Public Comment — City Council Finance Committee, June 3, 2026

Nicki MacPherson
From: Brian Swanson
Sent: Wednesday, June 3, 2026 12:02 PM
To: City Clerk (Public); City Council; Finance
Cc: planningcommission
Subject: Public Comment: Agenda Item 5.1 — Required Communications for the Fiscal Year 2026 Annual Comprehensive Financial Report - Finance Committee Meeting Agenda - June 3, 2026
Attachments: 01.27.2026 - BSwanson - Public Comment - City Council Meeting - Agenda Item 9.2 - Audited ACFR for FY25.pdf; 02.18.2026 -
BSwanson_PublicCommentVerbalScript_FinanceCommittee_Item5.3FY25InternalControls Memo.pdf; 02.18.2026 - BSwanson_PublicComment_Agendaltem5.3_FY25 Memo on Internal Control_FinanceCommMtg.pat; 03.24.2026 - Public Comment_ CityCouncilMtg_Request to Pull Agenda Item 5.4 - FY25 Memorandum on Internal Control.pdf; 05.26.2026 - PublicComment_CityCouncilMtg_AgendaandAgendaltem8.1- Resolution No. 2026-066 - Adopting the Fiscal Year 202627 Operating and Capital Budget.pdf
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Finance Committee Members:

I submit this written public comment regarding Finance Committee Agenda Item 5.1 for the June 3, 2026 regular meeting, titled "Required Communications for the FY26 Annual Comprehensive Financial Report." The staff report states that it is the Finance Committee's role to "receive and accept" the communications on the Statement on Auditing Standards for the Fiscal Year 2026 Annual Comprehensive Financial Report. It further states that the American Institute of Certified Public Accountants' Statement on Auditing Standards communication is intended to facilitate auditor communication regarding the audit process, including roles and responsibilities, observations, findings, audit risks, independence, audit timing, and new accounting standards. The staff report also states that this annual communication should occur at the beginning and conclusion of each audit year. (City of San Ramon Finance Committee Agenda Packet, June 3, 2026, Agenda Item 5.1, pp. 7-8.)
This is not a routine consultant-introduction item. It is an audit-governance item. It is the beginning of the Fiscal Year 2026 Annual Comprehensive Financial Report audit process after a Fiscal Year 2025 audit cycle that already raised serious public concerns regarding the Annual Comprehensive Financial Report, the delayed and separated Memorandum on Internal Control, internal-control deficiencies, late or incomplete audit disclosure, the City's $6,004,488.87 correction, Measure N governance risk, the City's structural deficit, and the completeness of the public administrative record.' My prior comments specifically identified the January 13 correction, negative fund balances, unsupported transfers, unbudgeted expenditures, General Fund backfilling, the missing Internal Controls Memorandum, bank-reconciliation failures, unposted audit adjustments, grant-tracking failures, a missed Single Audit deadline, untimely journal-entry review, cash-handling segregation-of- duties issues, and the City's repeated tendency to present audit and budget rhetoric without matching 1 • accountability. Those prior comments are not separate from this item. They go directly to the Fiscal Year 2026 audit-risk record.

I therefore submit this comment not only as a comment on the auditor's required communication, but also as a follow-up to my prior written and verbal public comments regarding the Fiscal Year 2024/25 Annual Comprehensive Financial Report, the Fiscal Year 2025 Memorandum on Internal Control, the City Council's March 24, 2026 handling of the Internal Controls Memorandum, and the May 26, 2026 City Council budget adoption item. Those prior comments are incorporated by reference because they identify unresolved issues in audit, internal control, fiscal governance, Measure N, transparency, public records, the Financial Resilience Framework, and Council Goals and Objectives that should inform the Fiscal Year 2026 audit from the beginning, not after the audit is substantially complete.

The incorporated comments are: my January 27, 2026 written public comment regarding Agenda Item 9.2, Acceptance of the Fiscal Year 2024/25 Annual Comprehensive Financial Report; my February 18, 2026 written public comment regarding Finance Committee Agenda Item 5.3, Fiscal Year 2025 Memorandum on Internal Control; my February 18, 2026 verbal public comment script regarding the same Finance Committee item; my March 24, 2026 written public comment requesting that City Council Agenda Item 5.4, Fiscal Year 2025 Memorandum on Internal Control, be pulled from the Consent Calendar and formally discussed; and my May 26, 2026 written public comment regarding Agenda Item 8.1, adoption of the Fiscal Year 2026/27 Operating and Capital Budget.

