Here’s one way around campaign finance laws: Make up a false, non-existent agency so the laws just don’t apply to your ads, mailers, and billboards. But these ads from the apparently made-up “Citizens for Campaign Finance Transparency” are paid for by a pro-Mark Farrell PAC.

You may have received a political mailer, or seen posters plastered on walls, or maybe even a spam text message showing some gob-smacking disparities in fundraising for the SF Mayor’s race. The ads claim they’re from a “non-profit watchdog organization” called Citizens for Campaign Finance Transparency. But there’s something odd about their “transparency,” as these ads lack the legally required disclosure of who paid for them.

The figures about mayoral candidate Daniel Lurie’s very large campaign contributions are correct, and do accurately note that as of September 30, Lurie had given $5.9 million of his own vast fortune to his campaign. So in that sense, yes, Lurie has gamed his own wealth to lead the fundraising race. But the mailers and posters make candidate Mark Farrell look like a real underdog here, with only $1.5 million raised. That leaves out the very key detail that Farrell’s campaign has been using money from a separate Prop D political action committee (PAC), an unprecedented practice that has raised calls for a criminal investigation.

If you count the PAC money, Farrell’s campaign may have more than $2 million in extra contributions not being counted on these charts, and that sum could be more than $8 million. That certainly tips the scales of these ads’ cited figures.

So what is this so-called group Citizens for Campaign Finance Transparency? The ads claim that it’s a “non-profit watchdog organization,” but we found no record of this organization existing in the California Secretary of State nonprofit database. And while the ads show a website called SFCampaignFinance.org, that website simply redirects to the San Francisco Ethics Commission website.

So we have a seemingly made-up commission being cited on political ads that do not say who paid for them. Is this even legal?

We asked the SF Ethics Commission, and the answer was, well, yes and no. These ads do not specifically say they support or oppose any candidate or ballot measure, even though they’re clearly designed to make Lurie look bad. So they are legally deemed to be educational, and not subject to the same rules as ads for PACs (which these days, PACs prefer to be called “independent expenditures”). But the ads are deemed to be “electioneering” materials, and per SF law, the ads should have a disclaimer saying who paid for them, which they do not.

The Ethics Commission directed us to the section of San Francisco election law on electioneering materials. That law says that “Every electioneering communication for which a statement is filed pursuant to subsection (b) shall include the following disclaimer: "Paid for by __________ (insert the name of the person who paid for the communication)."

The ads don’t say who paid for them, so SFist did some digging. The posters popping up around town appear right alongside political posters from local pressure group and PAC TogetherSF, who are also known for the “That’s Fentaife!” ad campaign and falsely claiming the Civic Center farmers’ market was closing down. These two sets of political posters even went up on the same day.

But that doesn’t prove anything. These posters are likely handled by some third-party firm that also puts up posters for upcoming concerts and new album releases. Just because these ads are next to TogetherSF posters, that doesn’t prove the same group paid for them.

But we can determine who registered the SFCampaignFinance.org website. According to WHOIS lookup data, the site is registered to an AMWG Consulting,and was created on September 10, 2024.

Looking through local campaign finance records, we see that the PAC called “Mayor Mark Farrell for Yes on Prop D” paid AMWG Consulting of Scottsdale, Arizona $1,500 for “web page design” sometime in August or September. The Arizona location may be significant, because the legal complaints about Farrell’s alleged campaign finance violations cite that Farrell is using Arizona attorneys who are not licensed to practice law in California.

That $1,500 payment does not necessarily prove that this pro-Farrell PAC paid for these ads. Searching more of these records, we also see that AMWG Consulting has been paid this year by Michaela Alioto-Pier’s DCCC campaign, and from some other PAC called “The Fight for San Francisco’s Future.”

But notice the dates of these payments. The payments from the pro-Mark Farrell PAC came on August 5, all of the other payments were from before the March 5 primary election this year. If the website was created September 10, 2024, and the pro-Farrell PAC paid AMWG Consulting in August or September, that seems to make it pretty clear that the “Mayor Mark Farrell for Yes on Prop D”  PAC paid for at least the website portion of this ad campaign.  

SFist reached out to the Mayor Mark Farrell for Yes on Prop D PAC for comment, and we have not heard back. We’ll update this post with any response. But we did hear back for  the Daniel Lurie campaign.

“They know Daniel will upend the broken system they’ve grown and exploited, and they’re fearful of the change he’s going to bring,” a Lurie spokesperson tells SFist. “Ultimately, San Francisco won’t get the change it needs by replacing one corrupt insider with another.”

The Mayor Mark Farrell for Yes on Prop D PAC has raised $2.3 million as of today. While contributions to candidates’ campaigns are capped at a $500 limit in San Francisco, there is no limit to PAC contributions. And filings show that this pro-Farrell PAC has received $645,000 from conservative mega-donor William Oberndorf (plus $195,000 from his Oberndorf Enterprises), another $500,000 from SF Standard owner Michael Moritz, and $200,000 from Chicago-based investor John Pritzker.

That PAC is also paying for Prop D ads currently clogging your mailbox that are basically just Mark Farrell ads, often making little mention of Prop D itself. The Chronicle broke a great story in August showing that Farrell’s mayoral campaign appeared to be illegally using this Prop D PAC money to subsidize his campaign for mayor. Indeed, a look through the Prop D PACs filings show they’ve been reimbursing Farrell’s mayoral campaign for so-called shared expenses like “Shared Expense - Campaign Staff,” “Shared Expense - Office,” “Shared Expenses - August 2024 Rent,” and even “Shared Expense - Office Snacks.”

But it may be a different pro-Farrell PAC that dumps even more money toward his campaign. There’s another PAC called “Committee to Fix San Francisco Government, Yes on D, No on E, A Coalition of San Francisco Civic Organizations Dedicated to Improving the City's Future” (yeah, these things are awkwardly named). That PAC has raised $6.4 million, including the monster $2.4 million donation from Moritz highlighted above.

Campaign filings also show that particular PAC has paid hundreds of thousands of dollars to TogetherSF, and tens of thousands of dollars to a PR firm called Riff City Strategies. Riff City Strategies was recently named in a $54,000 fine from the SF Ethics Commission over Riff City's undisclosed paid work on the Chesa Boudin recall campaign. The company's president Jess Montejano also happens to be Farrell’s campaign spokesperson.  

So yes, on paper, the Daniel Lurie for Mayor campaign has vastly outraised the Mark Farrell for Mayor campaign. But if Farrell has two PACs that appear to be directly supporting his campaign too, the contributions toward those PACs amount to $2.3 million and $6.4 million, respectively.  Adding those numbers in would make the above charts look a whole lot different.

The galling thing about this is that SF PACs are putting out information from mystery fictional organizations, as a way around disclosing who actually paid for the advertisements. And if political ads can get around the disclosure laws by just claiming to be from some made-up organization, well, that has pretty terrifying implications for future SF elections.    

Related: Former Mayors Willie Brown, Art Agnos, and Frank Jordan Call For Criminal Investigation of Mark Farrell Campaign [SFist]

Images: Joe Kukura, SFist