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Accepting Travel Expenses

What are "travel expenses"?

The Ethics Ordinance (PDF) defines "travel expenses" to mean any "reasonable payments, advances, or reimbursements for travel, including actual transportation and related lodging, food, and beverages."

Why are travel expenses subject to regulation?

Travel payments may confer a personal benefit on the City Official who is travelling. Restrictions on travel expenses prevent outside interests from exercising, or appearing to exercise, an improper influence over City decision making.

Is there a limit on how much someone may pay for my travel expenses?

As a general rule, travel payments from a reportable source are considered gifts, subject to the $460 gift limit. There are some circumstances, however, in which travel payments aren't gifts, or aren't subject to the gift limit. For example, travel expenses paid by the City of San Diego or by another government entity for inter-agency programs are not treated as gifts. In other cases, when a City Official provides equal or greater consideration in exchange for travel payments, those payments may be treated as "income" instead of a "gift." Consult the Ethics Commission for additional information.

Is there an travel exception for when I give a speech at a conference?

If travel payments are a gift, they will not be subject to the gift limit if the travel is (a) reasonably related to a legislative or governmental purpose, or to an issue of state, national, or international public policy, and (b) the travel is in connection with a speech given by the official. Although such payments are not subject to the gift limit, they are reportable on the official's Statement of Economic Interests.

Is there a travel exception for when the donor is a 501(c)(3) non-profit organization?

If the travel payments are a gift, they will not be subject to the gift limit if the travel is (a) reasonably related to a legislative or governmental purpose, or to an issue of state, national, or international public policy, and (b) the payment is provided by a governmental entity, an educational institution as defined in the Revenue and Taxation Code, or a 501(c)(3) nonprofit organization. Although such payments are not subject to the gift limit, they are reportable on the official's Statement of Economic Interests.

May someone pay the City for my travel expenses?

Under certain circumstances, City Officials traveling on City business are not receiving a gift when another entity makes a payment to the City for their travel expenses. For this exception to apply, the City (not the donor) must determine which City Offical should use the travel payments. Such payments are not reportable on the filer's Statement of Economic Interests form, but are reportable by the City on an FPPC Form 801. Contact the Ethics Commission for additional rules relating to this exception.

I am a candidate for a Council office. May I accept travel expenses for campaign activities?

Yes. A person may pay for transportation, lodging, or food expenses that are directly related to your campaign activities, such as attending a political fundraiser, participating in a candidate forum or debate, making a speech at a voter gathering, or attending a meeting with campaign staff or political consultants to develop or implement campaign strategy. Acceptance of these expenses do not count against the gift limit, but the payment of these expenses are subject to the City's $550/$1,050 contribution limit and must be disclosed as a contribution in accordance with the San Diego Elections Campaign Control Ordinance and the Political Reform Act.

May my campaign committee pay my travel expenses?

Yes. You may use your campaign funds to pay for campaign-related transportation, lodging, and food. Note that you must keep detailed records regarding such payments, and must report these payments in detail on your campaign statements.

I still have questions. How do I get help?

The Ethics Commission is available to provide telephonic or written advice regarding these matters.