____________________________________________________________________________________
FOR CITY CLERK ONLY
Council Meeting: _______________________
Disposition: ___________________________
Agenda Item No: 3.a
Meeting Date: March 16, 2026
SAN RAFAEL CITY COUNCIL AGENDA REPORT
Department: City Clerk
Prepared by: Lindsay Lara, City Clerk City Manager Approval: ______________ TOPIC: ESTABLISH ELECTRONIC AND PAPERLESS FILING FOR FPPC CAMPAIGN
DISCLOSURE STATEMENTS
SUBJECT: INTRODUCTION OF AN ORDINANCE ADDING CHAPTER 2.09 TO TITLE 2 (ADMINISTRATION) OF THE SAN RAFAEL MUNICIPAL CODE TO REQUIRE
ELECTRONIC AND PAPERLESS FILING OF FAIR POLITICAL PRACTICES COMMISSION (FPPC) CAMPAIGN DISCLOSURE STATEMENTS; CEQA
DETERMINATION: EXEMPT PURSUANT TO CEQA GUIDELINES, §§ 15060, subd. (b)(2)-(3), 15378(b)(2),(5)
RECOMMENDATION:
Introduce the Ordinance, waive further reading of the Ordinance, and refer to it by title only.
BACKGROUND:
The Political Reform Act of 1974 defines a committee that receives or expends $2,000 or more in a calendar year as a “controlled committee.” Once this threshold is met, the committee is required to file periodic campaign disclosure statements with the local filing officer, including Fair Political Practices Commission (FPPC) Form 460 and other applicable forms.
Currently, the City Clerk’s Office accepts paper filings of these campaign statements. Staff manually review, redact where necessary, scan, and upload each document to the City’s website. While this process satisfies minimum statutory requirements, it is time-intensive, creates potential for human error, and delays public access to filed information.
To modernize and streamline this process, the City Clerk’s Office is implementing NetFile, a web-based electronic filing system that allows candidates and committees to file FPPC forms online. NetFile supports Forms 460, 470, 496, and 497, among others, and meets the technical requirements established by the California Secretary of State. Adoption of the proposed ordinance would require committees to file campaign disclosure statements electronically through the City’s designated system.
Government Code section 84615 authorizes local agencies to require candidates and committees to file campaign statements electronically with the local filing officer. However, before a local agency may accept electronic filings, the City Council must adopt an ordinance approving the use of an online or SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 2
electronic filing system and making legislative findings that the system will operate securely and effectively and will not unduly burden filers.
ANALYSIS:
Electronic filing enhances transparency by making campaign statements immediately available for public viewing upon submission. It eliminates the need for manual data entry and scanning, reduces administrative burden on staff, and provides filers with built-in validation tools that help ensure required fields are completed before submission. In many instances, the system improves accuracy by preventing incomplete filings that do not meet statutory requirements.
Government Code section 84615 expressly authorizes local agencies to require elected officials, candidates, and committees to file campaign statements electronically with the local filing officer.
However, prior to accepting electronic filings, a local agency must adopt an ordinance approving the use of an online filing system and making a legislative finding that the system operates securely and effectively and does not unduly burden filers.
NetFile is a vendor-hosted, secure web-based platform that utilizes industry-standard encryption protocols comparable to those used in online banking. The system stores and backs up data in multiple secure locations, providing redundancy and disaster recovery safeguards to ensure the integrity and availability of campaign finance records. The City currently use NetFile to manage Statements of Economic Interests (Form 700) and has been satisfied with its performance and reliability. The renewed agreement continues this partnership and expands services to include ethics training for the City’s executive team to meet new 2026 state law requirements, as well as the electronic filing for candidate campaign disclosure statements, directly related to this ordinance.
Electronic filing of campaign disclosure statements is widely implemented throughout California.
Currently, around 250 cities utilize NetFile for campaign statement filing. Within Marin County, the County of Marin and the cities of Fairfax, Novato, Larkspur, and Sausalito have adopted electronic filing requirements.
Adoption of the proposed ordinance would align the City of San Rafael with statewide best practices, enhance public transparency, reduce administrative inefficiencies, and provide a more convenient and reliable filing process for candidates and committees. Approval of electronic signatures for campaign disclosure statements aligns with San Rafael’s 3-year Strategic Plan, Priority Area F.2.1: High Performing Government. Attachment 1 contains the proposed ordinance for City Council consideration.
FISCAL IMPACT:
There is no direct fiscal impact as a result of the introduction or adoption of this ordinance. The cost to expand the City’s use of the NetFile platform, as described, is estimated at $3,000 per year and is being absorbed within the approved budget within the City Clerk’s Office.
OPTIONS:
The City Council has the following options to consider on this matter:
1. Introduce the ordinance.
2. Direct staff to return with more information.
RECOMMENDED ACTION:
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 3
Introduce the Ordinance, waive further reading of the Ordinance, and refer to it by title only.
ATTACHMENTS:
1. Ordinance
ORDINANCE NO.
