About them of whether or not from a technical and compliance perspective, if they thought that was feasible and what they highlighted is it is feasible but only if done in certain ways. The concern that they had is that on the 496, theres a section thats called park 2 where you actually list the independent expenditures and you do those in aggregate disclosure style. If you do a 10,000 mailing, one line item in part 2 says, june 1st, mass mailing. Cost 10,000. Thats one line item. What the treasurers flagged for us was that its not feasible to do separate line items in part 2 for each of the separate costs. Its not feasible to say june 1 printing of the mail, 400. June one, design of the mailers. That would not be feasible because that schedule is populated from information in that file and that information also feeds into a schedule on the form 460. The preelection statement. By requiring filers to enter into into the file that would produce that breakdown, that would disrupt their 460 filing and that would populate schedule d on the 460 which is a schedule of expenditures that support or oppose a candidate. That would populate that schedule and with that broken down information which is not sense cal on schedule d. They flagged for us we should not require that could be given in part two. What they suggested and what i think we will suggest to filers is that they do either one of three things. That they even provide the breakdown in the description, for each i. E. , so when you do a line item, on the 496, its possible to enter a description of the line item so this one, he made a specific example. This is that acceptable to you . That is what i was getting at. You dont need to know into the details. I commend them for their skill at filling out these forms but i dont think we have a policy discussion about that because i do want you to talk about the other definitional aspects and make sure weve got that right and there arent any unintended consequences or whatever sounds good. The bottom line is that i dont think any amendment to regulation 1. 1612 is needed. Filers will use the 496 and its the most feasible and i think ultimately the most useful way to have this information provided. Ok. Great. So i will go to the amendments at this point and talk about one amendment i do think should be made based on the response ive heard from stakeholders. Can you tell us who you talked to . I mean, not everybody that you talked to but most particularly since this was measures sponsored by the board or the boards legislative aids that they review it and the City Attorney get a chance to review the definitions yes. The City Attorneys office as and the people who propose the amendments all work with the regulated community to do the disclosures. So the amendments that they proposed are all in the nature of either technical amendments or those who clarify or correct things to make them more accurate. Ok. Great. The first mendment is to regulation 1. 1612. Is that the one we were just looking at . A treasurer asks that a cost estimate provision be added to this regulation. And if you look back on the previous page, in regulation 1. 161 you see the cost estimate provision and what this says is that even though you are required to disclose this information short lie after the communication goes out, you have to disclose the separate cost associated with it and if you dont actually know the separate cost yet, because maybe your vendor hasnt billed you for them. Its ok to put an estimate and to amend the filing later when you get the invoice and you know the separate costs. That is already in effect here for mass mailing disclosures and its something that also acceptable for the 496 so the treasure asked that we also institute that concept here with the 496 separate cost disclosure in regulation of 1. 162. I would recommend to break that regulation into two parts. The text in there rit now, just make that part a. And then add part b the cost victim provision for that proceeding regular. Just for the record, same as 1. 1611 sub section c you will make that same language and of 1. 1612 with some changes. I should read them right now. I read what i would suggest so its in the record the provision would say sub section b estimated cost of independent expenditure, period. Filers who do not know the actual costs associated with an independent expenditure when they file form 496 as described in sub section a of this regulation, may provide a good faith estimate, provided that they amend the form within 48 hours of receiving more information about the actual costs of the independent expenditure. Ok. How do you propose to move these amendments one by one or . I think i would leave that we dont have a written substitution, right. We have to im just trying to figure it out. What your system is for making clear how were going to move each one of them sure. They call this amendment number one . Sure. Ok. Three of them are in writing. Three of them are in Public Comment. Its in front of you. This is not so this is the this one is not. Ok. So, i think what id like to do is tell you the two that are not. First the two that i am just going to head into the record because it is not submitted to us in written form. For the three that were submitted to us in written form, you have that in front of you ok. Great. The second one is on page 8 of the agenda item under regulation 1. 1273. This regulation relates to the land use matter contribution prohibition. Theres a safe harbor that says if a committee gets a written attestation from a kin contributor saying the contribute or does not have a financial interest in the landuse matter if the candidate accepts a contribution from that person, the candidate will not be liable for the violation if it does turnout that the person in fact does have this provides language we would accept from a candidate in order to trigger that safe harbor so it gives them something to copy and paste and run with into their contribute orchard. Someone proposed we add clarification that this can be accepted in electronic form. That when it says in written, that does not mean a physical writing, exclusively it could include an electronic writing. The purpose is that a lot of contributions these days are received over the internet and they go on the website and they enter the credit card information and these as testtations, can you do it for contribution and prohibition as well, its a check box that someone clicks. So what i was suggesting is that these first line of the regulation be amended so that it says the candidate will meet the Due Diligence requirements of section 1. 