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FPPC details Streamline eligibility and penalty tiers for common campaign violations
Summary
Legal and enforcement staff outlined how the Streamline program applies to late filings, unreported contributions, ad-disclaimer errors, cash contributions, bank account violations, recordkeeping, contribution-limit breaches and behested payments, with illustrative hypotheticals and penalty ranges.
Senior Commission Counsel Theresa Gilbertson and Commission Counsel Jonathan Rivera presented Part 2 of a multipart briefing on the FPPC Streamline program, drilling down into how the office applies eligibility factors and penalty tiers to specific campaign violations.
Gilbertson said each violation category has defined eligibility factors that guide whether a case receives a warning letter, a prep offer, a tier 1 or tier 2 streamline stipulation, or must go to a mainline stipulation. Examples covered included late campaign statements, unreported contributions or expenditures, committee-naming errors, advertising disclaimers and placement, cash contributions of $100 or more, campaign bank‑account use, recordkeeping, contribution‑limit breaches, and late behested‑payment reports.
Why it matters: Streamline is the FPPC’s process for resolving…
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