Transparency, Brown Act Compliance, Public Access, and the Administrative Record Any materials related to Agenda Item 5.1, whether provided before, during, or after the June 3, 2026 Finance Committee meeting, must be permanently posted on the City's website in HTML and searchable PDF formats directly adjacent to Agenda Item 5.1. This includes the agenda, staff report, auditor communication, engagement letter, fee attachment, peer-review report, presentation materials, corrected packet pages, written public comments, and any later supplemental materials.

The Finance Committee is not an informal staff meeting. It is a Brown Act legislative body. Government Code section 54952 includes committees of a local agency within the definition of "legislative body," and the California Attorney General's Brown Act guide explains that the Brown Act applies to local agency legislative bodies, including councils, boards, commissions, and committees. (Government Code § 54952; California Attorney General, The Brown Act: Open Meetings for Legislative Bodies, https://oag.ca.gov/system/files/media/the-brown-act.pdf.) The San Ramon Finance Committee plainly functions as a standing committee with continuing subject-matter jurisdiction over finance, budget, audit, investment, internal control, and fiscal governance matters. The June 3 agenda identifies the body as the City of San Ramon Finance Committee, lists Chair Robert Jweinat and Vice Chair Mark Armstrong, describes the meeting as a regular meeting, and states that the agenda is posted in accordance with Government Code section 54954.2(a). The City, therefore, cannot treat Finance Committee public-comment access, agenda descriptions, late materials, written-comment posting, or administrative-record preservation as less formal or less important than City Council procedures.

The City must not fragment public comments across multiple pages, bury them behind excessive navigation, or place them under vague platform labels that do not tell the public what the materials are. In particular, CivicClerk should not place written public comments under a generic or nondescript "Supplemental Material" tab or subheading without a clear "Public Comment" label. "Supplemental Material" is not descriptive enough. It could mean staff revisions, late attachments, consultant slides, • corrected exhibits, handouts, or public testimony. A member of the public should not have to guess whether written public comments are hidden inside a generic materials category.

The immediate issue here is not primarily the 72-hour agenda-posting rule. The immediate issue is that the Finance Committee agenda establishes a written-comment procedure but does not specify where timely written comments will be available for viewing. The June 3, 2026 Finance Committee agenda states that public comments may be submitted by email to [email protected] at least two hours before the start of the meeting, that the subject line should include "Public Comment," and that written public comments will not be read aloud during the meeting. However, the agenda does not state whether timely written comments will be emailed to the Finance Committee, placed in a binder or other physical inspection location at the meeting, posted online, or otherwise made available for public inspection before or during the Committee's consideration of Item 5.1. (City of San Ramon Finance Committee Agenda Packet, June 3, 2026, p. 2.) That omission matters because the Finance Committee consists of two members. When written comments are submitted before the City's two-hour cutoff and distributed to both Committee members, they are distributed to the entire legislative body. Government Code section 54957.5(b)(1) requires agenda-related writings distributed to all or a majority of the legislative body less than 72 hours before a regular meeting to be made available for public inspection at the time they are distributed. The timing trigger is distributed to the legislative body. It is not the start of the meeting, not the moment the Chair calls the item, and not the time when staff places a binder in the back of the room. (Government Code § 54957.5,
https://leginfo.legislature.ca.gov/faces/codes displaySection.xhtml?lawCode=GOV&sectionNum=549

57.5.)
I recognize that the City may argue that placing written comments in a red binder at the meeting is sufficient. That argument is inadequate in this context. A physical binder may be one component of public inspection. Still, it should not be treated as the exclusive method of public access when written comments are submitted electronically, distributed electronically, not read aloud, and capable of being posted electronically before the Committee acts. The City already uses electronic submission. The City already distributes written comments electronically to decision-makers. The City already has an online public-comment posting practice for City Council meetings. In that context, a red binder alone does not meet the practical meaning, public-access purpose, or spirit of the Brown The City Council's own agenda practice demonstrates the point. The May 26, 2026 City Council agenda stated that written comments received up to two hours before the meeting would be emailed to the City Council, placed in the red binder at the meeting, and posted online at https://www.sanramon.ca.gov/public comment. That language told the public where comments would go and where they could be reviewed. It did not treat the red binder as the only access point. The January 27, 2026 City Council meeting notice similarly stated that written public comments received until two hours before the meeting would be distributed to the City Council by email, provided at the meeting in the red binder, and posted online at the same City public-comment webpage.