127c if the contribute or certifies in writing in electronic format to the candidate at the time the contribution is made that the following is true. So ragged the words includinn electronic format. Correct. Can we call that amendment number two and then i wanted to ask you though, sta substantive, say this form comes up and you are making a contribution, the regs wont come up so i see people asking questions about what a land use matter is and whether or not the commissioner was asking and said if you are remodeling your bathroom you cant contribute to anyones campaign so is there some citations or link or something that people are going to find when they have to sign this attestation i sought to put the minimum of what we would im still thinking if were going to get a lot of frustration because theres a lot of people who arent going to be able to sign and wont attest to this because its so broad. Anybody that has had to rebuild the deck on their house has had a land use matter at the Building Inspection Commission right, because you have to get a permit for it so just trying to anticipate that and and the regs if someone can find it or then they could put a link in on the candidates website because well just confuse a lot of people and you will get a lot of phone calls. Im fine with that you get a lot of phone calls anyway. Im just trying to think out loud if you are looking is there some were all lawyers up there, is there a way you can give people a clue where they would go to figure out if they can check this box or not . Or do they just need to go back to the candidate . So, im hoping and kind of assuming that committees and their council are probably going to be tangling with us and developing their own approaches to how to best present this. Its fine if some kind of parenthetical is added as those terms are defined by statute and regulation. I think thats fine. I would probably advise against including those definitions here or starting to. You could reference the code amended, you know, they do define land use matter in section 1. 127 in prop f. That gives someone a towhold into where am i looking. I dont know if adding that just one little citation i mean im a lawyer and maybe im looking at citations and i know we need to do this today. Obviously, as this rolls out well get feedback and we can make improvements to make it more workable. Im sure a lot of people want to try and get this information from their donors at the outset because chief want to end up with the liability on the backside so i want to try and make it as you user friendly as you can. You do include the Building Inspection Commission in here and building inspection is usually just Building Permits so im trying to think of what discretionary entitlement comes in front of the Building Inspection Commission. Did you get any feedback on that from the folks you consulted . We talked with folks at the Planning Department to dig into all of the mechanics of this new co section. For the reasons that department and that commission handles the vast majority of land use matter as defined. I can tell you what we found is that 1. 127 is not perfect. It does not match up perfectly with how land use matterser dealt with in the city. What the regs endeavor to do is faithfully carry out that code section. Warts and all. You make a valid point about the Building Inspection Commission but we thought to include the departments included in the code so to not artificially limit it and not impose the elementtation that was not imposed by the voters. Looking at this further highlights in my mind i would like to at least put in, i do not have a financial interest in the land use matter as defined in code section 1. 127 and Everything Else flows from that so im trying to think of there are Code Violations issues that might be tied up with the building permission. The building inspector does have some incre incres ary authority. I appreciate you were trying to be all encompassing as possible. So, that would be my recommendation we put some tie into what a land use matter as defined in some code section and that at least gives them a starting place. Should we call that amendment 3 . You can do that to add the words as defined in campaign and governmental conduct code section 1. 127 immediately following the term lapped use matter . Right. Its 1 point im just looking at the prop f. Its defined in where did it go . 1. 127. 1. 127 sub section a right, thanks. Thank you for that. So the i guess well call it amendments four, five and six, are contained in written form in the Public Comment that you have in front of you and its also on the public table from anita mayo. She has amendments 1, 2, 3 and well call them four, five and six. All of these are good amendments. I would recommend all three of them. And i would call them technical in nature. Just correcting the language to make it more concise. The first one is to clarify in regulation 1. 1141 that it is ok for partnerships that have business entity members to make contributions to committees as long as they do so through a separate segregated fund. So if you look at the regulation itself that is on page 6 of the agenda item, you can see that in section sub section a. That already talks about the separate segregated fund. It clarifies if any of the business entities that use a separate segregated fund, that they can its something because we are not able to prohibit. We have to allow that. Go to the next page and sub section i its just to make sure i understand, so that if these business entities companies and partnerships and corporations wanted, really wanted to make their 500 contribution they could set up a separate fund. Correct. A separate segregated fund is a type of pack so essentially a corporation can set up a pack and they can raise money for the pack. If they dont actually put funds from the Corporate Treasury into the pack and then give to the candidate. If they were to use the pack to solicit contributions from us, lets say, then they could use the treasury of the pack to make contributions. That kind of use of a pack is called a separate segregated fund its important to clarify that here in the regulations. I appreciate ms. Mayo in the audience. Thank you for this and the other feedback. So her amendment essentially is to just call out that sub section a that use of a separate, segregated fund down here in sub section i. Sub section i is different. It talks about partnerships that are made up of business entity partners so if lets say two corporations enter into a partnership, this is talking about whether or not the partnership can make a contribution to candidates. In the first line, she pointed out is too narrow and too constricconstrict tive. Its prohibited under 1. 