Accepting Travel Expenses
What are "travel expenses"?
The Ethics
Ordinance (PDF: 76K) 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?
Restrictions on travel expenses prevent outside interests from exercising, or appearing to exercise,
an improper influence over City decisionmaking.
May I accept travel expenses from a restricted source?
High Level Filers and Local
Code Filers may not accept travel expenses from a restricted source. It
is also unlawful for a restricted source
to offer travel expenses to anyone who is a High Level Filer or Local Code Filer.
May someone pay for me to fly to a conference where
I'm giving a speech?
It depends on the purpose for the trip. A City Official may accept a payment for travel if (a) the travel
is 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 gift limits, they are reportable on the
official's Statement of Economic Interests.
May a 501(3) nonprofit organization pay for me to fly to a conference that is
related to my City duties?
Yes, a City Official may accept a payment for travel if (a) the travel is 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 gift limits, they
are reportable on the official's Statement of Economic Interests.
May someone pay the City for my travel expenses?
Under certain circumstances, Local Code Filers traveling on City business are not receiving a gift when
another entity makes a payment to the City for their travel expenses. (This exception does not apply
to High Level Filers.) Payments to the City for a Local Code Filer's travel are not reportable on the filer's
Statement of Economic Interests form, but are reporatable by the City on an FPPC Form 801.
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 $500 contribution limit and must be disclosed as a contribution in accordance with the San Diego Elections Campaign Control Ordinance and the Political Reform Act of 1974.
May my campaign committee pay my travel expenses?
Yes. You may use your campaign funds to pay for campaign-related travel expenses
incurred for transportation, lodging, and food.
I still have questions. How do I get help?
The Ethics Commission is available to provide telephonic or written advice regarding these matters.