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SAN RAFAEL ADDING CHAPTER 2.09 TO TITLE 2 (ADMINISTRATION) OF THE SAN RAFAEL MUNICIPAL
CODE TO REQUIRE ELECTRONIC AND PAPERLESS FILING OF FAIR POLITICAL
PRACTICES COMMISSION (FPPC) CAMPAIGN DISCLOSURE STATEMENTS WHEREAS, Government Code Section 84615 currently provides that a local agency may adopt an ordinance to require an elected officer, candidate, committee, or other person required to file statements, reports, or other documents required by Chapter 4 of the Political Reform Act (commencing with Section 84100 of the Government Code), except an elected officer, candidate, committee, or other person who receives contributions totaling less than $2,000 and who makes independent expenditures totaling less than $2,000 in a calendar year, to file those statements, reports, or other documents online or electronically with the local filing officer; and
WHEREAS, the City has entered into an agreement with NetFile, Inc., a vendor approved by the California Secretary of State, to provide an online electronic filing system ("System") for campaign disclosure statements; and
WHEREAS, the System will operate securely and effectively and will not unduly burden filers; and
WHEREAS, the System shall ensure the integrity of the data transmitted and shall include safeguards against efforts to tamper with, manipulate, alter, or subvert the data; and WHEREAS, the System will enable filers to complete and submit filings free of charge, and will make all the data filed available online and free of charge in an easily understood format that provides the greatest public access; and
WHEREAS, the City of San Rafael desires to amend the San Rafael Municipal Code adding section, 2.09 “Electronic and Paperless Filing of Fair Political Practice Commission Campaign Disclosure Statements” regarding electronic filing of Campaign Disclosure Statements.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SAN RAFAEL DOES HEREBY ORDAIN AS FOLLOWS:
Section 1. Recitals. The above recitals are true and correct and incorporated herein by reference.
Section 2. Section 2.09, Electronic and Paperless Filing of Fair Political Practices Commission Campaign Disclosure Statements, is hereby added to the San Rafael Municipal Code to read as follows:
2.09 Electronic and Paperless Filing of Fair Political Practice Commission Campaign Disclosure Statements.
A. Definitions. The following definitions apply for the purposes of this section:
"Candidate" shall mean a candidate, as that phrase is defined in Section 82007 of the Government Code, as may be amended from time to time, for any City elective office for any general, special or recall election.
"Committee" has the meaning set forth in Section 82013 of the Government Code, as may be amended from time to time.
"Contribution" has the meaning set forth in Section 82015 of the Government Code, as may be amended from time to time.
"Electronic filing system" shall mean the electronic online filing and data storage system provided for by the city clerk for campaign statements, reports, forms, or other documents filed pursuant to Government Code Section 81000 et seq. "Person" has the meaning set forth in Section 82047 of the Government Code, as may be amended from time to time.
"Statements" shall mean any statements, reports, forms, or other documents required by Government Code Chapter 4 - Political Reform Act (Section 81000 et seq.), as may be amended from time to time.
B. Any elected officer, candidate, commission, committee, or other person required to file campaign disclosure statements, reports, forms or other documents required by Government Code Chapter 4 (Campaign Disclosure) - Political Reform Act (Section 84100 et seq.) shall file those statements, reports, or other documents online or electronically with the electronic filing system unless exempt from the requirement to file online pursuant to Government Code Section 84615(a) because the officer, candidate, or committee or person receives less than two thousand dollars in contributions and makes less than two thousand dollars in expenditures in a calendar year.
C. In any instance in which an original statement, report or other document required by Government Code Chapter 4 (Campaign Disclosure) - Political Reform Act (Section 84100 et seq.) must be filed with the California Secretary of State and a duplicate or copy of that statement, report or other document is required to be filed with the City Clerk, the filer may, but is not required to, file the copy electronically.
D. Notwithstanding any other provision of this code, once an elected officer, candidate, committee, or other person files a statement, report, or other document electronically pursuant to subsection B, all future statements, reports, or other documents on behalf of that filer shall be filed electronically.
E. The electronic filing system shall be implemented and maintained to be consistent with the requirements of Government Code Section 84615, as that section may be amended from time to time.
F. The City Clerk is authorized to adopt such administrative policies and procedures as deemed necessary by the City Clerk to implement this Section 2.09.
G. If the City Clerk’s electronic system is not capable of accepting a particular type of statement, report or other document, an elected officer, candidate, committee or other person shall file that document with the City Clerk in an alternative format.
Section 3. Compliance with the California Environmental Quality Act.
The City finds that this action is evaluated to be exempt from the California Environmental Quality Act pursuant to State Guidelines Section State CEQA Guidelines, §§ 15060, subd. (b)(2)-(3), 15378(b)(2),(5), as it is not considered to constitute a “project” for the purposes of CEQA.
Section 4. Severability.
If any provision of this Ordinance or the application thereof to any person or circumstance is held invalid, the remainder of the Ordinance and the application of such provision to other persons or circumstances shall not be affected thereby.
Section 5. Effective Date and Publication.
This Ordinance shall become effective thirty (30) days after it is adopted and shall be posted or published as required by State law.
THE FOREGOING ORDINANCE was first read and introduced at a regular meeting of the San Rafael City Council on the 16th day of March 2026, and was passed and adopted at a regular meeting of the San Rafael City Council on the 6th day of April 2026 by the following vote, to wit:
AYES: COUNCILMEMBERS:
NOES: COUNCILMEMBERS:
ABSENT: COUNCILMEMBERS:
______________________________
Kate Colin, Mayor
Attest:
_____________________________
LINDSAY LARA, City Clerk