14b for make a contribution to a candidate committee. This proposes adding the action unless its made by the partnership separate segregated fun pursuant to sub section a of this regulation so basically just making that first sentence not overly restrictive because if you read it in isolation, could you read it to mean that the partnership cannot have a separate segregated fund but under sub section a it could. I would suggest adding that. The next amendment, well call it amendment 5. Its just to make the definition lineup with how it appears in the code. This is on page eight and now were in the land use matter rule. So one of the defined terms or one of the terms that is used that is defined in the regs is discretionary review hearse because as you can see i only called it discretionary review but it should be called discretionary review hearing because its how the term is used in the code. Ms. Mayo points out it needs to lineup. Amendment 5 is to add the word hearing in that subsection b after both uses of the term discretionary review. The title would read discretionary review hearing and in co quotations it would say discretionary review hearing it means the process by which, et cetera. Again, from a citation point of view, when you talk to the Planning Department staff, i mean, i think discretionary review is like an obscure part of the municipal code. Did they have a citation that they could give you for that . No, so, it is in deed obscure but its not an obscure part of the code. Its a special power of the Planning Commission that is not set fourth in code or in the charter. So theres no citation to make right. What about dish think they have adopted regulations like outlining. Im sure they have very elaborate provisions for how you seek discretionary review on someones project. Because again, it is just seems so discretionary review is hearing when a hearing is not required. I mean, if no one else is brought it to our attention or worried about it, its a fairly hefty part of the Planning Commission calender. Theres a fair amount of discretionary review hearings that they process all the time. I mean, probably it doesnt matter because im hug there are some that involve 5 million worth of construction. Anyway, i just dont have a citation for the regs so i cant really help. If there was someway to pin it to something a little bit more than just so my initial plan and approach for all of the 1. 127 definitions was just to have references to the planning code. Ideally those dont exist. They dont exist. I can tell you that a lot of the work that went into the regs was devoted to this particular regulation and trying to identify or define rather terms that are not defined. But that everyone seems to understand. But that are not defined. So, this represents my best effort at doing that. You might want to do it for your own staff implementation. I imagine that you can go to the Planning Commission and get the discretionary review packet that describes how one goes about seeking that that might, at least if someone gets fancy and tries 20 argue theyre entitled to this ex semmion because, anyway. We have that material on planning website about what a discretionary review it. This is the best we could do at boiling that down to a definition but beyond this, theres definition going to be a degree of interpretation and advice giving around 1. 127. Theres no way around it. It is a morfis and its complicate and a lot of it we have to figure out as we go maybe it helps by referring the hearing they do that. So its a discretionary hearing and its at issue. So ok, ill let us move on. The final amendment we can call amendment 6, is regarding the displacementer formatting rules in regulation 1. 1613. So that is on page 11. Of the attachment and ms. Made owe called out where language needs to be added thats in subsection a2. And this is talking about how to format the names of the contributors to the top contributors. So if you are listing your top contributors and the advertisement and those are committees and you are additionally listing the contributors to those committees, she points out that the words and contribution amount need to be added in the first sentence so it would read for any major contribute or that is a recipient committee the names of the top two major contributors of 5,000 or more to that committee, which i defined as a secondary major con contributor must be following the name, contribution amount of the major relevant contributor. You need to put the dollar amount after the name of the contributor and after that, you put the names of the contributors to that contributors. That is correct. What she points out here is you would not want to put the name of the contributors immediately after that because that would get in between the name of the contributor and how much money that person or entity gave. I agree. Its a good addition to add that language there in the first sentence. Ok. Those are all the amendments that i would suggest. Im glad to answer any questions about those or anything else in the regulations that you might have questions about. Just more broadly, stepping back for a moment, with this new ordinance and the regulations that are implementing prop f, how will the Ethics Commission be in a position to enforce this ordinance. Is there a data base where all land use matters so defined can be searched to know whether or not Entity Company x and properly made a contribution improperly. These ordinances are only as effective as the enforcement ability. Is there a data base that contains all land use matters . Yes and no. Theres not one that solely contains land use matters as defined here. Theres nowhere that you can just call up a data base and it has all land use matters exactly as that terms is defined and interpreted here in 1. 