The June 3 Finance Committee agenda does not provide equivalent information. It accepts written comments via email and states that they will not be read aloud. Still, it does not say they will be posted online, does not identify a public-comment webpage, does not say they will be placed in a red binder, and does not identify a physical inspection location. That is the gap. The problem is not merely whether the City has a binder in the room. The problem is that the agenda fails to disclose 3 • where written public comments may be reviewed and fails to commit to timely electronic posting, even though the comments are submitted electronically, and electronic posting is feasible.

Government Code section 54954.3 requires that every regular meeting agenda include an opportunity for members of the public to directly address the legislative body on any item of public interest before or during the legislative body's consideration of the item. It also provides that the legislative body may not prohibit public criticism of the policies, procedures, programs, services, or acts or omissions of the agency or legislative body. (Government Code § 54954.3, https://leginfo.legislature.ca.gov/faces/codes displaySection.xhtml?lawCode=GOV&sectionNum=549

54.3.)
That opportunity is not meaningful if the City accepts written comments, distributes them to the Committee, declines to read them aloud, and then fails to tell the public where those written comments can be reviewed. The issue is not whether the City must read written comments aloud. The issue is whether the public can see the written record being provided to the legislative body before the body acts, especially when the City itself has created a two-hour cutoff for timely written submissions.

Government Code section 54957.5 reinforces that point. For late-distributed agenda-related writings, the statute requires public availability at the time of distribution to all or a majority of the legislative body. If the City relies on a physical inspection location, that location must be identified on the agenda. If the City relies on the website-posting alternative, the writing must be posted immediately on the City's website in a position and manner that makes clear that the writing relates to an agenda item for an upcoming meeting. A generic "Supplemental Material" tab does not clearly identify written public comments as public comments, and a red binder alone does not satisfy the website-posting pathway. (Government Code § 54957.5(b)(2)(B)(ii),
https://leginfo.legislature.ca.gov/faces/codes displaySection.xhtml?lawCode=GOV&sectionNum=549

57.5.)
The 72-hour reference should not be misapplied as though it creates a 72-hour deadline for public comments. Public comments submitted under a two-hour procedure obviously cannot be submitted 72 hours before the meeting. The more relevant point is that once timely written public comments are received electronically and distributed to the Finance Committee under the City's own procedure, they become agenda-related writings in the legislative body's hands. If those comments are distributed before the meeting, the public should be able to review the same written record before or during the Committee's consideration of the item. If the City uses the Brown Act's website-posting pathway, the posting must be made immediately. It must make clear that the writing relates to the specific agenda item for the upcoming meeting.

Nor should the City avoid public access by delaying distribution to the Committee until the dais packet or the moments before the meeting begins. If staff receive written comments hours or days before the meeting and wait until the meeting room is being prepared to place them in a binder or on the dais, the City has not promoted public access. It has merely delayed the moment when the public can see the written record provided to the decision-makers. That kind of practice is inconsistent with the Brown Act's purpose of ensuring that public agencies act openly and that the people remain informed so they may retain control over the public bodies they created.

The Court of Appeal's decision in Sierra Watch v. County of Placer is instructive. The court held that a writing is not made available for public inspection merely because it is theoretically placed somewhere; it must be actually available for public inspection at the time required by section 54957.5. The court rejected a technical reading that would have allowed a document to be placed in 4 • a county office when the office was closed and still be treated as available. (Sierra Watch v. County of Placer (2021) 69 Cal.App.5th 86, available at https://law.justia.com/cases/california/court-of- appeal/2021/c087892.html.)
The same principle applies here. If the City receives public comments electronically, distributes them electronically, and can post them electronically, then placing them in a binder shortly before the meeting begins is not a meaningful substitute for timely public access. It may provide limited access to the few people physically present in the room. Still, it does not provide practical public access, including those watching remotely, those reviewing the item before deciding whether to attend, those with disabilities or access limitations, or those who reasonably rely on the City's published electronic records.

