Changing the mechanism on what happens. We within the to change it so the sort of agency dealing with each individual contractor including grantees have to require the notice. Wed have to reach out to each individual board and commission and letting them know they are required to do this through the contracting process through rfps and rfqs, we have to do that process, but were changing the mechanism that exists. Contained in that notice provision to the Bidding Company whether its a forprofit or nonprofit, then it would be incumbent on them to notify the boards or investors that theyre subject to the requirement. Correct again, the specifics of how or who receives the notice is not contemplated here and beyond the scope of the ordinance. The agency would be required to notice those persons submitting proposals. Okay. So again just to clarify when we talk about city contracts, were talking about two different kinds of city contracts. Right . One is forprofit contractors architects whoever account in the private sector. The other would be what people call grants or things to provide a service to the residents of the city right . So if you say the agencies are required to notify the contractors of these requirements, i am assuming these agencies know they have to provide it to whether theyre private companies or cbos communitybased organizations. Is that your understanding . Agencies whether theyre health and Human Services or department of Child Protection services, they provide that to the potential guarantees . Again if we made the change, we are a direct the agencies to do so, yes thats what we would expect. But you said they already do that. Im saying there is currently a notice provincial which is different. Our notice provincial changed it so that the individual agencies dealing with the contractors on the sort of eye level, one to one level, that they have to do that notice. Right now the notice doesnt operate in that way and id have to get up to specific language to see how it works but it doesnt work that way. So im being informed by the attorney that currently its on the organization itself, that is the bidding organization to inform their board and key directors. Were changing that so that the agency has to do that. Were improving the process from what it currently stands. So i think ill just recap. Where we are is section 2c were discussing whether or not we want to now change the existing section 1. 126 as in current law to exempt undirectors of nonprofit organizations. We all realize this is now part of existing law that doing this is not currently in the ordinance, were talking about adding Something Else in the ordinance that would essentially say that the definition of contractor does not include this class of persons and reason for this would be that theyre different than other contracts with forprofit companies that are making money that nonprofits dont make money. Unpaid directors dont have a financial incentive and therefore the risk of corruption is lessened. That is the argument for this particular proposed change to existing law. Just trying to recap where you are on c to distinguish that. As i understand, the staff recommends against that change. We would a pose oppose the change. I think jessica did a good job of describing this. The corruption issue is still there. Even though a director of a nonprofit may not be financially compensated there are benefits to win for that organization. They join the organization to be an advocate for it and to seek to bolster it and to have it be successful. Part of that may be to seek city grants. There is still an incentive for someone to pursue a city grant to the organization on which they are an unpaid director. Since that incentive exists, we believe there is a danger of corruption and they should not be allowed to make contributions to official whose may approve their grants. In a similar situation where a forprofit companys director would not be allowed to do so. We see no reason for that distinction. I think that ill continue to run through the memo. I think that would be helpful to give everyone a lay of the land, and then perhaps after do so, the commission can go back and address each individual section. Where are you now . I propose remove to Section Three which begins at the top of page three. This corresponds to 1. 127 the new code section similar to 1. 126 on 1. 126 operates would ban contributions by such parties to an official who has discretion over that land use matter. Operates in a similar way. The slang similar. Were talking about a different class of individuals. This code section in the ordinance has been a point of contention. One policy question is whether or not this section should be removed from the ordinance. One reason for doing so that has been offered is that there arent sufficient cases or there is insufficient evidence indicating that this class of persons parties with the financial interest in a land use matter is sufficient evidence that they do, in fact make political contributions to the city officials who have discretion over the land use matters and therefore this prohibition would be unnecessary. The position of the staff is that we would not oppose removing this although we do think that there is sufficient evidence to support it. There would be a significant challenge to enforcing it because of the nature of the contracting sorry the lappeduse decision pros Land Use Decision in the city. And it would be difficult to track this and enforce upon violations. All o though we think it addresses a concern, we leave it to the commission whether or not to strike this decision from the ordinance. What falls within the definition of a landuse matter . If somebody is applying for a building permit, is that a land use matter . That would be a land use matter. Can i want to point you to exactly that section. One moment. What happened to the term Public Benefit . So i think that term was used in the original proposal. That is based on prop j. I think that weve moved away from that term because of how broad it is that weve been trying to focus on specific