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Enforcement staff outline plan to expand fixed‑penalty program into streamlined administrative resolution process

San Francisco Ethics Commission · December 14, 2020
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Summary

Enforcement staff presented a draft Streamlined Administrative Resolution Program to speed and standardize penalties for enumerated campaign and disclosure violations, with stakeholder meetings and draft regulations to follow before a return to the Commission.

San Francisco Ethics Commission enforcement staff on Dec. 14 outlined a plan to expand the city’s 2013 fixed‑penalty policy into a broader Streamlined Administrative Resolution Program (SARP) intended to accelerate resolution of certain enumerated violations.

Jeff Pierce and senior investigator Eric Willett described SARP as a staged process: intake screening, eligibility assessment by a SARP administrator, corrective actions (such as filing or amending required reports), application of resolution guidelines (including confidential warning letters and penalties), and, when necessary, referral back to the mainline investigative program. The aim is to provide predictable outcomes for routine violations, reduce negotiation time and free investigator resources to pursue higher‑priority matters.

Willett said the SARP administrator would have discretion to issue confidential warning letters for minor violations or to propose stipulated settlement agreements for commission approval on consent. If respondents decline liability or refuse settlement, the case would return to the mainline program for a standard investigation or possible hearing on the merits. Staff emphasized that public case resolutions will continue to be posted on the commission’s enforcement web page when a stipulated agreement is adopted.

Commissioners supported stakeholder engagement and asked staff to circulate draft regulations and hold stakeholder meetings in January before bringing a formal proposal back to the Commission. Commissioner Chiu asked whether “parking‑ticket” style automated handling of late filings and other time‑stamped violations could be included; staff said late‑fee processes already exist and SARP templates could include streamlined forms and correspondence for common scenarios.

No vote was taken; staff said they will distribute draft regulations and schedule stakeholder meetings prior to a formal action in early 2021.