127. That does not exist. Land use matters are public information. So that they are out there and you cant find them. But its not as easy as just calling up a data base. Its not like 1. 126, the contractor contribution rule where we have two sets of notices that are actually creating a data base and when they file notice you have a data base of approved contracts and you can use that for compliance. What you would be doing is essentially asking the contribute or to identify parcels of land they have a financial interest in or parcels of land has a financial interest in but their shareholders for. You would check to see, for that parcel of land, are there any on going city processes that constitute a lappeduse matter. The best way to do that is to use the Planning Department planning information map, call up the address of the parcel, that will give you a list of any Building Permits or discretionary or anything going on with that property you would want to preview all of those processes and see if there are any, within the relevant time period that constitute what is defined as entitlement, request for an entitlement in the code. And again, thats kind of a ambiguous term. Its not defined in the planning code and so there would have to be some work there to determine our any of these entitlements and we worked with planning to identify which ones are not titlements and its on going advice giving because the fees you played to the Panning Department are based on the value of your project, which are always underestimated and now theyll probably be over estimating or never mind. And any event, i think that you might want to get your i. T. People together because it might be a slightly more simple cross tab. If you are talking about over 5 million projects, there are fewer of those than everything thats spendin pending before te Planning Commission. At least when you its something to think about comparing and they also have to list the owner of the property. They have to give authorization for an application at Planning Department and you can that would tie in with your list of potential contributors. Putting the machine to work for you. To fer et some of that out. It has to be the donor how will the donor make they cant make their 500 contribution . Well, hopefully they will work with the committee to try and identify it. If they did not make the written attestation to the committee and they declined to do that but the committee wanted to accept the contribution, the committee would have to ask the contribute or why did you not make this written attestation to us. Is there a financial interest you have in a land use matter and work to try and identify what they are and then do the Due Diligence with them of actually looking those items up and seeing if they are in fact land use matters as defined. There are certain things you can rule out off the bat. If its under 5 million and it has to do with their primary residents you can rule it out. If its not a primary resident and its over 5 million, would you have to go through that more detailed process of looking it up and evaluating it. Link particular to the name of the person or corporation or whatever that was the entity and making a contribution. Correct what makes it challenging and impossible to create a data base right now, of people who are prohibited for making contributions, even if there were perfect data base, of all land use matters, no department keeps track of every person who has a financial interest in the land use matters. They dont know who all those people are so they bridge that gap. We have a running list. Im just seeing there is information that gets filed with the Planning Department that when you are looking it will be easier to find than just randomly going through their agenda for a year or something. They have a robust data base on the matters that are pending before that commission. They do have a data base and were trying to figure out what materials to make available to people. They wouldnt have a end product of a data base of names. Theres always a good a leg work and well make it easy and spell it out for them but the pieces are not there to put together in a full proof compliance tool. Theres not. Well, i guess well have to just try and work through the issues as they come up. Hopefully it wont be too much of a budget buster. I dont want to hold this up any longer on this holiday eve so its move we have Public Comment. So i talked about the six amendments. Im glad to talk about those or anything else in the regs that you might have a question about any other questions . Call for Public Comment on agenda item number 6. Good afternoon, commissioners, i wanted to thank mr. Ford for presenting my amendments to you and i think they will provide clarity and to the regulations and the only other additional item i thought about, as you were discussing regulation 1. 13 were you going to do after the land use matter as defined in section 1. 127a. Say excludes a persons primary residents and it leads that way fight a few people will know the primary residents are not if they have issues or matters before the Planning Commissioner entities of the boards regarding a paper ary residents they wouldnt have to worry about that. Prohibiting them from making a contribution. Thank you. Thank you. We would add that parenthetical into the language . The amendment for regulation 1. 