classes of individuals rather than such a broad class. That persons with a Public Benefit that could include many parties that dont pose a risk of kruks corruption and a risk of corruption. Staff may have but i havent. To answer commissioner rennes question, land use matter is deched if you look at page three, its the second defined term. Land use matter is an elected officer for a planned Code Amendment or entitlement that requires a public hearing before a board or commission under the planning code or Environmental Quality act. Lapped use maryments shall not include land use matters shall not be under this. We talked about the citywide process for Land Use Decisions and this is language that we developed with them that together we thought encompassed where there was a greater use of kruchtion. Corruption. Its an effort to hone and target specific decisions. Youre saying you wouldnt if i understand you youre saying that you wouldnt oppose eliminating it, yet that seems to be the classic example in this city of where the public views the corruption to be the greatest. Well, if i may were only prohibiting a 500 contribution ban. Its 500, the developers or any other companies would still be able to make contributions to an independent Expenditure Committee or ballot measure committee. We cant touch that through this ordinance. What were talking about is they cant give the 500. Just if i may quickly, to reiterate that point the sort of main case from the Second Circuit that the proponents rely on for this is called the parch case. In that case, they took a limit in new york city which i want to say around 1500 more most parties. For most parties. They reduced it to 500. Were talking about a limit versus a ban and a single case that has said that that was, this was another class of persons other than lobbyists and contractors who should be subject to this sort ever ban. Sort of ban. It reinforces. Youve convinced me. Id like to move on to section four. This pertains to Civil Penalties in sit sewn suits found in 1. 170. Essentially, existing law already allows right now citizens of the city to bring a civil suit to enforce a violation of the Campaign Finance reform ordinance, if the city declines specific the Ethics Commission and City Attorney decline to do so, what is proposed currently in the ordinance is to allow such persons in the suit to pursue penalties. This is brought by a private citizen. It can only seek an injunction to have the court force the party to stop the violation. But as is the ordinance would then allow them to court to impose a civil penalty as we impose the penalties in our proceedings. Additionally if Civil Penalties are awarded and collected after a citizen suit, then the theyd beentitled to 50 . Id like Deputy Director bloom to speak on this since this is regarding enforcement matters. I think, yes, so staff would not oppose removing the civil penalty commission from the corruption ordinance. You heard Public Comment ex comment from members of the public last meeting who were concerned that it might operate as an increased incentive for frivolous or litigation designed to harass people. Staff would not oppose this change. So. If i can have one clarification. All were saying that obviously there is a citizen suit provision in the law. We would just strike the portion that awards 50 of any penalty which to that individual moving it back to an injunction cost and attorney fees. I would be in support of that because the private plaintiffs currently has the right to sue for injunction relief. If there is a Campaign Finance violation, if the Ethics Commission and City Attorney and d. R. A asleep at the switch a private citizen could come forward and sa candidate x, you need say that candidate x, you need to put the disclaimer in and file how much money youre spending and who is contributing to your campaigns and paying for the mailers. I think under no circumstances would a private plaintiff be entitled to seek damages under any theory at this juncture. The private plaintiff wouldnt have suffered any monetary damages either. I think that it, from a policy standpoint, i dont think that we should be rewarding or giving an incentive to plaintiffs to recover something that they would not otherwise be entitled to. Mr. Chairman, you have removed the Civil Penalties from this section correct . Chairperson keane just part awarding 50 of any penalty. How do you get 50 of an injunction . Youve taken out a monetary award. And very few people want to spend money up front for an injunction on the thought that oh, well, ill recover all my attorneys foo fees. Fees. I object to deletion of monetary remedy for anyone who waits for the City Attorney to file an action and doesnt file, ive forgotten what you have in here. You dont have 90 days or anything you have that sort. And i suppose alternatively, you could allow Monetary Division with the plaintiff in the discretion of the court. Which i may advance. Between now and november. Miss bloom. Under existing law, plaintiffs awarded attorneys fees if they are successful. If they have a good case, enterprising private plaintiffs attorney would take the case because theyre going to be compensated by the government. 