person. in implementing the disclosure requirements, staff is creating new forms for each of the disclosure requirements so that filers will have a specific process for complying with these that are tailored. there will be a field for each of the separate items that are part of the disclosure requirement and those forms will feed into our preexisting electronic disclosure system where filers file and then since it's an electronic format, each of the pieces of data separately goes into a different column or row in a spreadsheet so that if

you're doing research, you can electronically search through all the disclosures. you can search for who is bundled for a certain candidate or which elected official has behested contributions to ballot measure committees, those kind of things. you can research. that's why it's important for them to be done on forms, distinctioned forms. the comment that he with received was that we should not create distinct forms because that would constitute significant administrative burden on the filers, that it would be more reasonable if they were able to satisfy these new disclosure requirements by stating this required information on the public note, on the form 460. the form 460 is a campaign statement that all committees file annually, sometimes also shortly before elections. they basically disclose all of the finances, incoming, outgoing cash, loans, non-monetary

contributions, everything goes on the 460. there is a way to include a public note which is basically a box where you can insert text. it's used usually to clarify something about the filing or provide information you couldn't put under one of the precreated fields. the comment was under the public box could be used to note these disclosure requirements. we opted not to pursue that course because for one, it would be hard for filers, single box. it's unstructured. it's hard to know how to properly fill this information in. then likewise, for people who want to look at this information, it's not intuitive to look at the public note. you would have to know that's where it is in order to look there. there would be no other place to tell you to look there. then also, there would be no way to actually search it since it would be unstructured data. you wouldn't be able to perform the kind of detailed searches

that people usually do when they're looking at this kind of information. >> through the chair, can i ask, one of the commenters ask we most forms on our website so that people can preview them before you actually are up to the speed of logging into the system. is that something that we already have or can do easily? because just from a background point of view maybe, or is it part of your -- i know you're doing training and outreach because of all the changes, et cetera. maybe that's just something that needs to be, you know, made widely available so that they know what to do with it when they do get the new form. >> yeah. i think that's something that we could do. that is not our current practice. i don't know if director paul

wants to speak to that point, but currently, we don't provide those forms specifically so that people use the electronic filing system. >> i don't mean provide them, but you can make a pdf viewable right on the website or in the -- >> i think the concern is people would use the pdf to file. >> i see. >> they enter the information into the pdf and e-mail it to us. that's the old format. that's how -- >> i see. >> filing used to be done. people would fill them out basically like an electronic verse o -- version of a paper form. >> it's not searchable. >> they don't feed into our system. >> you can put a watermark or something on it so it wouldn't work. i'm just saying, i thought -- i understand, because there are some of us who don't live in the electronic world, weren't born and raised in it and like to see things, you know, sort of like how does this whole form play

out without clicking through ten screens. i think there is some public information request there that was sincere. so i don't definitely want to let people lapse back into unnecessary waste of paper, but just didn't realize that was the concern about keeping the forms only electronic. >> i think commissioner ambrose raised an important point. what's the interface and how user friendly is the process, and i think that it's important that we strive to improve the interactions and -- i think there's a lot of value to making it available at least visibly, if not downloadable pdf, with you would leave it to you, director, to determine how best to do that. but, you know, we would love to

hear from -- in public comment if this would be helpful to people, too. i for one, it is nice to be able to see something and check it out before i actually commit to logging in and -- >> i think her request was limited to the new -- those particular new forms as it relates to obligations of nonprofit or what she considered to be people outside the general electoral process where they might be a little bit more intimidated by net filers. just if you can look into that. >> if i might just have a quick response. under the executive director's report, we have some updates. our deputy director and chief officer is here. i think she can speak to the process that we're engaging in to get information out there online and the easiest way possible. so maybe i'll defer that and we can ask her. >> great. thanks. >> i had one more question. i know you were giving us the things you put in and the things you didn't put in, the comments

presented by ms. stern kind of the bigger one is this whole definition of affiliate. are you going to speak to that, or are we going to hear about it in public comment? >> >> yes, i will spoke to that. >> before we leave the separate forms issue, a couple of my fellow commissioners weren't on the commission at the time and commissioner lee, i think you remember, perhaps, the discussion at the time was disclosure versus a ban on payments entirely and that it seems to me that when we went down the path of going with disclosure of behest the payments since of banning them, that the disclose you'r dis -- d serve -- [ please stand by ]

>> the committee will not be held liable for failing to disclose that. there is no way for them to know the reason why we felt that warded a safe harbour is twofold the main reason is that there is a statutory requirement in that section that the contributor informed the committee that the contribution was made at the behest of an elected official. that means that from an enforcement perspective, if the committee fails to disclose a political behest, we pursue an enforcement action against them, they claim that they never received notice from the contributor, and that means we can turn to the contributor