Los Angeles City Ethics Commission


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FORMAL ADVICE LETTERS

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CEC #	Date Issued	Issue	Issue Description:	Requestor:	Law Section:
03-01	03/13/03	Assumed Name Contributions	Congressman Xavier Becerra and the “Becerra for Mayor” committee are required to repay to the General Fund contributions received by the committee made under assumed names, and repay to the Matching Funds Trust Fund matching funds received for some of those contributions. The true source of the contributions was Mattel, Inc. (See CEC Cases 2001-18-A, B, and C).	Steele (Becerra)	LAAC Section 24.5(k), 24.5(n)(1) and (3); City Charter Section 470(k); LAMC Section 49.7.20(A);
02-16	12/17/02	Gift and Travel Restrictions	A City official is not required to report, nor is he subject to City and State limits on gifts of travel, lodging and meals he accepted in connection with travel to Korea for conference.	Nazarian	LAMC Section § 49.5.10; Cal. Gov. Code Section § 82028; 2 Cal. Code of Regs. Section § 895032;
02-15	11/01/02	Post-City Service.	A City employee is prohibited from responding to assisting his new employer with responding to a Request for Proposals released by a City contractor at the behest of the Department of Transportation, which is his employer. City law does not prohibit employee from working to fulfill a sub-contract with a City contractor provided the sub-contract is awarded to his employer. (Withdrawal and change of advice given in Advice Letter #02-13)	Cannistraci	LAMC Section 49.5.11, 49.5.12;
02-14	10/30/02	Return of Campaign Contribution	A City Councilmember may make an expenditure to return a contribution to his general election campaign committee because that committee remains active.	Zine	2 Cal. Code of Regs. Section 18225 (a)(2)(B); City Charter Section 470 (g);
02-13	10/17/02	Post-City Service Restrictions	The one-year ban on communicating with a City employee’s former agency does not apply to an employee whose former position was not designated on his department’s Conflict of Interest Code as a City official required to file a Statement of Economic Interests. City law does prohibit that employee, however, from engaging in post City-service employment in which his responsibilities would include attempting to influence any action or decision on any pending matter in which he was “personally and substantially” involved while employed with the Department of Transportation.	Cannistraci	LAMC Section 49.5.11;
02-12	10/04/02	Officeholder Account Funds	The Controller may not use officeholder funds to return a contribution made to her terminated campaign committee, received when the committee was still active.	Chick	LAMC Section 49.7.12;
02-11	09/25/02	Post-City Service Restrictions	A former City official may not, on behalf of his company, assist in the preparation of a response to a RFP published by his former Department, or in any other way to attempt to secure the contract, because he had personal and substantial involvement on the subject of the RFP while working for the City.	Sones	LAMC Section 48.02, 49.5.3, 49.5.11, 49.5.12;
02-10	09/24/02	Officeholder account/Legal Defense Fund	A Legal Defense expenditure, such as a payment to the Office of the City Attorney for copying and transcription fees associated with an administrative proceeding against a City Officeholder, should be paid from the officeholder committee bank account, by means of an officeholder account check using funds raised for Legal Defense purposes.	Holden	LAMC Section 49.7.12 (B) 1-6, (C);
02-09	09/11/02	Officeholder Account	A Councilmember may use her officeholder account to provide funds to her District’s neighborhood councils for the purpose of purchasing office supplies and paying for operational expenses such as telephone service.	Kaufman (Hahn, Janice)	LAMC Section 49.7.12 (A) (2)(b) and (w);
02-08	08/15/02	Campaign Finance	A candidate for City Council may not: 1) re-designate or transfer contributions solicited and accepted in connection with the CD 8 election to his campaign account for the CD 10 election; 2) re-designate contributions via his contributors’ authorizing the re-designation of their contributions to his CD 8 campaign to the candidate’s CD 10 campaign; 3) maintain the committee name and bank account established in connection with his CD 8 campaign.	Gould (Wright)	2 Cal. Code of Regs. Section 18404; 2 Cal. Code of Regs. Section 18521; City Charter Section 470(c)(9), 470(c)(1), 470(c)(6), 470(g), 470(a); LAMC Section 49.7.4;
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DISCLAIMER:

Advice issued by the City Ethics Commission (CEC) provides guidance to the person requesting the advice and is based on the specific facts that person has provided and the language contained in the law at the time the advice was issued. As the Charter, ordinances, and related laws are subject to change, we strongly advise you to contact the CEC for advice based on your specific facts and circumstances.