B. C. Matthews, the commission’s Director of Enforcement, told commissioners on Nov. 8 that an investigation found eight counts of campaign-finance violations involving transfers from a ballot-measure committee to the Mark Farrell for Mayor 2024 candidate committee. Matthews said the law imposes a $500 contribution limit for candidate committees and that certain payments lacked ‘‘full and adequate consideration,’’ meaning the transfers should have been treated as contributions. The enforcement division calculated the series of prohibited contributions at more than $93,000, excluding refunded payments.

Matthews said the case was brought to resolution before the election ‘‘so that the public would have the information about these violations when it mattered most.’’ She credited senior investigators Jeff Zomolt and Zach Damico for conducting and supporting the investigation and thanked David Lazarus, counsel for the respondents, for working with staff on the settlement.

Commissioners pressed staff about the factual basis for a previously stated fifty–fifty allocation of shared expenses and about a July 2024 memorandum from the respondents’ compliance counsel that claimed staff time had been tracked. Matthews said the investigation did not find tracking to support the fifty–fifty allocation and that the commission discovered the July memorandum during the investigation; staff said they had not been told of that representation earlier. Commissioner Salahi flagged that, if knowingly false, the memorandum could raise issues under professional-conduct rules and suggested the commission consider referrals to the state bar or other authorities; Matthews said staff would take that feedback and follow up as appropriate.

After public comment, the commission moved and seconded approval of the proposed stipulation. A roll call recorded the three present commissioners voting in the affirmative and the motion passed unanimously.

The stipulation, as described in the enforcement presentation, names the Mark Farrell for Mayor 2024 committee and the associated ballot-measure committee, and identifies Roy Herrera as treasurer for both committees; the enforcement director said there is no personal liability for Herrera in his capacity as treasurer. The commission’s action was recorded as an approval of the staff-recommended stipulation; the full text of the stipulation and the commission’s formal order are part of the official meeting file.

Next steps: staff indicated they may consider referrals to other authorities based on the investigative record; no further action on this agenda item was taken at the meeting.