>> 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 that

enforcement action and they would be liable, potentially subject to penalties unless they can prove that they had given that notice to the committee. essentially it wouldn't create a workaround to the disclosure requirements that if the committee tried to use this safe harbour, there would still be liability that somebody actually failed to give notice the other reason that we felt safe harbour was a little bit more warranted here was that there is no way to see on the face of the contribution that it even triggers disclosure. all you would see is a 5,000-dollar contribution from somebody. nothing on the face of that indicates that it warrants disclosure. it is different for the bumbling -- bundling disclosure and the entity disclosure. for both of those, when you receive the contribution, the trigger for the disclosure is triggered to you. when you receive a check from a corporation, you can see it is a

check from a corporation. whether or not you have educated yourself, you know that it is disposable. is it possible for you, when you receive the contribution of the knowledge that the trigger is present, and the answer is yes, you can see it as an entity contribution. it makes it a little bit less necessary for safe harbor to exist. like ice -- likewise with bundling. when they receive an envelope of ten checks handed to them by one person, they know that bundling has just occurred. there is no separate inquiry for them to ask for that bundling to occur. again, i understand that they might not appreciate that bundling disclosure that exists, that has been an engagement of the compliance endeavor. they want to make sure they are aware of the disclosure requirement, but they at least know when they are getting bundled checks and they need to implement some strategy within their organization the organization that when bundling

happens, it is labelled as such so that the treasurer or whoever else is filing disclosure can have that information and can file the form correctly. >> can i ask a real basic question? is bundling only when you get the checks in one envelope for one person, so if somebody has a fundraiser and they encourage everyone in the room to make a donation, but to give them all separate envelopes and stamps, then they didn't bundle, but if they take them and -- in hand and bring them all in at the same time, is that bundled? >> the language in the statute is delivered or transmit. >> deliver or transmit? so not encourage -- okay. >> that would be more of a behest. if i encourage you to contribute to a candidate. >> but if you are not an elected official, you could behest all you want, that is just public advocacy, right? >> correct, and it is not

disposable. >> thank you. >> it is a good question. >> we are in the process now of being given device and interpret what the language means, but we do consider delivering a transmit to have a physical component to it. >> actually, that is one of my big picture questions. the small one went into effect in january, so you have been engaged somewhat with answering questions about this. have there been much in the way of questions, given we have not had an election since january? >> not much. >> if i may add, i don't think there was much public awareness campaign going on other than folks who are intimately involved with public financing. the general public really hasn't been aware of this log going

into effect a few months ago. >> right. our engagement and compliance team is currently working on developing the kind of materials that were spoken about in public comment. they are working on the kind of back sheets and website contact that would help people understand that and they are in the process of thinking about what kind of communications will be most effective to notify people about these, and as they develop the forms, there will be content at the top of the form that will give some explanation that would appear on the website when you are going to fill out an electronic form. so yes, that is definitely a big point of view right now. so the last item that commissioner ambrose alluded to earlier is the definition of affiliate. in the regulation, we propose that sponsored or controlled committees be retained in that

definition, what that means is that if a corporation has a contract with the city, and that an official recently approved that contract, such that the contribution band is triggered, and the corporation cannot be up to the candidate, but now under 1.126, the principal officers, shareholders, more than 10%, subcontractors, would be prohibited from giving to that official who just approved the contract. and additionally, we think it is important to maintain the rule that any sponsored or controlled committee would be prohibited from giving. if the contractor is ibm, and then ibm sponsors ibm pack, the ibm pack should be prohibited from giving to the candidate if ibm itself is prohibited.

this was explicit in the code before the aca oh. the code before this used a different set of defining terms, and they reshuffled the terms. it did not include sponsoring of the control committee in the new definition. the public comment we received said that evidence is a clear legislative intent to not cover sponsored or controlled committees, but staff takes a different view, that that was not something that was i was done intentionally for the purpose of sponsoring these committees. and thus it is within the power of the commission to retain these entities under the ambit of 1.126. we also think it is incredibly important that they be retained, only because, how obvious it is that a business entity could work around this merely having it sponsored or controlled

committee make the contribution that would otherwise be prohibited. we think that would fly in the face of the clear intent of the provision and it would frustrate it. it is also the case that sponsors of controlled committees would not be caught under general aggregation principles most of the time, so separate from 1.126, the contractor contribution van, there are general principles of aggregation in the code that say certain circumstances we will aggregate the contributions of separate individuals or entities , we will count them together, and the nexus has to be -- the one person or entity directs those controls -- directs and controls. is a much narrower nexus. you have to direct and control and it has to be by the majority of the same people. what that means is that if the corporation corporation has a