100 percent of the time they get the attorneys fee as wards paid. Its not a situation like in private practice whether it depends on whether the defendant is solvent. I understand. Good attorneys bring key tem actions because eventually theyll be compensated. Its a little different from that. I know its different, but i i annal jiezi put itto a key tem. In a private case where you deal with a private plaintiff and private defendant and government that is unwilling toability. In those cases, the environmental plaintiffs bar has Great Success used in injunctions absent civil penalty awards to change environmental law for the better. Im a huge pro opponent of citizen suits. I think theyre an important part of our tools in the tool box for enforcement you i am opposed to siferl penalties in this context. The defendant in these cases are attempting to exercise their political peach rights and its a different context from the runofthemill case. Ill suggest something mr. Larry bush furnished us a month ago with a 2013 memorandum from the City Attorney. About the number of ordinances in San Francisco and there were then eight which allow a private the right of action. I recommend that you bring that uptodate and id like a memorandum on that for all members of the commission. And then secondly, examine those with respect to whether there is a monetary award to the plaintiff or plaintiffs as the case may be. Ive listened to these cries of unfairness about a private right of action and i am not at all persuaded and particularly when i note the number of existing ordinances in San Francisco. And i wonder how those have operated. I havent heard any complaints about them, or read any complaints about them. One thing you want to notice with that memo is that most of the instances where they can invoke those there has to be injury in fact. They have to be harmed by it. Theyre not stepping in place by the government. Its an important distinction. Why shouldnt they be able to step in the shoes ever the government if the government doesnt enforce its own law . Ill leave that to you commissioner. You have a clue as to how ill vote. Id like to move on section five on page four. This is regarding board and Commission Member fund raising specifically this is section 3. 231 in the ordinance. Prior versions of this ordinance had a version of 3. 231 that would prohibit members of boards and commissions from Fund Raising Activities for their appointing authorities. The current version expands upon this rule to say that members of boards and commissions cannot engage in Fund Raising Activities for any city officer. So this is an expansion upon the rule and a policy question. Before the commission now is whether or not we should revert to the prior version. Whether or not 3. 231 should only prohibit members of boards and commissions from fund raising for their appointing authorities. One reason offered in support of this change back to the prior version is that there is not as strong of a risk of corruption when a member of a board or commission is fund raising for someone other than their appointing authority. So there no reason to restrict fund raising for all officers and there is not sufficient evidence indicating that such fund raising goes on or is problematic. Are there any questions about this section . No, no questions. If i think about this and i want to create a real life example say there is say i have been appointed to the Arts Commission or the Historical Preservation commission and so the original language of the ordinance would prohibit me from raising funds from the appointing official. You dont want to give the appearance that i got the job because i can raise money for the mayor. But what if the classmate of my sons parent is running for school board and i want to invite some of the parents from the class over to hear this person speak or invite my neighbors over and say i think that peter would be terrific on the school board. I would love to have, you know, neighbors come over and have some coffee on a saturday morning. Where is the corruption or the corruption effect there . What am i missing . I cant speak to that particular fact pattern but generally the idea behind expanding the rule from Fund Raising Activities for the fund raising authority and expanding it to all officials is that this doesnt occur solely in a relationship between two people between the board of Commission Member and the candidate for whom they are fund raising that perhaps they might fund raise for a political ally of their appointing authority or someone else within their party or someone who theyre aligned with and that might although they are not fund raising for the appointing authority, it might create favor for the appointing authority that theyre making contributions or creating Political Capital that is being exchanged within the system. Even though its not going to the appointing authority, it would be counted as a factor in that appointment or reappointment. Were talking about someones ability to engage in political speech. It could curry favor with an elected official but how do we balance that against peters ability to support this neighbor or, you know parent that he knows quite well in their campaign for school board. So i hear you, but im a little troubled by that. But lets keep, unless others have comments that we should keep moving. Okay. So move on to section six, this section corresponds to section 3. 20784 in the ordinance. This is the rule that would prohibit an official from asking someone who has a matter before him or her to convey anything of value to a third party. It covers behested payments and inkind payments that are goods or services and there are a number of policy questions on this item. The first one top of page five regards whether or not we should be focusing on the definition of anything of value. So should the commission limit the definition of anything of value it does not include volunteer services, the fact pattern here is an official asking someone who has a matter before her to take part in some kind of volunteer activity. Typically this would probably be a charitable volunteer activity. Some kind of community event. Staff doesnt oppose this, we see this as being a pattern that poses a lesser risk of corruption. We think this could be carved out of the definition of anything of value without weakening 302784. Second item should the commission add any exception for any behest during a Public Private partnership. An example would be a committee on Information Technology and this is an organization that is part of the city and that the city uses to engage private sector actors in Public Private partnerships obviously regarding technological needs. In this scenario,fo would be able to ask a Public Company to make for example, a donation to a city agency of computers or software. Even though that company has something before the official. So long as the official makes the request through in this hypothetical. This could be replicated in other agencies. The thinking here is that this presents a lessened risk of corruption because coyte and other organizations like this are subject to open meeting laws and that this isnt the kind of closed door secret request that would carry a risk of corruption. This would be open and people could see it. It benefits the city and that also its not made by a single individual. Its made by the body. So staff would not oppose making an exception like this in b. Moving on to c. Should the commission reduce the timeframe of the rule from 12 months after the person had a matter pending before the official to six months after the matter was pending. We discussed a similar issue with 1. 