This is also consistent with guidance from the League of California Cities and the Institute for Local Government. The League's Open & Public guide describes the Brown Act as a floor, not a ceiling. It emphasizes that the public has the right to participate meaningfully and review documents used in decision-making at a relevant point in time. (League of California Cities, Open & Public: A Guide to the Ralph M. Brown Act, https://www.cacities.org/UploadedFiles/LeagueInternet/86/86775625-b7df- 4fc8-ab60-de577631ef1e.pdf.) The Institute for Local Government has similarly advised that if materials are distributed at a meeting, the agenda needs to explain where those materials can be obtained. Its Brown Act question-and-answer guidance recognizes that materials distributed to all or a majority of a legislative body are disclosable public records that must be available for inspection and maintained in accordance with records-retention requirements. (Institute for Local Government, Brown Act webinar materials and supplemental questions, https://www.ca-ilg.org/sites/main/files/file- attachments/brown act webinar - keeping clerks ahead of the curve. pdf; https://www.ca- ilg.org/sites/main/files/file-attachments/brown act webinar q as final 1.pdf.) The Finance Committee agenda should therefore be revised for this and all future meetings to state, at a minimum, that timely written public comments will be emailed to the Finance Committee, made available for public inspection at the meeting location, and posted online at a specifically identified webpage before or at the same time they are distributed to the Committee, when technologically feasible. The agenda should also state that written comments will be clearly labeled by agenda item, such as "Public Comment - Agenda Item 5.1," and not buried under a generic "Supplemental Material" label.

The administrative record for Item 5.1 should include this comment, any attachments, all other written public comments, the auditor's required communication, the engagement letter, any presentation slides, any correspondence between staff and the auditor regarding the packet, any corrected pages, and any follow-up written responses. If the Finance Committee receives and accepts the auditor communication, the record should show what the Committee actually received, what questions were asked, what public concerns were presented, what materials were available to the public at the time of distribution, and what follow-up actions were directed.

Item 5.1 Is an Audit-Governance Item, Not a Routine Consultant Introduction The staff report frames Item 5.1 as an opportunity for the Finance Committee to engage in discussions with consultants who have key roles in the "management and safekeeping of City assets and operations." That wording is important. The auditor's communication is not merely a procedural courtesy. It is part of the governance structure for the Fiscal Year 2026 Annual Comprehensive Financial Report. The staff report states that the auditor will specifically address the engagement team, deliverables and scope of the audit, areas of primary audit risk, responsibilities of the auditor and management, independence, audit timing, and new accounting standards. It also states that the 5 remaining required communication items will be addressed once the audit is complete and a draft report is presented to the Finance Committee for City Council review. (City of San Ramon Finance Committee Agenda Packet, June 3, 2026, pp. 7-8.)
That matters because the Fiscal Year 2025 audit cycle already raised significant issues regarding internal controls, bank reconciliations, prior-year audit adjustments, grant tracking, journal-entry review, cash-handling segregation of duties, delayed audit deliverables, and the administrative record. The Fiscal Year 2026 audit should begin with those issues squarely in view.

The auditor's May 21, 2026, communication states that the audit will address whether the City's basic financial statements for the year ending June 30, 2026, are fairly presented in conformity with United States Generally Accepted Accounting Principles. It also states that the audit will consider internal control for purposes of determining audit procedures; test compliance with certain laws, regulations, contracts, and grants; and consider internal control over compliance with requirements that could have a direct and material effect on a major federal program if a Single Audit is required. The communication further states that the audit of the financial statements does not relieve the Finance Committee or management of their responsibilities. (City of San Ramon Finance Committee Agenda Packet, June 3, 2026, Attachment A, pp. 9-11.)
That point should be emphasized. The external audit is not a substitute for City management's own internal controls. The audit is not designed to guarantee the detection of every misstatement, every compliance failure, or every internal control weakness. The City cannot rely on the existence of an audit to substitute for timely reconciliations, accurate fund accounting, complete grant tracking, proper journal-entry review, effective segregation of duties, accurate Measure N reporting, or complete public disclosure.

The auditor's communication also expressly invites Finance Committee members to participate in the audit process by responding to questions about whether they are aware of fraud, areas susceptible to fraud, possible or actual noncompliance, waste or abuse of programs and controls, or related-party transactions involving the City, its component units, or elected or appointed officials. (City of San Ramon Finance Committee Agenda Packet, June 3, 2026, Attachment A, p. 11.) I am not alleging fraud in this comment. However, I am identifying areas susceptible to material misstatement, internal control failure, noncompliance, waste, abuse of programs or controls, or incomplete public accountability, based on the City's recent audit history and public budget records. Those areas include the prior $6,004,488.87 correction disclosed in January 2026; negative fund balances in internal service funds; unsupported transfers; unbudgeted expenditures; delayed year-end close; failure to timely provide the full Internal Controls Memorandum with the Annual Comprehensive Financial Report; the prior finding that bank reconciliations had not been completed for months; failure to post prior-year audit adjustments; grant-tracking failures; the missed Single Audit deadline; untimely journal-entry review; cash-handling segregation-of-duties issues; the acknowledged extended absence of an Accounting Manager; reliance on consultants to supplement core finance functions; and the City's ongoing dependence on Measure N to cover a structural deficit.