sponsored pack, but different people control the cultivation from the pack, so let's say you have a board of directors that controls a corporation, but you have a political giving committee that controls the pack , and those are different people, that the contributions would not necessarily be aggregated with the corporations that means that if we do not consider sponsored or controlled committees to always be affiliates, there is the potential that they will not be aggregated under those general aggregation principles, and therefore, corporations who are subject -- any business entity is subject to this and then could use a sponsored or controlled to bypass it. that would be a new development. it does not exist or did not exist prior to this, and we think it is important to avoid that.

>> in the law, it says that sponsored and controlled is defined in chapter 1 of the campaign and government conduct code. you don't happen to have that definition? i am still having a little trouble understanding the difference between ibm's, and their sponsored and controlled pack, and two that brings in, but i do hear you. i think the big concern about the question raised was what was the legislative intent, and that is something that you can ask the city attorney's office to take a position on if you so desire. >> i can just briefly add that i agree with staff's interpretation. obviously, the purpose of the band is to prohibit contributions from certain companies doing business with the city, and to be frank, it would be a rather unreasonable interpretation, but that does

not extend to a campaign committee directly controlled by the same company or corporate entity. that would be a very unreasonable interpretation and a very unreasonable result in my opinion. >> thank you. >> thank you. >> did you have other questions? or commissioner questions? any other questions? are there any other comments? >> no. >> thank you. i would like to invite public comment on agenda item number 5. >> this is about -- >> could you pull the microphone >> i'm sorry. this is a regulation listed on page 12 -- anyway, it is the

provision of how long the executive director, how much time the executive director has to certify, and they are being eligible for public financing processing and matching funds. the current -- and i didn't know there was such a thing between the regulations and code, so i had a hard time order -- adding the code. so your senior analyst send that to me. anyway, the current regulation and code is that the executive director for certifying a candidate who makes the application for the public financial pro -- finance program has 30 days to make that determination. in the code, it also says in terms of the processing of matching funds, the executive director has four days for it to

be processed, and i am proposing that the days be shortened. as you have heard before, one of the biggest problems is not only a surety of receiving public funds, but the quickness with which the funds are made available, and i am proposing that for processing applications for our certification for public finance for candidates, that it be shortened to ten working days , and then for processing, matching the application, it could be shortened to three days i know from my experience as a volunteer treasurer in 2016, i had no problems at all, and the application for profit was very quick. in 2018, it was a different

matter, and i was told verbally that most certifications take place within a two-week period, so i don't think it is unreasonable to ask for a ten day -- for ten days to be put in writing as a goal for processing the certification. and by the same token, i don't think it should be, you know, it is a challenge for staff to process match contributions to three days. and if there is a problem of timing in terms of the matching, the current regulation is that the minimum match -- the minimum amount that has to be applied for with the matching fund is $1,000, and so that could be increased so that, you know, it would happen, the application would have been less frequently. there is also a requirement that the match request -- is requested ten days before the election that -- which i think

should remain in place, that the minimum contribution match requested is $200. i think that should remain in play. >> thank you. page 16 in the regulation. >> thank you. >> good afternoon, commissioners i just have a few comments regarding the proposed regulation. on page 17, proposed regulation 1.126-one clarifies the definition of affiliate, a new term and an anticorruption unaccountability ordinance, with respect to contractors doing business with the city. under the proposed regulation, the term affiliate includes any community that is sponsored or

controlled by the name, party, or prospective name party to a city contract. this proposed definition, however, exceeds the scope. under the previous version of sex in and 1.126, and his regulation. the contractor contribution been applied to a committee and a sponsored or controlled by the contractor. however, when it was adopted, a sponsor of controlled committee was deleted from the contractor ban provision and was not included as part of the definition of affiliate. as a result, the term affiliate does not include a committee that was sponsored to a contract these contracts should be deleted. the same principles that applies to the more than 10% provision that you just changed applies here. in addition, exempting a committee from a contractor ban

