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By Roz Rogoff

About this blog: In January 2002 I started writing my own online "newspaper" titled "The San Ramon Observer." I reported on City Council meetings and other happenings in San Ramon. I tried to be objective in my coverage of meetings and events, and...  (More)

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Get a Clue!

Uploaded: Oct 13, 2011
Did Abram Wilson violate California's Fair Political Practices Commission (FPPC) reporting requirements by entering $0 in expenditures on his City Council campaign's 460 form? That's the assertion Steve O'Brien makes in his October 6th blog entry.

Steve O'Brien never contacted Abram Wilson to ask about his zero dollar entry on his 460 form. I phoned Wilson to ask about O'Brien's claims. "If he would do his homework, he would not make these outlandish statements," Wilson said about O'Brien's blog.

As an Online College Instructor, I always want my students to do their homework and I try to do mine. So when someone at the Candidate's Forum last week asked me how Abram Wilson could have spent zero dollars on his Council campaign, I said I didn't know but I'd find out.

In addition to phoning Wilson to ask, I downloaded the Campaign Disclosure Manual 2 from the Secretary of State's website and phoned their Advice line on Thursday, October 13th. The instructions in the Campaign Disclosure Manual are confusing, and O'Brien and Wilson each got some things right and some things wrong.

O'Brien starts off with an assumption that Wilson incorrectly omitted the filing fee as an expenditure on his 460 form:

"How is that even possible given the $1,000 filing fee every candidate must pay the city in order to run? The deadline for paying that fee has long passed. So either Wilson didn't pay it, which is a totally different problem, or he failed to report it. That makes FPPC filing violation #1."

No, Steve, "A candidate's personal funds used to pay the filing fee and/or the ballot statement fee do not count toward the $1,000 threshold" (Campaign Disclosure Manual 2, 2007, p. #1-1).

O'Brien goes on to make a big deal over the cost of Wilson's campaign signs, which even he says are small and hard to spot.

"Next, what about Wilson's campaign signs? I started spotting them (difficult as that is) on September 28th. Likely they were up earlier. Again, the 460 filing was for financial activity through September 24th."

Wilson told me he charged his campaign signs on a credit card. These came to well under $1000. My DSRSD signs, which are bigger and nicer than what I've seen of Abram's, cost me about $300 on a credit card.

O'Brien's estimate of Wilson exceeding the $1000 limit is wrong, but he got the next part right.

"Is it possible to design, print and post signs around town in less than 4 days? Perhaps, but the FPPC still requires candidates to disclose any pending bills on Schedule F of the 460. Pending invoices for signs included. So that's FPPC filing violation #2."

The Campaign Disclosure Manual 2 (2007) is confusing on this point (emphasis added).

"If the committee has entered into an agreement to make payments over time for a product or service, other than general administrative expenses such as rent and utilities, the unpaid balance MAY BE REPORTABLE on Schedule F as an accrued expense" (p. #6-22).

So I phoned the FPPC Advice line and was told that because the 460 was filed with contributions greater than $1000, the Schedule F with accrued expenses should have been included with the 460. Abram lists one contribution of $1295 on his 460 form, which was transferred from an old Mayor's campaign account to the current account.

I asked the Advice Consultant what happens if the Schedule F was not filed. She said the County would ask for an Amendment or the Candidate's Committee could file an Amendment.

I asked our City Clerk if there's a special form to file an Amendment, and she said it's just a checkbox on the 460 form.

There's no time line on when 460's must be amended for expenditures. "Except for amendments required to provide contributor information (see Chapter 1), there is no deadline for filing amendments to campaign reports" (Campaign Disclosure Manual 2, 2007, p. #5-3).

So even if Wilson didn't file a Schedule F when he should have, this isn't considered an FPPC Violation.

O'Brien then questioned Wilson's fundraising expenses.

"Ok, what about donation solicitations? My sources tell me Wilson mailed out a donation request last month. . . . Mailings cost money- postage, envelopes, copying. None of that cost reported in his statement. That's filing violation #3."

Wilson told me he sent personal requests to a very select list of past contributors at a cost of $200-300 for stamps. So it looks like Abram spent or charged $500-600 on his campaign, but it is more than $0 and should have been reported on his 460 form. I emailed Abram and his Campaign Treasure, Dennis Garrison, that they need to file an Amended 460 form.

O'Brien's blogs are reprinted on the San Ramon Patch. Regional Editor, David Mills, who took over as interim Editor of the San Ramon Patch after Jennifer Wadsworth left for personal reasons, posted a message on the Patch to Steve O'Brien to contact him about his latest blog entry.

I asked Wilson if he would consider suing O'Brien and/or the Patch over this attack. He said he would, but Mills removed O'Brien's October 6th blog entry from the Patch a few days ago.

While I believe in freedom of the press, there's a fine line between liberty and license. O'Brien may have crossed it this time.
What is it worth to you?


Posted by member, a resident of San Ramon,
on Oct 14, 2011 at 9:09 am

What a bunch of "stuff". Wilson absolutely failed to disclose. What would have been so hard about reporting? He was just lazy and got caught. Excuses. Look at Perkins filings. All up to date. Again excuses.