Those issues are directly relevant to the audit-planning record now before the Finance Committee.

Prior Annual Comprehensive Financial Report and Internal Controls Comments Must Be Part of the Fiscal Year 2026 Audit-Risk Record
• My prior comments regarding the Fiscal Year 2024/25 Annual Comprehensive Financial Report and Fiscal Year 2025 Memorandum on Internal Control should be provided to Maze & Associates and included in the Fiscal Year 2026 audit-planning record.

The January 27, 2026 Annual Comprehensive Financial Report comment identified the City's Janua 13, 2026 disclosure of $6,004,488.87 in corrections required to close Fiscal Year 2024/25. Those corrections were not routine. They involved negative fund balances, unsupported transfers, unbudgeted expenditures, multi-year liabilities requiring General Fund backfilling, a $4.52 million "dL to General Fund" liability, a delayed year-end close, incomplete standard procedures, loss of institutional knowledge, and reliance on an outside certified public accountant consultant to unwind legacy practices.

The February 18, 2026 Finance Committee written comment and verbal script addressed the Fiscal Year 2025 Memorandum on Internal Control. It explained that the Memorandum appeared to have been dated January 12, 2026, which would have meant it could have been included with the Annual Comprehensive Financial Report presented to the City Council on January 27. Instead, the City Council was asked to receive an incomplete audit presentation, and the Internal Controls Memorandum was presented later to the Finance Committee. That sequence deprived the full City Council and the public of a complete audit record when the Annual Comprehensive Financial Repor was presented.

The March 24, 2026 City Council comment then requested that the Fiscal Year 2025 Memorandum on Internal Control be pulled from the Consent Calendar and formally discussed, because the findings were not routine, not ministerial, and not appropriate for silent acceptance. That comment also explained that the findings were directly connected to the $6 million correction and that the City Council needed to document the connection, require a corrective-action plan, and commit to presenting all audit deliverables together in future Annual Comprehensive Financial Report cycles.

Those prior comments remain directly relevant to Item 5.1. The Fiscal Year 2026 audit should not repeat the Fiscal Year 2025 process. The auditor, Finance Director, City Manager, Finance Committee, and City Council should confirm at the beginning of this audit cycle that all audit deliverables will be provided together; that internal-control findings will not be delayed or routed in a way that separates them from the Annual Comprehensive Financial Report; that the full City Counci will receive the complete audit record; and that public comments identifying audit-risk concerns will ! provided to the auditor.

The Finance Committee should also recognize that the Fiscal Year 2026 audit is occurring after the City adopted, or was asked to adopt, a Fiscal Year 2026/27 budget that remains dependent on Measure N to cover a structural deficit. The May 26, 2026 City Council budget staff report states th the Fiscal Year 2026/27 budget "continues to show a structural deficit that is alleviated by the use o Measure N receipts," identifies a projected Fiscal Year 2025/26 operational structural deficit of $12. million, and identifies a Fiscal Year 2026/27 structural deficit of $13.7 million to which $14.9 million , expected Measure N will be applied. (City of San Ramon City Council Agenda Packet, May 26, 202 Agenda Item 8.1, pp. 224-226.)
That Measure N context makes audit-risk planning more important, not less. A temporary transactions and use tax used to cover ordinary operating deficits requires heightened audit transparency, strong General Fund controls, clear revenue tracking, accurate transfers, reliable funi balance reporting, and complete public disclosure.
7 The Fiscal Year 2026 Audit Must Be Tied to the Council's Goals and the Financial Resilience Framework
This comment is also directly tied to the City Council's Fiscal Year 2026/27 Goals and Objectives. Goal 2 is to "Maintain a Secure Financial Base," including enhanced financial forecasting and exploration of revenue growth options alongside broader cost-saving strategies. Goal 3 is to "Provide Cost Effective and Responsive Services to Sustain Quality of Life," including standardized department analysis and reporting of service data, consistent metrics, and risk-management briefings. Goal 5 is to "Enhance Engagement and Communication with Residents and Business Community," including website improvements and better public communication. (City of San Ramon Fiscal Year 2026/27 Proposed Operating Budget, City Council Goals, pp. 13-14 and pp. 140-143.) The Fiscal Year 2026 audit process is central to all three goals. The City cannot maintain a secure financial base if internal-control recommendations remain unresolved, if audit deliverables are separated from the Annual Comprehensive Financial Report, if management representations are accepted without a clear corrective-action record, or if the City continues relying on Measure N without strong controls over General Fund revenues, transfers, reserves, and structural-deficit reporting.