is consistent with some provisions of state law. for example, california government code 1566 imposes limits on contributions from a party participant or an agent of the group to a member of the state board of equalization during a specified time period before in adjudicatory proceeding, involving that party or participant. however, the regulation exempt from coverage contributions from committee, affiliated with that party participant or agent of the foregoing. on page 20, the proposed regulation provides the notice requirement for city contractors , in one of the listed notices in subsection c. refers to a committee that is sponsored or controlled by the contracting party as i just mentioned, since the committee language was deleted from the organization when it was adopted as reference to committee, and this regulation should be

deleted. finally, on page 21, the proposed regulation, you have just addressed my final comment by changing that language from 10%, to more than 20%, which is specifically stated in the ordinance. thank you. >> thank you. >> good afternoon, commissioners , my name is jesse, i'm a political law attorney practising in san francisco and i am speaking today on my own behalf. i wanted to indicate my general support for the proposed regulatory amendments and to commend and thank pat ford for

all his hard work and for the open and thorough approach that he took with respect to the use of amendments. they have been needed for a little while now, and i think he did in excellent job with them generally. i did want to address, very briefly, two areas where i think , in general, we may agree in principle, if not on the ultimate regulatory proposal in front of you. in particular, first, as mr. ford said, i think some of us would have preferred to be able to use the primary campaign report accessed by the general public to disclose the new campaign -related information, not the behest of payment information, but there's the bundlers, there's the money raised by elected officials, and then there is the corporate donor information. we would have preferred the 460, instead of new separate forms,

but if that is not going to happen at this point, i guess i would simply ask that the commission commits to integrating the new reporting with the electronic filing requirement system, meaning that file that is used with respect to the 460 as it has done with the public financing system. so and that is not immediately obviously, but i know it is technically feasible, so just as soon as possible he possible, because in general, i think it is going to lead to more accurate reporting and it will be easier for the committees that have to comply with this to track and restore and ultimately to report the data. that is just the one comment. second, i just want to explain with respect to their request for the safe harbor for one of

the reporting requirements, as mr. ford said, there is already a safe harbor requirement with respect to the money raised by public officials. i will finish up. not asking with respect to bundling, because that is pretty apparent for the committee, but more with respect to the corporate donor disclosure because with the information about a principal officer, like aco, that is something you can find online and something -- it is pretty easy to determine, but with respect to the question of whether somebody has received funds from the city in the prior 20 months, it is hard for a committee to verify that other than relying on the donor itself to provide that information, and so, you know, all we can do is ask and follow up and say, are you sure? but ultimately, the information

that they give us information say, hey, there is no contract, we have to rely on that, and what we would say is if somebody is -- if the committee makes a reasonable good faith attempt to get that information and reasonably relies in good faith on the information that is provided to them by the donor, it would seem unfair, ultimately , to penalize that committee if the information given to them was inaccurate or incomplete. so those are my two comments. in general, i just want to commend mr. ford for an excellent job in general on these regulations. thank you. >> thank you. mr. ford, does this follow-up to the integration? i would imagine, but i do want to confirm that the new forms it created would be integrated into net files so that there would be another way to file them. is that correct?

perhaps in honor of time, they will be. >> i will ask our deputy director to address that, i think there is some questions that might come up during the executive director's report, but since this topic is on the table now, i've asked them to come and address that. >> good afternoon, commissioners for the new forms that we are building, they are being built in a different system, and not not file because it is a system that is available through city contract, and we wouldn't need additional funding for designing the system, in order to not file , we will need funding, and also a contract in place to be able to do that. it has been mostly building all of the new forms using this.

>> i see. once the forms are submitted to the commission and dock you signed, are they -- will they then be searchable why the public? >> that is correct. they will be searchable by the public because these forms, the dock you -- the dock you find system is integrated with the opened data system. so we are able to oppose the filings through that in realtime >> for these are filed through net file -- before, these were filed through net file? >> correct. >> it would require a budget, dollars are not currently in our budget. >> that is correct. we would have to work with net file to see if the steps have been enhanced or made in the system. i know some of the forms -- some

of the suggestions regard incorporating different elements , but we looked at the current form, and i don't think it has been raised too efficiently to accomplish that level of detail. we can still be planning to talk about that file and see what it would take to enhance the system , and of course, we also need to look at funding in addition to that. we can get back to you when we have more information from them. i don't have an idea of the timeline, because it would also require them to do an evaluation of the requirements and then get back to us. >> i see. it is not -- it seems like it is a more straightforward, inexpensive, less expensive and uses less resources. >> yes.