126. What should be an effective time period of rule b after the event that triggers the rule. The thinking here is that if 1. 126 were kept at six months, likewise 3. 20784 would work under a sixmonth window. These would apply concurrently if a person has a contract pending its approved these two rules would operate in conjunction. Again, staff would not be opposed to the change. We think the 12month period would be a more robust rule, however, if 1. 126 is kept at six months it would make stens to keep 3. 20784 also at six months. Moving on to d should the commission add an exception that allows officials to ask a person with business before them to make a behested payment as long as the payment goes to a 501c3 organization that provides direct services. This would be a Pretty Simple exemption or a pretty targeted exemption at the core of the rule. This is not working at a definition or time period, this is a carveout. That would allow a closed door request by an official to someone with a matter before them as long as that payment would go to a 501c3 Organization Staff does not support this. We think this would drastically undermine the purpose of this rule and in fact, we would prefer not to have the rule, not to have 3. 20784 at all if this exception were to exist because it would be such a big loophole it would make the provincial infectal infectal and inwe ineffectual. Anything of value can include an inkind gift good for services and include favors. It is a favorable broad term. Staff does not support limiting it only Cash Payments. There is a documented history of persons asked to give goods or services and these things can be directly reduceable to cash value. We believe these still present a ridiculous of corruption and we believe if this rule only applied to Cash Payments that people would instead of making Cash Payments or instead of asking for Cash Payments, theyd redirect their requests and ask for goods to be given and that likewise, this would undermind the operation of the rule. Moving on top of page 6 item f, should the commission remove section 3. 278 from the ordinance . This might be the most blunt fix to the disagreement over the pro viption vision. We dont provision. We dont for this. Staff does not support this. We dont think this is the proper way to resolve it. We hope that on some of the earlier points a through e the commission could find a way to change it in some way so the ordinants could move forward and it will not have to be removed. Lastly item g, should the commission remove section 3. 2784 from the ordinance and replace it, this creates a stronger sense of disclosure rule for behested payments. This is an argument thats been made frequently that instead of prohibiting officials from asking for behested payments or asking for other things of value to be given that we instead just have a disclosure regime that will bring this practice out into the open and allow the public and commission to at some future date evaluate whether or not there is a practice going on that is worth prohibiting in the first place and that this could be readdressed at a later time. Overall staff doesnt support this. Wed like to see 3. 20784 move forward as a sub substantive con thrict flict of interest rule but if the commission is unable to reach an agreement on 3. 2784 that to have mill restrictions would be better than not. Making any change regarding this practice at all. I would propose maybe that now since weve gone through the member memo now we can go back with a broader view of everything in the memo and maybe the commission could engage in a discussion on this specific section. Before we do that, letstlemen. [gavel] chairperson keane were back if session now. Well continue with the presentation relating to the memo. Weve had it from mr. Ford in regard to discussion like once again, id have commissioners chiu and lee to lead us that matter. So, where we left off was section lets see page 5, i dont have the exact section section 6. What chair keane was referring to at the top of the discussion. I think that for my benefit, it would be helpful to me to have a discussion about peter, what i heard you say was what is corruption . Is it the elected official in the making of ask in an of itself of someone who has a matter before the government . Or is it a quid pro quo where there is an ask by an elected official of a party with a matter before the government. And that the person receiving the ask then makes this contribution or a donation or something to a third party and then receives something in return. Chairperson keane it would not be a quid pro quo because you could see a situation where you have a particular official ask someone to make a donation and that person has a matter before that official and is making the donation purely because that official has put the arm on them essentially extorted it and that person goes ahead and makes the donation and the elected official says thanks very much but im not going to youre not getting this from me. I think you still have there the unethical aspect of the official using his or her power to have someone do something which is not on the merits and whether or not the official comes through and stiffs that person shouldnt make any difference. So the quid pro quo personally certainly is not necessary. May i interject, if the may or a member of the board of supervisors who has a duty to support the