The City cannot provide cost-effective and responsive services if its financial data, grant tracking, fund balances, internal service fund charges, and budget-to-actual analysis are unreliable. Cost- effective service delivery depends on reliable accounting. Reliable accounting depends on internal controls. Internal controls depend on timely reconciliations, complete grant tracking, prompt audit adjustments, segregation of duties, and clear responsibility for finance management.

The City cannot enhance engagement and communication if public comments are not clearly labeled, if meeting agendas do not identify where written comments are available for viewing, if materials are buried under vague "Supplemental Material" headings, or if the Annual Comprehensive Financial Report is published in a form that is difficult for the public to search, navigate, or understand.

The Finance Committee should therefore treat Item 5.1 as part of the same governance framework that the City invoked when adopting the Fiscal Year 2026/27 budget and discussing the Financial Resilience Framework. Audit communications are not separate from fiscal resilience. They are the control structure that determines whether the City's fiscal-resilience claims can be trusted.

The Packet Contains Record-Integrity and Timing Issues That Should Be Corrected Before Acceptance
The June 3 packet contains at least two apparent inconsistencies that should be clarified on the record before the Finance Committee receives and accepts Item 5.1.

First, the staff report states that Finance staff is "currently preparing for the Interim portion of the audit," which "will occur the week of June 8." That is prospective language. But the auditor's communication later states that "the interim phase of the audit (internal control review and tests) was completed the week of June 8, 2026." Because the Finance Committee meeting is scheduled for June 3, 2026, the interim audit phase cannot have already been completed the week of June 8 unless the packet language is template language or was prepared for a different date. The Committee should clarify whether the interim audit has occurred, will occur, or whether the auditor's communication contains an error. (City of San Ramon Finance Committee Agenda Packet, June 3, 2026, pp. 8 and 11.)
8 • Second, the engagement letter response page appears to show the Finance Director's signature date as June 20, 2026. That date is after the June 3, 2026 Finance Committee meeting and after the May 18, 2026, engagement letter date. If the signature date is the result of a typographical or packet- assembly error, it should be corrected. If it is not an error, the Committee should clarify how the engagement letter could be presented as signed before the date shown on the response page. Either way, this is exactly the type of record-integrity issue that should be corrected on the public record before the Committee accepts the communication. (City of San Ramon Finance Committee Agenda Packet, June 3, 2026, Attachment A, p. 20.)
These issues may be minor in isolation. But in context, they matter. The City's prior Annual Comprehensive Financial Report and Internal Controls Memorandum process already raised concerns about audit timing, missing deliverables, delayed disclosure, incomplete records, and selective presentation of audit information. A packet requesting that the Finance Committee accept required audit communications should be internally consistent, date-accurate, and clear.

Management Responsibilities Must Be Addressed Publicly
The engagement letter places substantial responsibility on City management. It states that management is responsible for designing, implementing, establishing, and maintaining effective internal controls relevant to the preparation and fair presentation of financial statements; following laws and regulations; ensuring reasonable assurance that programs are administered in compliance with requirements; ensuring that management and financial information is reliable and properly reported; making records and information available to the auditor; preventing and detecting fraud; informing the auditor of known or suspected fraud; identifying and ensuring compliance with laws, regulations, contracts, agreements, and grants; taking timely and appropriate steps to remedy fraud and noncompliance; promptly following up and taking corrective action on audit findings; and preparing a summary schedule of prior audit findings and a separate corrective action plan when applicable. (City of San Ramon Finance Committee Agenda Packet, June 3, 2026, Attachment A, pp. 16-18.)
Those responsibilities should be discussed openly because they are directly connected to the concerns previously raised regarding the Fiscal Year 2025 audit cycle. The City had significant deficiencies and other matters identified in the Internal Controls Memorandum. The City had material corrections requiring General Fund backfilling. The City had grant-tracking failures serious enough to affect the Single Audit schedule. The City has acknowledged an extended absence of an Accounting Manager. The City is relying on Measure N to cover an ongoing structural deficit. The City's Financial Resilience Framework remains in progress. Those facts make management's responsibilities more important, not less.