relative to the file system. there is a lot of work involved in designing and coding, which our team is working on it actively, but we have a framework of how to build those forms. it is automated from the point of somebody filing the form on the website, to how it gets to our system internally, and how it gets posted onto the public. we are able to use the same work for all of our forms. >> the only thing i would ask is even though there might be separate systems on the back end at the commission, but to the extent and is feasible from a design standpoint, from user experience, if it could be visible so that as clients go

into go file, that it would be -- where do i have to navigate now, so that the user experience would be as seamless as possible despite the fact that there are two different architectures in the back supporting it. >> i think that is great feedback. that is something we are looking into. as we are building out these additional forms, we are also building out the content that transport mentioned earlier. for each of these forms, we are building out separate webpages with instructions so that we can provide enough information to the public regarding these forms we are also looking at the menu design and layout of our website the maybe places made to highlight certain forms, and provide information about these places. this is something we are looking into as we're hand singh this. >> i was on the los angeles

commission site, if you're a candidate, if you are a committee -- however you design it, i'm not trying to tell the painter how to paint, but as you think about the redesign of the website and moving things around , i really want you to put the user experience for those who are wanting to know, what is the form 462, those who are very experienced participants in the political process so there is as little friction as possible. i think it would be great. >> in december of 2016, we did launch our new website. a lot of our content is being designed than our previous website, but as we are building on these additional departments, we are noticing that some changes are needed, and how we are navigating through different types of informational websites so something like that is definitely on our radar. i can talk more about the implementation in the report section as well. i want to give you an update on

how we are approaching these types of activities right now. >> wonderful. thank you. >> is there questions from commissioners? commissioner ambrose? >> it is great you are doing all the work on the outreach because i know how complicated this is, and i know we want to encourage people to get involved in the political process. we will need to hold their hand to get them started. so the comments about safe harbor, so we are getting safe harbor on behest of the payment because it is not clear that the money was behest did, if it comes from someone, and that makes sense to me. it looks to me, and maybe i am misunderstanding it, that on page 13, the right-hand corner

page number, that under 1.1267, we are also giving a safe path by telling the candidate that if you get someone who gave you the money to sign this statement, then you can rely on that. is that correct? if the candidate will meet the due diligence requirement of the contribution been, if the contributor, whoever that happens to be certifies that the following is true, i am not a city contractor, director or 10% owner, and that means than that we wouldn't find them to be in violation if they get one of the statements signed by everyone who gives the money. and then i have another question after that.

>> i would have to look at whether or not that would actually be a complete defence, and result in no liability, or merely it would be a mitigating factor. i don't know right now looking at it. i would have to look at the code and the other regulations and see if due diligence, satisfying due diligence is efficient. >> i think that is important. if we are -- one, having served as general council for the water power enterprise, we did thousands of contracts for over 100,000 dollars over a short period of time with all of the capital improvement. the number of subcontractors could be literally thousands of

subcontractors who may or may not even know that the person that they gave their bid to actually submitted a proposal. i think we are going to get a lot of questions about, i am i okay with taking money from jane or joe, and if this implies that as long as you get the person who is giving you the money to tell you that they are not a subcontractor of some proposal, but it doesn't really, it just means that you met your due diligence requirement but you will still get an enforcement action i committee, i want to make sure we're clear on that when we send this over to the board. this does not go to the board board, these are just regulations. >> it does go to the board? i am sorry. i didn't realize that they adopted these.

>> the board of supervisors is not required to have a separate action or vote on the proposed regulation. >> i do think it is important to clarify that. i anticipate that we are going to get a lots of puzzled folks out there, the other thing i was going to ask you, in fact, is for purposes of 1.26 or 126, agency seeking to enter into contract means a city department that is purchasing authority for the contractor agreement, under the charter, i am not a city administrator, right below that, and 1.1268, notification by city department. they are required to notice by the ethics commission every time he gets a proposal for contract and has a value of more than