most vulnerable population in the city, lets say it that way. So if he or she asks somebody to support an event, not in front of five people or 20 people, support this worthwhile event to support kids to go to summer camp on what have you that person wants something. No. From the mayor or board of supervisors. Well what happens if that person happens to have an ongoing grant lets say if they have provided meal service for the last 10 or 20 years. But because of the appearance of a corruption, then that is a corruption in your mind. Even though there was no the person who is doing the asking should be doing that type of activity, trying to bring in resources to support Community Groups. If we agree on that one, and the Community Group not asking for anything else from the public official. Let me give you an analogy commissioner lee, because you made that argument the last time that essentially what it boils down to, if what the official is really asking for is going to be some really good thing its going to have all sorts of good effect upon the community, its going to have a good effect upon all sorts of things, but the official is in a position relating to the person that theyre asking for it to do something for that person and the official still asks for it, that is the official using his or her power to get someone to do something that they would not otherwise do or that they would be expecting the official to do something for them whether they do it or not. So it really doesnt matter whether its something. Simple example, i rob a bank and get a bunch of money and give all the money to Cancer Research. As a result of that, my giving that money to Cancer Research finds a cure for cancer and there is no canceler in the world. I say, you know, listen there shouldnt be laws against bank robbery, look at what i did. Look at the effect of that. That is sort of the oversimplistic analogy to the idea if it reats something good, therefore if it creates something good it validates it. Commissioner lee or someone with a Long Term Plan maybe 10 years from now has nothing before this official or next 12 months, agrees to give the money. Chairperson keane its not it doesnt matter whether they agree or not. We dont care whether they agree or not. Its the fact what were pro mibting is the prohibiting the official from asking that person to do something. Commissioner lee if that person doesnt have anything officially before that body chairperson keane thats fine. But we are sort of punishing all individuals who have something whether its innocent or what just because they have something before the body which includes a majority of the nonprofits because they get grants and contracts from the city which ultimately is decided by the board of supervisors and the mayor. So because of that, the public official would not be able to ask either their philanthropist or Business Community chairperson keane no because they the public you have someone who is a developer. Wants to have a permit for something. And that is before the mayor or before the board of supervisors. The board of supervisors then asks that person, give to my favorite charity. By doing that, that official is using their power to get that person to do something. And the way it works in terms of . San francisco, the mayor or board of supervisors comes through for that person. What happens then systemically is that the decisions are not made on the merits. Decisions are being bought. Thats what were trying to address. Were trying to address that underlying prevalent corruption that you have in San Francisco that comes from those things. And the fact that you say well its going through this organization that provides wonderful stuff for people. That the mayor or the supervisor happens to like, thats still things are not done on the merits, theyre bought and paid for thats corruption. Thats San Francisco as it exists today. And that is something that we want to address. Its like soft corruption. Chairperson keane it is soft corruption but corruption nevertheless. Thats the reason of the proposition j as originally conceived. Commissioner lee i dont commissioner chiu i dont think youre making the argument that because of the rye accept yent that recipient makes it okay, the more narrow point i wanted to make is we talk about pay to play. A ban would eliminate all of that. But what i keep hearing is its the corruption because it is paying to get a result. Its paying to get the result. And in terms of the record, ive hearder toys about google, but we dont know what happened with google. We know that google has access to the stocks and google made a contribution of x number of dollars to fund muni passes for youth. How did that come about . I dont know that we have those facts. Was a solicitation by an elected official . Or did google come and said wed like to work out something with you to be able to have access to the bus stops so we can run the shuttles to our headquarters. How can we work something out . Whichful that were the case, i dont know that our ordinance would prerent it. Chairperson keane it wouldnt and we wouldnt want to prevent it because then you have google on its own doing good acts. Wonderful, we welcome that. What were saying is officials in position of power dont put the arm on and extort particular entities like google or airbnb or whoever it might be to pay something in order because they expect to get something that is before you. To me, thats just a basic desire to have a noncorrupt government. And its something that in regard to the prohibitions bens past payments, i think the staff has told us that so many other places have that these prohibitions against past payments that San Francisco is an ought law by not having them. Kyle, could you address that, because ive heard something similar but i wanted to make sure were clear in terms of what the law as you currently understand it to the best of your research and belief at this point knows about the payments and regulations thereof. So, california is unique in the sense that it define what is these things are. Back in 96 or 1997 the