Staff: Neal Bucknell, Senior Commission Counsel and Ann Flaherty, Special Investigator. Respondents are represented by Tom Willis of Olson Remcho LLP. In 2018, Safe & Affordable San Francisco (the SASF PAC) qualified as a city general purpose committee. Kim Lutz was the SASF PAC treasurer, and Derek Jansen was a principal officer of the SASF PAC. That same year, Voters for a Real Change, Opposing Mark Leno for Mayor 2018 (the VFRC PAC) qualified as a committee primarily formed to oppose Mark Leno for Mayor of San Francisco in the special mayoral election held June 5, 2018. Sonia Hidalgo was the VFRC PAC treasurer, and Robb Birkhead was a principal officer of the VFRC PAC. Tony Winnicker was an advisor/fundraiser for the SASF PAC and also an advisor to the VFRC PAC. In this matter, the SASF PAC, Lutz, and Jansen: failed to file required 24-Hour Reports with the San Francisco Ethics Commission (SF Ethics), in violation of Government Code Section 84203 (1 count); failed to timely file a Statement of Organization with SF Ethics, in violation of Government Code Section 84101, subdivision (a) (1 count); and failed to timely file a pre-election campaign statement with SF Ethics for the reporting period ending May 19, 2018,in violation of Government Code Section 84200.5, subdivision (e) (1 count). The VFRC PAC, Hidalgo, Winnicker, and Birkhead failed to timely file a Statement of Organization with SF Ethics, in violation of Government Code Section 84101, subdivision (a) (1 count). Additionally, Winnicker, the VFRC PAC, the SASF PAC, Birkhead, Lutz, and Jansen avoided required top contributor advertising disclosures, in violation of Government Code Section 84505, subdivision (a) (2 counts). Total Proposed Penalty: $18,000.