$100,000, and that includes modifications of existing contracts of more than $100,000. contracts at that size might not even go to the board, you are going to be working with a lots of departments, d.p.w., p.u.c., port, who have a lot of these contracts will try and figure out how do they comply. i am wondering, have you had any conversations with the city administrator or the purchaser about what they have to do to meet these obligations? >> yes. one thing i wanted to point out is this f2 requirement does only applied to contracts that will require that approval by the board. it has a total anticipated value of $100,000 and required by city elected officer. requires the approval of a city elected officer, only such

contracts would warrant or be triggered. >> so the board and the d.a., the mayor, the city attorney, public defender. okay. and then for all those other departments, it will only be a 10 million-dollar contract? and 100,000-dollar modifications , or 500 dollar met if it -- modifications? >> and only if it requires approval. >> there is shockingly a large number of contracts that are over $10 million. i still think it really is a service to yourself and the city department who are going to be want to be in compliance with that submission. i would definitely do a reach out to them specifically that is beyond just the public. >> we are in the process of doing that. i think implementing this notice

requirement and the f-4 requirement, which is when the elected official actually approves the contract, that also triggers a notice, and implementing both of these is a pretty crucial part, and also a somewhat difficult part of this code section, because it requires that cooperation and coordination with other departments, but that is definitely something we are working on and figuring out from a business process standpoint, what is the best way to allow them to do it in an effective way that creates the information that the section seeks to make available, which is a list of builders -- bidders and contractors, so someone contemplating contemplating making the situation will know whether or not the contribution would be prohibited. i think we will be working with other departments moving forward on this one. >> that would be quite an

interesting database because it doesn't exist now. >> that is correct. >> thank you. >> okay. any other comments or questions? okay. i would move to approve the revised regulations attached in agenda item five with the addition of the agenda item five , regulation supporting campaign and governmental conduct code, plus the two changes that mr. ford had identified on agenda item page 31. and the second full paragraph, the first full sentence by replacing 10% shareholder with the word greater than 10% owner.

and then on agenda item five, page 24, regulation 1.142-5, process for establishing eligibility, river but get -- not participating through all declaration, subsection a, it is the third line after the words filing on the nomination papers, striking the period replacing it with a calm a, and deleting the word under state law, a candidate must file sir her nomination papers no longer then the 88th day prior to the election. and then continuing on with the additional understory -- underscored text. commissioner lee has a second. what do you want to do? >> it sounds like the chair would like to do a roll call

vote for the motion seconded by commissioner lee. [roll call] >> the motion is approved with all four members voting in the affirmative. thank you. >> agenda item number 6, discussion of the monthly staff policy report. this is the pat ford show today. >> i am here all week. [laughter] >> thank you, she meant -- commissioners, agenda item six, i'll be very brief, this is our monthly update for the policy division. the big news here is that we are losing brian. he is leaving our office and going back to the public defender's office from once he came for a new and exciting

position that has been created specifically for him to do criminal law policy. he learned so much in the three and a half months here. he now has policy positions created for him in other departments. >> but why? why would you want to leave? [laughter] >> so, with that fact in mind, and with new developments on both the financing friends and the register front, the the memo here, the report proposes a plan for the policy division that basically would encompass three policy projects at this point, policy project one would remain the public financing project, at this point you have now approved an ordinance, so i will be working with him to finalize

that ordinance, send it to the board, we will be seeking a sponsor for the ordinance. i believe that supervisor marr is willing to sponsor that ordinance, so we will be continuing to work with his office and trying to gather support amongst the members of the board of supervisors to approve this ordinance and require eight out of 11 votes. will first go to the rules committee. there will be a process with this ordinance. i definitely want to be engaged on that, provide the commission 's perspective on this piece of legislation, and that will definitely take some time. i propose keeping that as the main policy project for the time being. likewise with the regulation amendments that you just approved, at this point, andrew and i will be working in those final amendments that you approved today to create one final version, transmitting that to the board so that the board

has the option for 60 days to call a hearing on those regulations. at the end of that period, assuming that nothing happens during the 60 days, we would then move into the implantation phase of making sure that all of the different sets of regulations on the website are up -- updated. will be working with staff to make sure that they are aware of all of the changes, that any documents or forms reflect these changes, and making sure that these go into full effect and effect all of our processes in the office. this will be a continuing process, no work for two months while they sit, but then starting in july we would be picking these up again and doing implementation phases together with other divisions in the office. and then thirdly, the form 700, e-filing for all project is something the office is in development for a number of

months. this again is the idea of having all filers of the form 700 file electronically. currently, only members of the board of commissions, elected officers, and department heads file electronically, meaning day go into the system on an electronic interface and fill it out. everyone else files on paper, which can mean that they are filling data into a p.d.f., but when they submit it, they printed and handed to someone in their office. it stays in a filing cabinet in their office. this project would be to convert all filers into that uniform, online interface. it is a fairly significant project that involves collaboration with a lot of different divisions within the office, and frankly, with a lot of different departments within the city i believe at this point