state made a law defining these at the time, the original thing is they called them contributions and limited them. The state Legislature Said no, this is not a contribution we want to be able to do these things so require us to disclose this. So in terms of other places that do this im not going to pretend to say that other places dont allow this and dont call it past payments i think it would be naive to say this doesnt occur bl but there are rules against this. That isnt to say that there arent other jurisdictions that dont define it and dont allow it. California is unique in how they define behest. They call it out specifically as a different item rather than calling it a contribution or prohibiting on a conflict of interest bribery or tit tit for tat. Its not that california is the only state at that doesnt prohibit them but california has taken it and regulating it by requiring disclosure of behested payments over 500. I know no other state that calls them ought as asks for other parties. Thank you. So i think that in the different exceptions outlined here i think back, first is the policy question of where does the corruption lie. Is it in making the ask . Or when there is something exchanged like the pay to play. The quid pro quo. Then i think about what should an ordinance be. It should be clear. And a ban is clear. But it becomes less clear when we have a long list of exceptions. It it becomes, i think, harder for people to dot their is and cross their ts and make sure theyre doing what theyre supposed to do and not what theyre not supposed to do. Clarity and simplicity i think are to be valued here. And then from a regulatory standpoint, a ban obviously will be a prohibition, but we have a ban with exceptions. And then as an alternative, what we had discussed with staff was a disclosure regime a pro bust disclosure regime in part to get at that robust disclosure regime to ask where is the money going and what are they getting in he can change to shine a light on this soft belly of corruption. I dont think anyone in this room or on the commission would say theyre in support of corruption at all but in an effort to bridge the gap here, its a strong set of disclosure i think could serve as a deterrent if there they theyre going to be illuminated by a requirement of all their dealings and could give hard data for money spent contributed at whose request and what outcomes were derived during the matter before the governing body while the request was made and the payment was made. Mr. Chair. Chairperson keane yes commissioner lee. Commissioner lee i support the continuation of looking at the disclosure strengthening the disclosure position because so much has been talked about anecdotal stories and everything. We all understand that corruption exist and it happens. But this is a very serious piece of legislation that were looking at. It has profound impacts. And i still i think it would be helpful for us to look at what this actually is happening. What is the data . A couple of meetings ago a couple of folks were saying its the actual and appearance of corruption. I think actual, it would be good through the disclosure numbers. Let us take a look at wore where things came from and where theyre going as commissioner chiu says so we can have a good picture where things are and where we need to address it. In terms of the appearance, as an Asian American, appearance to me and many of my brothers and sisters can have a negative connotation. Back in 1996, because of the appearance that we are Asian Americans, were not actually not americans and viewed as foreigners. Therefore, we should not be participating in the political process. A group of Asian American political donors were singled out by the fbi for investigation. Many of my friends, we had to hire lawyers to defend our right to participate in the political arena. So appearance to me has to be backed up by facts. Has to be backed up by data to really warrant what were doing and why were doing things. As some of you know, i was appointed by the president. I was barred from going into the white house because the Security Guard saw me and saw me as a foreigner. Because of the appearance that he perceived me to be a foreigner therefore i had no right to go into the white house. Where the president appointed me to serve my country. I really look at this as not someone who is not supporting any type of anticorruption activities. In fact, i am thats why im here. But at the same time we need to really make sure how can we address this, how can we make sure that there are no unintended casualties because of a approach based on feeling and appearance that, you know, yes things are bad. But we need to know how bad it is. Where its coming from and how can we address that instead of saying that okay, here is the problem, lets address it and, you know, i just feel that we need to have the data we need to have the numbers to look at the Bigger Picture before we proceed in november december, when ever were going to take this up again. Wh wh okay so i guess as the kses so as the next point of process, i would propose a motion but give me a chance to clarify what im going to propose. So i would make a motion to i guess the right terminology would be to accept or agree with the recommendations in the staff memo with certain septions. Certain exceptions. I would move that we accept the staff memo except for the modifications and ill go by page . 8 number. So i would propose that we on section 2a would accept staff staff saying would not be opposed to the change. I would propose it would be that we would go with the original term of proposal of 12 months. That the threshold be increased to 100,000. I would agree with staffs recommendation there. For section c, i would propose modifying the provision on the directors of nonprofits to ensure and this may not be encapsulated in the ordinance itself. I would ask for staffs direction on that. But i would want to make sure there is a very robust provision in there, would be educated on their obligations. Section 3a, i think that i would go with my if we could keep