The Finance Committee should ask staff and the auditor to identify how the Fiscal Year 2026 audit will specifically test or consider the prior-year deficiencies, whether the prior corrective actions have been completed, whether the City has a current written corrective-action matrix, and whether that matrix has been provided to the auditor.

The Committee should also ask whether the acknowledged extended absence of the Accounting Manager affects audit risk, audit timing, closing procedures, management representations, staff capacity, internal control, or audit fees. At approximately 2:50:49 in the April 28, 2026 City Council budget presentation, the City acknowledged using a "consulting service firm to supplement the ... existing extended absence of the ... accounting manager." That statement is directly relevant to the Fiscal Year 2026 audit. The auditor's fee attachment expressly recognizes that changes or reductions in Finance Department staff can have a pronounced impact on audit costs and that Maze & Associates may meet with the City to assess the impact of such changes before the next phase of • work. (City of San Ramon Finance Committee Agenda Packet, June 3, 2026, Fees Attachment, p. 22; City Council Meeting recording, April 28, 2026, YouTube, approximately 2:50:49, https://youtu.be/- ZdBP-C8eBA?si=1T-y1GM1wuDz1Efv.)
The Accounting Manager issue should not be left as an oral aside from a prior budget presentation. It should be part of the Fiscal Year 2026 audit-risk discussion.

Auditor Independence, City Records, and Public Inspection Must Be Protected The packet contains important language regarding records and auditor independence. The engagement letter states that the auditor cannot retain the City's documents on the City's behalf because doing so would impair independence under the American Institute of Certified Public Accountants Code of Professional Conduct. It further states that the City is responsible for maintaining its own data and records, that SharePoint or OneDrive are used only to transmit or exchange information, that they are not intended to store the City's information, and that the City is responsible for downloading deliverables and other records it wishes to retain at completion of the engagement. It also states that data and other content will either be removed from SharePoint or OneDrive or become unavailable to the City within a reasonable timeframe, generally one week after the report is issued. (City of San Ramon Finance Committee Agenda Packet, June 3, 2026, Attachment A, p. 19.)
That language should be taken seriously. It means the City cannot rely on the auditor's SharePoint, OneDrive, portal, working files, or transmission system as a substitute for City records management. The City must maintain its own audit records, Annual Comprehensive Financial Reports, Internal Controls Memoranda, management representation letters, corrective action plans, auditor communications, agenda materials, public comments, and related correspondence. Those records must remain under City control, retained in accordance with the City's records-retention obligations, and posted or made available to the public unless exempt from disclosure.

The same engagement letter also states that, unless restricted by law or regulation or containing privileged and confidential information, copies of the auditor's reports are to be made available for public inspection. That statement should be implemented as a public-access commitment rather than treated as boilerplate. The final Annual Comprehensive Financial Report, Memorandum on Internal Control, Government Auditing Standards report, Single Audit report if required, Controller's Report, Gann Appropriations Limit agreed-upon procedures report, Transportation Development Act reports if required, and related communications should be posted in a searchable, durable, publicly accessible form.

The City's website and CivicClerk practices must support that obligation. If public comments or audit documents are buried under "Supplemental Material," placed on temporary pages, posted in non- searchable or inaccessible formats, or separated from the agenda item they address, the City is not meeting the transparency standards its own Council Goals require.

The Annual Comprehensive Financial Report Should Be Posted as a Searchable, Web-Ready, Public-Facing Document
The fee attachment states that "print to PDF" versions of reports are provided at no charge, but that those reports do not include bookmarks or hyperlinks and may have large file sizes. It also lists a "WEB PDF Annual Comprehensive Financial Report" option for $875. (City of San Ramon Finance Committee Agenda Packet, June 3, 2026, Fees Attachment, p. 21.) 10 For a City that repeatedly emphasizes transparency, fiscal accountability, community engagement, website improvement, and public trust, the final Annual Comprehensive Financial Report should not be posted as a minimally navigable print-to-PDF file if a web-ready, bookmarked, hyperlinked version is available. A public-facing Annual Comprehensive Financial Report is not merely an accounting deliverable. It is one of the City's most important public financial disclosure documents.