, we have met with eight to ten different departments to talk to them and work with them on how we can implement this project. it is still in development at this point, but i think that we foresee hopefully moving further with this over the summer and starting to talk to more departments, and talk with potential bargaining units with the impact that this would have on city employees who would be required to use this different system, and potentially start looking at regulations that we would bring before the commission that would require electronic filing, so at this time, policy has been assisting other divisions in these talks with other departments, and is starting to think about what a process plan would be, but as the project moves beyond development and starts to go towards the project phase, i

foresee having a more active role, especially as it pertains to any meet and discuss that we would do with employee bargaining units, that is something the policy would be heavily engaged on, or if and when this project comes to the point of regulations, it is something that policy would be heavily engaged on. that is kind of the third policy project around that portfolio, three projects of implement in the public financing. and continuing to promote the public financing reforms and if they are approved, helping to implement them and implementing the need for regulations, and assisting with the regulations and regulation drafting for these projects. i think since i will be a one-man operation once again, that is probably more than enough to keep me occupied between now and fall. i think that these projects, each of them have at least a

three to six month lifespan with the form 700, one having a vastly longer lifespan to be determined and enough to keep me busy for a while. there are some other updates in here, the ones i wanted to highlight. i wanted to highlight the paid online political communication project. brian contributed a great webpage to our website that is our attempt to help the public understand how online communications, online political communications are paid for. as you remember, this project was to try and find ways to help people understand that when they see a political ad on facebook or twitter, help them understand who is paying for it, where is that coming from? so this webpage, there is a u.r.l. here in the report, in the footnote, the page explains

some of the fundamentals of campaign-finance in terms of what is the committee, the committee his pay for communications, and how do i find what committee paid for this? it talks about disclaimers, it talks about how to use committee names to then use the dashboard on our website to look that committee up, how is the committee funded, and how's it spending its money, et cetera, and it also talks about, what you do if you see an ad that doesn't have a disclaimer, but it is promoting a san francisco candidate or measure, and it provides our office phone number it says to contact the enforcement division for potential disclaimer violation. we see this as an important way to help the public, especially those who might not be aware of campaign-finance law, and the general structure of for sixties and committees, to help them have some kind of entry point into this world, it is straightforward, it instead of

containing a single webpage, it is tailored towards electronic media users, people who are maybe not watching t.v. or radio , but who are really tuned into social media and e-mail and that kind of stuff, we think this will be a huge step forward , and we will monitor the traffic on this site. hopefully we will get feedback from people, but we think this is a good way to make some progress in this area, i would like to thank brian for taking the lead on that project, but with that, i'm glad to take any questions that you might have, otherwise i think i'm done. >> any questions from commissioners? commissioner lea? >> quick question, can i assume that the paid online communication section is going to be translated into different languages that you already have on the website? >> we have not had that page translated yet. it is something that we could definitely look into.

are there particular languages? >> i was strongly suggest the chinese language be translated -- i mean chinese be included in this. a lot of the adds are popping up in chinese social media. >> okay. i will look into that. thank you. >> public comment on this stuff policy report? being none, agenda item number 7 , discussion of stuff enforcement including an update on various programmatic and for some programs and activities since the last month's meeting. >> thank you commissioners. i am pleased to be with you today. this month's report highlights some changes that the commission is making in this, investments that i think will pay significant dividends in the

division's ability to fulfil its mandate and to bring a resolution. it matters that we're continuing we are continuing to identify with you as being of april -- particular priority to this commission. specifically the commission invested money to send two of our senior investigators to a training at the end of april. that training took place in new orleans and it was hosted by an entity at the center executive branch, the federal council on inspectors general. of jeff and thomas were there in new orleans, surrounded by federal investigators who work in the various offices, in addition to a small number of individuals who work in local jurisdictions. they received training from the u.s. department of justice including the public integrity

unit, as well as attorneys from the u.s. office of government ethics, and presentations cover legal issues and public corruption, campaign-finance, and other issues. as i said, we are in the process of identifying this. i think if you were to speak to the investigators, what they would tell you is that what was most useful to them, and heartening to them, was the amount of time they spent learning through case studies, and that is a process of hearing how investigators at the federal level brought a case from complaint to resolution, it gave them a lot of insight into the work that they do on a day to day basis, and it also inspired them to think, maybe even with a more clear headedness about the kinds of complaints that the commission should convert into