1273 yes, definitely. I would move that any other Public Comment foray again da item number 6 . So, i would like to make a motion to adopt amendments numbers 16 as previously discussed. Do we need to read out everything for the record . I dont think so. I second that amendment for a motion amendments 16 for the regulations all in favor. Aye. So the motion is carried. The amendments 16 are approved unanimously. Thank you. Agenda item 7. Discussion of monthly staff policy report. Thank you, agenda item 7 is my monthly staff policy report. I need a clarifying point. Its unclear on the record whether or not we actually adopted all of the amendments and their totality or just the amendments you itemized. The regulations in their totality ms. Mayos not just the stakeholder suggestions but you have a variety of other suggestion thats you put forward to the commission that you did not itemize, right. You mean the amounts you are revising for the new thresh holds so we didnt talk will be i would propose adopting attachment one with with the edits proposed so theres not any ambiguity. As opposed to the edits before the commission and the attachment, right. Maybe before we move on we can go back and make a motion to adopt, also adopt, everything proposed in attachment one attachment one as amended by amendment 16 that were read into the record yes. So theres, mr. Ambrose making a motion to adopt attachment one as amended by amendments 16. Correct the list there was a suggestion to number the amendments, right and we were talking about specific subject matters and im concerned those topics are notten campusing of everything. Were going to adopt all of attachment one which has all of the written everything the staff but then as further amended by the ones that we talked about that are all numbered. His other stuff amending the dollar amounts is already written in attachment one. Just as long its clear were adopting everyone in attachment one and the suggestions that were previously proposed as amendments 16. I think you made the motion. I move that we adopt attachment 1. The amendment to the regulations that are proposed by staff and tapment one to agenda item number 6 as modified by what weve referred to as amendments 16 as discussed and read into the record and attachment number one. That make sense . Yes, thank you. All in favor, aye. The motion is passed unanimously. Back to agenda item number 7. Agenda i 7, the monthly poy report. I will make this brief and only provides updates that arent already here in writing since i know you already read this. So the first item under policy prioritization plan updates is the Public Financing review project and you approved some regulation amendments related to that project and another thing is to help other divisions in the office who are implementing these changes so they can go live january 1st, 2020. As you know the ordinance lowered the match able amount of a contribution from the full 500 to 150 and weve discovered that net file in its matching request function, when you enter in contributions and submitting matching requests to ask them to be matched, the way it was set up in the code of code meaning like the software code, not our code, but in the net files code, was that net file would search all the contributions that you had entered as receiving. Remember net files is all encompassing system that you use, not just for Public Financing for all of your reporting. So it will search all the contributions you entered and it will essentially generate a request for you and based on your San Francisco contributors that have not been matched and it will build, you can call it the best available match air class for so you it find all of the contributions and put the full amount up to 500 on the matching request. We discovered that mechanism is hard wired into the marching request. Theres not an easy way for us to institute automatic 150 cap on that. Net file will put full 500 contributions on to peoples match request. Theres no way for them to make it just 150. Theres no manual override so it will just kick 500 onto the request every time. That cannot be changed. What that means it cannot be changed by january 1st or at all . It cant be changed by january 1st. As you know, net file has a number of projects for us, including other jurisdictions but always a number just from us of changes to their system that were requesting and theyre always competing for bandwidth and this is big enough for my understanding is it would require enough work even if they did turn to this it would be hard to roll it out by january 1. What were going to do for this election only, is is to allow candidate committees to use the net file and we realize they have no way to limit their matching request contribution to 150 so well allow them to submit full 500 contributions for matching. We wont consider it a violation and we wont get them in trouble for asking for more than theyre entitled to but well have a manual auditing process where our auditors, who add straighted the program, have to keep track of all of the contributors themselves and make sure they never match over 150. Essentially, that process is not automated. That file cant be right now. Were going to have to manually do that for 150 limiting process ourselves is there an e. T. A. On when they could complete the update to the source code . It would be some time during next year. In any event, it will not capture this election and we dont think its a good idea to change the system on people midway. So you mean the march 2020 election or the november . They cant fix it before november 2020 . He cant fix it for november 2020 election period. Thats a year from now . Well, although the election is almost a year from now, the time that people are starting to use net file it would be six months from now well, its now honestly. Committees are already out there and i believe they can submit matching requests earlier in the year. I want to say february i have to check but some time in february they can start submitting. So its a little sooner than you might think. The roll out period would have to be now. We want it to go now so what weve come up with is the best solution to manually do this 150 limiting process for this election in the meantime, work with net file to institute an automated 150 cap that will be in place in time for the following election is there anything to check the manual work on the back end . Just to run a script to test . The math . Yeah, i would have to touch base with our team to see if they can do Something Like that. I dont want to speak for them. Im sure they are automate it and we dont want to be doing everything manually and we have the matching request point in terms of auto make where its