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Campaign Disclosures for Lobbyists

This Frequently Asked Questions page contains answers to many of the questions that the Ethics Commission has received relating to the disclosure of campaign contributions, fundraising activities, and campaign services. For more information concerning the Lobbying Ordinance, please visit the Lobbyist portion of our website or refer to our lobbying-related Fact Sheets.

How long do I have to disclose my 2012 fundraising activities?

If you are an owner, compensated officer, or lobbyist of a Lobbying Firm or Organization Lobbyist, then basic information regarding your 2012 fundraising activities must be provided on your firm's or organization's 2013 Registration Form. That fundraising information must also be reported on the 2014 Registration Form if the fundraising took place within two years of the date the Registration Form is filed. For example, if you engaged in fundraising activity in June of 2012, and your firm or organization registers in January of 2014, then your 2012 fundraising will have to be reported on the 2014 Registration Form.

Do I have to report the fact that my name was added to a host committee for a campaign fundraiser if I had only a limited role in inviting guests to the event?

Yes, if the event resulted in $2,000 or more in contribtuions. The Lobbying Ordinance requires that owners, compensated officers, and lobbyists report their "fundraising activities" even when they did not direct or control the solicitation or collection of contributions. Because you were a member of the host committee, you had at least some degree of responsibility for all of the contributions collected in connection with the event. Note that the quarterly reports include a box that can be checked to indicate that you were only one of a number of persons involved in the fundraising activity.

I contributed $1,000 to support a candidate for City Council, but gave the money to an independent committee, not to the candidate. Do I have to disclose it?

Probably. Each contribution of $100 or more that is made to support or oppose a City candidate must be disclosed on a quarterly report (Schedule C) if it was given to the candidate or to a committee primarily formed to support or oppose the candidate. Only if the contribution was made to a "general purpose recipient committee" will it be exempt from disclosure.

My firm registered me as a lobbyist, but I haven't lobbied anyone yet. Does my firm need to disclose my campaign contributions?

Yes. The firm must disclose the campaign activities (contributions, fundraising, and campaign services) for all of its lobbyists, even the ones who have not yet had a lobbying contact.

My firm has offices throughout California and in several other states. Do I have to keep track of the campaign activities of all of the firm’s partners?

The Lobbying Ordinance requires the disclosure of fundraising activities and contributions by any owner, compensated officer, and lobbyist of a Lobbying Firm. This requirement applies to the firm’s equity partners regardless of where they are located. In the event that an out-of-town equity partner engages in fundraising activities for a San Diego candidate or makes a campaign contribution to a San Diego candidate, such activities will have to be reported on the firm’s disclosure statements.

Do campaign contributions need to be reported on a Registration Form?

No. Campaign contributions are reported only on the Quarterly Disclosure Report, and only if the contributions were made during the quarter covered by that report. This requirement is different from the "fundraising activities" disclosure, for which relevant information must be reported on the Registration Form and the Quarterly Disclosure Report.

I am an uncompensated officer of an organization lobbyist. I also lobby City Officials on behalf of my organization. Are my campaign activities reportable?

No. All uncompensated officers, including those who contact City Officials, are exempt from disclosing their fundraising activities and campaign contributions.

I am a partner in a Lobbying Firm. I also have my own business providing professional fundraising services directly to candidate committees. Does the Lobbying Firm need to disclose my professional fundraising services?

Yes, but keep in mind that the disclosure will be made as "campaign services," not "fundraising activities." In other words, the Lobbying Firm will disclose on its Registration Form (Schedule C - Part 2) the compensated campaign services you provided to elected City Officials within the previous two years, and disclose on its Quarterly Disclosure Report (Schedule F) the compensated campaign services you provided to candidate-controlled committees during the quarter. On the other hand, even though your services are related to fundraising, they are not "fundraising activities" for purposes of the Lobbying Ordinance. The Lobbying Firm, therefore, is not required to disclose your professional fundraising services on Schedule C - Part 1 of its Registration Form or on Schedule E of its Quarterly Disclosure Report.

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