Form 803 - Behested Payment Report

A behested payment is when a state or local elected official or a member of California’s Public Utilities Commission solicits a donation to an organization, such as a 501(c)(3), that is used for legislative, governmental or charitable purposes. These types of payments are not considered campaign contributions or gifts, but are payments made at the "behest" of elected officials to be used for legislative, governmental or charitable purposes.

While state law limits the amount of campaign contributions and gifts, there are no limits on behested payments. State law requires the reporting of behested payments if they total $5,000 or more per calendar year from a single source. There are no reporting requirements for payments up to $4,999.99.

Officials must report the behested payments within 30 days of the date they are made by filing FPPC Form 803 (Behested Payment Report) with the City Clerk's Office.

The list will be updated as forms are submitted to the Office of the City Clerk.

2024

Filing Date Behesting Official Description Payee Payor Amount
01/12/2024 Buenaflor Nicolas South San Francisco Volunteer Gala to honor all of the Presidential Service Awardees(PDF, 709KB) City of South San Francisco South San Francisco Scavenger CO., INC. $10,000
01/12/2024 Buenaflor Nicolas South San Francisco Volunteer Gala to honor all of the Presidential Service Awardees(PDF, 643KB) City of South San Francisco AbbVie $10,000
01/12/2024 Buenaflor Nicolas South San Francisco Volunteer Gala to honor all of the Presidential Service Awardees(PDF, 763KB) City of South San Francisco Genentech $10,000
01/12/2024 Buenaflor Nicolas South San Francisco Volunteer Gala to honor all of the Presidential Service Awardees(PDF, 627KB) City of South San Francisco Genentech $5,000
01/12/2024 Buenaflor Nicolas Inaugural San Mateo County Sister-to-Sister Conference to empower AANHPI young women(PDF, 691KB) City of South San Francisco Kaiser Permanente $5,000
01/12/2024 Buenaflor Nicolas Inaugural San Mateo County Sister-to-Sister Conference to empower AANHPI young women(PDF, 686KB) City of South San Francisco Kaiser Permanente $1,000

2022

Filing Date Behesting Official Description Payee Payor Amount
09/07/2022 Eddie Flores Donation to support mental health services across San Mateo County(PDF, 645KB) Peninsula Health Care District Chan Zuckerberg Initiative $250,000

08/02/2023 Eddie Flores Donation to SSF Every Kid Deserves a Bike Program(PDF, 702KB) City of South San Francisco Rotary Club of South San Francisco $10,000

2019

Filing Date Behesting Official Description Payee Payor Amount
01/30/2019 Karyl Matsumoto Donation to South San Francisco Parks and Recreation and South San Francisco Police Explorers Post 850(PDF, 354KB) South San Francisco Friends of Parks and Recreation and South San Francisco Police Explorers Post 850 Ed Collantes
$20,000
02/15/2019
Amendment
Karyl Matsumoto Donation to South San Francisco Parks and Recreation and South San Francisco Police Explorers Post 850(PDF, 413KB) South San Francisco Friends of Parks and Recreation and South San Francisco Police Explorers Post 850 150 Airport LLC $20,000

Reporting Behested Payments

Under California's transparency laws, an elected official who fundraises or otherwise solicits payments from one individual or organization to be given to another individual or organization may be required to report the payment. Generally, a payment is considered "behested" and subject to reporting if it is made:

  • At the request, suggestion, or solicitation of, or made in cooperation, consultation, coordination or concert with the public official; and
  • For a legislative, governmental or charitable purpose.

Behested payments subject to reporting do not include gifts made principally for personal purposes, or contributions made for election-related activity to the elected official. While state law limits the amount of gifts and campaign contributions an official may receive, there are no limits on behested payments. However, a reportable behested payment that also results in any personal benefit to the official may be considered a gift to the official even when the payment is not made principally for personal purposes. To the extent a behested payment results in a personal benefit, the payment may require additional reporting as a gift and be subject to the gift limit. State law requires the reporting of behested payments if they total $5,000 or more per calendar year from a single source.

Officials must report the behested payments within 30 days of the date on which the payment meets or exceeds $5,000 from a single source.

FPPC - Reporting Behested Payments