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Officeholder Committees

  • About Officeholder Committees

    An officeholder committee is established by an elected City official to help the official carry out duties related to holding elected office. Each officeholder may control one officeholder committee, which is funded by private contributions and subject to the fundraising limits discussed on the reverse of this brochure. An officeholder committee is also subject to spending limits and may use its funds only to pay for the following expenses related to City business.

  • Allowable Expenditures for Officeholder Committees



    About City-sponsored events, government services, legal requirements, or the officeholder’s position on a City matter.

    Ads and Testimonials
    In the performance of City duties. May not support or oppose a candidate or ballot measure.

    Consulting, research, multi-media, polling, and similar services.



    Meetings, meals, conferences, receptions, etc. attended by the officeholder or staff in the performance of City duties. See details below.**

    To 501(c)(3) organizations when most of expenditure can be deducted for federal income tax purposes.

    Of congratulations, appreciation, or condolence for constituents, employees, and others with whom the officeholder interacts in an official capacity. Up to $190 per person, per event in Fiscal Year 2023-2024.



    Of officeholder committee staff. May not be used to supplement compensation of City employees for City duties.

    Equipment, furnishings, supplies, and rent.

    To honor or thank the officeholder’s staff or for office holiday celebrations.

    For the officeholder committee.

    Related to events. See below.**



    Course or seminar to maintain or improve skills used by the officeholder or staff for City duties.

    Of the officeholder or staff in professional organizations for governmental or legislative purposes. May not be used for fraternal, veteran, or religious memberships.



    Accounting, legal, and administrative services provided to the officeholder committee.

    Liabilities incurred by the officeholder committee.

    Unforseen obligations related to the officeholder’s campaign committee that came to the officeholder’s attention after the committee was closed or redesignated.

    Similar expenses may be permitted if the officeholder receives advice from the Ethics Commission permitting the expenditure before incurring it.


    --Expenses related to events may include materials, registration, and admission; transportation to and from the event; food and beverages during the event; and lodging, food, and beverages the day before, the day of, and the day after for attendee and immediate family, if attendee cannot reasonably be housed at home.

    --For an event officially hosted or sponsored by the officeholder, expenditures may include site fees, ad brochures, invitations, materials, equipment, services, refreshments distributed to attendees, and other incidentals.

    --Admission to a political event is a permitted expense only if: 1) the expense does not support or oppose a ballot measure or a candidate for elective office; and 2) the officeholder, officeholder’s immediate family, household, staff, officeholder committee, and officeholder committee treasurer are not personally benefitted by a substantial part of the proceeds.

  • Per Person Contribution Limits

    An officeholder committee established by an elected City official may not accept from another person more than the per-person campaign contribution limit for that office. This limit applies per fiscal year and is adjusted annually to reflect changes in the Consumer Price Index (CPI). During Fiscal Year 2023-2024, the per-person limit is $900 for committees established by City Council members and $1,800 for committees established by the Mayor, the City Attorney, or the Controller.

  • Fundraising and Spending Limits

    During Fiscal Year 2023-2024, an officeholder committee that is established by a City Council member may not raise or spend more than $126,000. An officeholder committee established by the Mayor, the City Attorney, or the Controller may not raise or spend more than $202,000. These limits are updated annually, to reflect changes in the CPI.

  • Disclosure

    Officeholder committees are required to publicly disclose their financial activities. They must periodically file California Form 460 to report their contributions and expenditures, with additional details required by City law. Reporting is typically required quarterly, but more frequent reporting is required when the officeholder is a candidate in an election.

    An officeholder committee must also disclose the communications that it distributes to 200 or more persons. The communication must include a disclaimer that states, “Paid for by [name of committee]. Additional information is available at” In addition, the committee must file a copy of the communication, including color copies of paper communications, audio files, video files, and scripts. The copy must be filed within five business days (or, once the officeholder has filed a “Declaration of Intention to Become a Candidate” with the City Clerk’s office, within 24 hours) after the communication is first distributed. Form 460 and officeholder communications must be filed online via the Ethics Commission’s Campaign Electronic Filing System.

  • Prohibited Spending

    Officeholder committee funds may never be used in the following ways:

    • To support or oppose a candidate or a ballot measure.
    • For membership in an athletic, social, fraternal, veteran, or religious organization.
    • To supplement the compensation of a City employee for performing City duties.
    • In violation of CA Government Code §§ 89506 - 89522.

    An officeholder committee may not be used for campaign purposes. To avoid the perception that an officeholder committee is engaging in campaign spending, some of the officeholder expenditures that are ordinarily permitted become prohibited when the officeholder is seeking re-election. From the date the officeholder files with the City Clerk’s office a “Declaration of Intention to Become a Candidate” through the election, the following expenses are prohibited:

    • Communications that are distributed to more than 200 persons or contain the officeholder’s name or photograph (unless the officeholder’s name appears only as part of an email or Internet address or only once on a letterhead or envelope).
    • Advertisements and testimonials.
    • Consulting, research, multi-media, polling, and similar services.
    • Admission to political events.
    • Costs associated with other events, unless the event is attended primarily by the officeholder’s staff for official City business.
  • Compliance

    An officeholder committee is subject to a mandatory audit when the officeholder’s campaign committee must be audited.

    Anyone who violates a provision of the laws regarding officeholder committees—or aids and abets another person in a violation—may be liable for administrative enforcement penalties of up to the greater of $5,000 per violation or three times the amount of money at issue.

This is a brief overview of the laws regarding officeholder committees. Please contact us for more information about how the laws apply to you or to report a possible violation.

Ethics Commission