Posted by kevin, a resident of San Ramon,
on Oct 14, 2011 at 12:56 pm

I think there a couple of glaring(to me)points regarding Mayor Abrams actions that aren't addressed;

First, when have you wanted something so bad you were not willing to spend any money to get it? I would think of serving on the City Counil as a public service. It does not pay a lot so the person seeking it would need to have a strong desire to serve his City and his fellow residents. How many people vote for a candidate that simply puts his name on the ballot and does not extend any money and minimal effort for the voters to know what he is about. One might say, mayor Abrams is already well known to the voters of San Ramon. I would say he has a long way to go in explaining himself regarding his record on many issues.

Roz, you ran for office recently. How detailed was your campaign reporting form. Did you treat it seriously? If so, why? I think reporting ZERO DOLLARS is making a blatant statement that the Mayor is tired of being on the City Council. If we elect him, he is willing to serve. Not what I want for a council member, especially in these times when we need fiscal work to guide our City through what is expected to be a prolonged economic slow growth peroid.

How ironic that Mayor Abrams would consider suing Steve O'brian over his column and not want to spend any money on his campaign. I think that speaks volumes about his priorities.

Posted by Steve O'Brien, a resident of San Ramon,
on Oct 14, 2011 at 3:42 pm

I'm not sure what there is to sue me about Roz. Wilson got off on a technicality regarding not disclosing his filing fee. Every other canddiate reported it. He was clearly wrong (as you note above) to omit reporting the cost of his signs and the postage he incurred. Apparently the FPPC agreed with me as they have asked Wilson to respond to why he didn't file an accurate financial disclosure form (you can find a copy of their letter to Wilson on my blog If none of our candidates reported any expenses and merely did ammendments after the election, that would make a farce of fair political practices law. A veteran like Wilson should err on the side of transparency, not the other way around. He should be held to the highest standard.

Posted by Resident, a resident of San Ramon,
on Oct 14, 2011 at 4:31 pm

I find it comical that Wilson calls O'Brien's claims "outlandish" and then goes on to admit that O'Brien was right about 2 of the 3 claims. Then you Roz somehow land on Wilson's side to the extent of suggesting a lawsuit against O'Brien. I think you've both lost it.

Posted by Roz Rogoff, the San Ramon Observer,
on Oct 14, 2011 at 5:20 pm

Roz Rogoff is a registered user.


The first time I ran for DSRSD in 2004 I raised $2000 in contributions, put in $2000 of my own money, and my mother contributed $2000. I outspent the other candidates 3 to 1 and came in last.

I wasn't planning to run last year, but someone said she hoped someone from San Ramon would run. I was standing next to her and though she was hinting to me to run, so I did. She later told me she wasn't hinting I should run, she wanted someone else from San Ramon to run.

I filed a 470 form, which is for donations and expenses under $1000, not including the filing fees. I did not have a candidate committee or bank account, and spent under $1000, except for filing fees which I paid for out of my personal account. That's very common, and not a technicality.



The Advice Consultant told me that a letter would be sent if someone filed a complaint. Since you are cc'd on this letter, you obviously filed the complaint. That doesn't mean the FCCP agreed with you only that the candidate must respond to a formal complaint.

The FPPC doesn't care about small change. The law is to keep track of money going into and out of a candidate's campaign account. So if the candidate pays filing fees out of their personal account, it's not counted.

The FPPC is more interested in who is contributing to a campaign and if money is being kicked-back to contributors. That's the kind of corruption the FPPC was formed to prevent.

It's nonsense to say Abram violated anything by not reporting a few hundred dollars on signs and stamps. He's running on his reputation, which is widely known. Voters can make the decision whether he should stay on the City Council or not based on his past performance.


Posted by Steve O'Brien, a resident of San Ramon,
on Oct 14, 2011 at 6:26 pm

Roz - after a few phone calls with an advisor I don't think you are in a position to interpret FPP law. The FPPC issued a formal warning to Dave Hudson for not correctly recording a donation from Herb Moniz's farm (a copy also posted on my blog). The rules are the rules and a shifting standard for a "few hundred dollars" is not right, and most of us understand this.

By the way, despite your assertions my blog about Wilson's non reporting of expenses was never posted on Patch. You need to keep doing that homework Roz.

Posted by john madison, a resident of San Ramon,
on Oct 15, 2011 at 8:00 pm

What a waste of energy...Abram...thank you for your service, and please just recognize your time of public service is over....KAPUT...
Time to move more $175K per year folks to make sure our grass is cut, the occupy movement is all about the fat cats in San Ramon government making more than 99% of us...we now know and will not lay down and have you enslave us to give you benefits none of us have!!!

Posted by Richard, a resident of Danville,
on Oct 16, 2011 at 8:08 am

If Wilson used his personal credit card to pay for expenses like signs he needs to count that as a contribution to his campaign as well as an expense. So his contributions may be off too

Posted by Paul Davidson, a resident of another community,
on Jun 19, 2015 at 8:16 am

Great article. Thanks for the info, this is really a helpful post. BTW, if anyone needs to fill out a FPPC form 406, I found a blank form in this link Web Link This site PDFfiller also has several related forms that you might find useful.

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