open investigations, and also it is a way that the commission might focus the use of its investigative resources in investigating something that they have converted into an open investigation, which is bringing a particularly acute awareness of the allegations at the core of the complaint, and really focusing on this particular allegations, or the allegations that you are most likely to prove. i would encourage you, if you have an opportunity to catch those investigators and hear firsthand about their experience in new orleans. in terms of professional of element, the division was fortunate to receive a briefing for a senior investigator about the kinds of tools that are available to the division for conducting what we call -- it is

to apply the methods and tools of auditing to a particular complaint that first elected campaign finance law. it is a mini audit that targets the specific allegations, or targeted to, say luminary evidence that we believe could indicate unlawful activity. i know already air expend several years with the commissioner as an auditor. he was able to draw on his expertise in helping the rest of the team to understand a little bit of tools are available to us when we dig in on certain kinds of campaign-finance violations. the report, as always, provides

an update for you on statistics. i would note that remaining in preliminary review now are -- equipment failure. remaining in preliminary review are 57 matters, down from 75 last month. that is still more than we had this time a year ago, but we are moving back toward where we were at a time before this city hosted two elections within a single calendar year. we temper the amount of time that it takes us to complete on average those preliminary reviews. you will see that we are still hovering around seven and a half months to evaluate whether the commission has jurisdiction or intends to invest -- do investigative resources into the complaint. we are heartened that the number of matters that the

investigators has to review is diminishing because that means that we have more research opposed to triaging. we do still have a pretty hearty number of investigations on the division docket. we have 88 as compared to 87 last month. on average, amount of time that it is taking the vision to get through a particular investigation and bring all the way to resolution, whether that is securing a settlement or closing it in the interest of justice or determining that the evidence suggests that there is not probable cause, to still still hovering just under 15 months. the commission science collection officer continues to work to collect late fees that the commission has assessed finance context. i think i reported to you last month that she was beginning to

prepare or had already prepared the first round of warning letters to people with outstanding late fees. she has now sent to rounds of warning letters to filers and is preparing a third round even now she has also collected a substantial amount of unpaid late fees in the process. she has referred four delinquent filers to the bureau of delinquent revenue, which the charter requires the commission to do when somebody owes money to the commission and has declined or received a payout. we will continue to make those referrals as filers from the second round and third round remained delinquent. not a lot of movement on the efforts of p.d.r. to secure payment on the five matters before them that we have reported to you every month, and

in particular, the matters involving chris jackson have not really moved, nor the matter involving jaclyn norman. the bureau is trying to sue. they know they have intend to file a lawsuit letter to all known addresses of that individual, but what that means is they don't know whether that individual actually occupies those addresses or will receive those letters. they are exploring ways to process on her, and then i would note that regarding the sweet, which is the largest of the outstanding fees that arose from -- he will remember a hearing on the merits against that respondent, the note here indicates that there is litigation that the city is filing against and there was to have been a case management program today. i spoke with an attorney from

the bureau today and her update is that the case management conference has been continued, meaning postponed to august. to allow additional time for breathing. i can report that the bureau has had direct conversation with her she exists. she is alive, she is ready to be engaged with. we will have to make some decisions going forward about what kind of process the commission wants the bureau to engage in, including whether we would permit the bureau to settle that matter for less then the amount of penalties that people have set forth, which is the combination that -- which is a conversation we can have in the future. >> can i ask a quick question? it is in bankruptcy court, isn't that what the proceeding is? i will be surprised if the city

can settle with her outside of encrypts he court. >> it says here the bankruptcy has been dismissed. >> oh, i didn't see that. >> i think she fell twice for bankruptcy, at each time it was dismissed. i believe she did not adequately follow up on her own filing. i can double check what i received from the bureau recently, but i believe i received a complaint from the bureau the day they filed superior court, but i will double check on what kind of litigation that is and what the status is. >> i guess the note is unclear. they set case management for bankruptcy, which is inconsistent with what is in the previous page. if you can -- when you bring it back, if we can talk about exactly what the procedural status is.

>> i will, thank you for the question. and then, lastly i would note we have included this month, a third attachment that has not been traditionally part of this report. this attachment provides greater perspective on the remainder of the statistics that we reported to you on the basis, so ordinarily what you would get in attachment one and two is a breakdown of the age of matter review, and under investigation, and the kind of matters that those are, and then the statistics near the top of the report, which compare current stats to the prior month, and to the prior year. but we have in attachment three is a snapshot of the data that we started collecting three years ago. what you