automated with a lot of manual oversights that were keeping close tabs on things. Yeah, more on that later. I just wanted to flag that for you because it will be a little strange that were actually telling committees its ok for them to request 500. Because, thats all they can do. I should also note, this is for the free net file. This is for the basic netfile that we make available to filers for free. The net file professional program which is a related separate but private Product Available to committees, its a private transaction between them and net file which we dont get involved with but our understanding is that the net file pro efficientl professionaa way for committees to say how much of a contribution they want to appear on a matching request. They could actually only request 150. They have the technical ability to limit that request is that being communicated to them . Were talking to them. My understanding is that most candidate committee whos are participating in the program, are working with the treasurer who uses net file professionals. So, it could turnout being for more candidates, their treasure will have access to a way to limit their submission to 150 but if they are use our system it will be weird where they wont have that ability communication is critical to make sure that they understand that even though the system is generating a 500 match, theyre actually only entitled to 1 othe150 sothey dont become or e disappointed when the amount they receive in terms of matching funds dont correspond to what the request was absolutely. Were focus recogniz focusing o. On the next page, e filing for all projects, as had he update you had at the last meeting, we concluded meet and confer i havent heard anything that and that suppose done and we are moving forward with that project full steam now and the next thing is i will bring you a draft regulation at the january meeting that would institute efiling for all and it will have january 2021 effective date. Thats a preview of what to expect next month. Another update thats not contained in here is that since writing this, i went to the conference with a number of other members of staff and ill let the director give you the full update but i can speak to my experience there and i was on a panel that focused on relationships that fall outside of the traditional scope of contribution and gift rules so i focused on the payment laws that were created in San Francisco and went into effect this year so those are the new prohibitions on using your value to an organization that you are affiliated with. And also the payment disclosures. That brought into the disclosure to appointed officials as well as elected and lower the threshold to 1,000 so i was giving an update to Ethics Commission staff from around the country and in canada too about this. I got some interesting questions and feedback about that. Its something that not all jurisdictions have on their radar. New york and l. D. Are doing this so it was added context to commission did earlier are did they go for an outright ban . In new york, they have actually created the rule that the commission did not approve last year. Which was to prohibit officials from soliciting from individuals who have matters before them. New york has that rule in place. So that was interesting to learn. Los angeles, i think the Los Angeles CityCouncil Approved a developer contribution rule similar to the one we were just talking about in prop f and there was some discussion in los angeles about whether that prohibition should extend to payments made by developers. I dont think they have that but its been part of the discussion down there. So, to answer your question, yes, its regulated in some cases considering being regulated in those places in a future meeting, if its inappropriate to discuss here, i would like to actually sew a report if possible, just on if theres any trends in terms of the reporting that thats been received to date to see how many payments have been made, how much have been made and to whom. It could be maybe are you talking specifically about the new payment disclosures created here . Yes. Yeah, i would be glad to. I can tell you right now that there have been very few. Of the 3. 610 disclosures by the officials making the ask for the payment, i think weve had a dozen or fewer disclosures and four filers and theyre all members of the board of supervisors. And not a really high aggregate value of the payments and i dont believe theres been any disclosures by people making the payments nor by organizations receiving the payments. The reason could be that the thresh holds were set high for people making payments and you only have to foil a disclosure if you make 10,000 or more in one year. And for organizations receiving the payments, you only have to file if you receive 100,000 or more in one year at the official. Its possible no one hit those thresh holds yet. I dont know. But thats the high level of review of the state of those disclosures right now. Thank you. I would be glad to provide more information and deeper dive into the disclosures we have received, if thats of interest. The only other update i wanted to mention is just to highlight that next month, in addition to the [please stand by] process with other departments. So thats something i would like to put on the policy prioritization plan. But i think there is some bandwidth now that the regulations have been approved and now that he efiling has been discussed, there is some room to have another project. Ill be working between now and next meeting with colleagues on staff to identify some good projects to put before you. So i look forward to that discussion. Likewise. Thank you. Ill be glad to answer any questions that you have. Any questions . Public comment on agenda item number 7 . No Public Comment. Agenda item number 8, discussion of informational report regarding possible elements in revising the commissions fixed penalty policy. Good afternoon, chair chiu and commissioners. My name is eric willett. Im an aid, senior investigator analyst with enforcement division. Im here to provide an update on staffs efforts to revise the penalty policy into the streamlined administrative resolution program. At the august 2019 commission meeting,