The City should therefore now commit to posting the Fiscal Year 2026 Annual Comprehensive Financial Report and related audit reports as accessible, searchable, bookmarked, and web-usable PDFs. If the City declines to purchase or prepare the web-ready version, staff should explain why the City is unwilling to spend $875 to make its most important annual financial report usable by residents, taxpayers, journalists, community members, Finance Committee members, Councilmembers, and interested parties.

This request is directly tied to Goal 5's website and engagement objectives. A city cannot claim to be improving user experience while publishing major financial documents in formats that are difficult to search, navigate, or reuse.

Measure N, the Structural Deficit, and the Fiscal Year 2026 Audit The Fiscal Year 2026 audit will cover a year in which Measure N became a central part of the City's General Fund structure. The Fiscal Year 2026/27 budget materials show that Measure N is being used to cover the City's structural deficit and that the City intends to reduce reliance on Measure N before it expires in 2035. This makes the Fiscal Year 2026 audit especially important.

Measure N revenues flow into the General Fund. The General Fund is the same fund that absorbed the prior $6,004,488.87 correction. The General Fund is the same fund used to support the City's reserve narrative. The General Fund is the same fund affected by transfers, internal-service-fund corrections, projected actuals, Measure N assumptions, capital carryovers, and the structural deficit. If the City lacks strong internal controls, timely reconciliations, accurate audit adjustments, complete grant tracking, clear management representations, and reliable financial reporting, the public cannot evaluate whether Measure N is being managed with the rigor voters were promised.

The auditor's fraud-risk and noncompliance questions, therefore, should not be treated as abstract. The Committee should ask how the Fiscal Year 2026 audit will address Measure N revenues, whether Measure N will be separately tracked or disclosed, whether controls over Measure N receipts and use will be tested, whether Measure N reporting will be reconciled to the budget and General Fund activity, and whether the Annual Comprehensive Financial Report will clearly explain Measure N's relationship to the structural deficit.

A temporary tax used to cover ordinary operations requires heightened transparency. It should not be folded into broad General Fund reporting in a way that prevents the public from determining how much was received, how much was used, what it supported, and whether the City is reducing or increasing its dependence on it.

The Finance Committee Should Not Quietly Accept the Communication Without Direction The recommendation for Item 5.1 is that the Finance Committee "receive and accept" the required communications. Acceptance should not be silent. Acceptance should include questions, clarifications, and direction.
11 At a minimum, the Finance Committee should ask the auditor and staff to confirm whether the Fiscal Year 2026 audit plan specifically incorporates the Fiscal Year 2025 Memorandum on Internal Control findings, the prior $6,004,488.87 correction, the missed Single Audit deadline, grant-tracking issues, prior-year audit adjustments, bank-reconciliation issues, journal-entry review issues, cash-handling segregation-of-duties issues, and the extended absence of the Accounting Manager.

The Finance Committee should also ask whether public comments submitted for Item 5.1 will be provided to the auditor as audit-risk information. The auditor's letter asks Committee members whether they are aware of fraud, susceptibility to fraud, noncompliance, waste, abuse, or related- party transactions. Public comments submitted on those subjects should not simply be placed in a public-comment file and forgotten. They should be transmitted to the auditor and included in the audit-planning record.

Finally, the Committee should ask whether the full City Council will receive the complete Fiscal Year 2026 audit deliverables together, including the Annual Comprehensive Financial Report, Memorandum on Internal Control, Government Auditing Standards report, Single Audit report if required, Gann Appropriations Limit agreed-upon procedures report, and any required communications at the conclusion of the audit. The Fiscal Year 2025 process should not be repeated.

The staff report states that the Finance Committee may prescribe an alternative schedule for these communications. The Committee should use that authority, if necessary, to ensure that the audit communication process is complete, timely, transparent, and aligned with the City's Financial Resilience Framework and Council Goals. (City of San Ramon Finance Committee Agenda Packet, June 3, 2026, p. 8.)
Specific Requests
Before receiving and accepting Agenda Item 5.1, I respectfully request that the Finance Committee ask staff and the auditor to address the following on the record.

First, the Committee should require correction or clarification of the apparent audit-timing inconsistency between the staff report's statement that interim audit work "will occur" the week of June 8 and the auditor communication's statement that the interim phase "was completed" the week of June 8, 2026.

Second, the Committee should require correction or clarification of the engagement letter response page showing a Finance Director signature date of June 20, 2026, which is after the June 3 Finance Committee meeting.

Third, the Committee should direct staff to revise future Finance Committee agendas to explicitly state where timely written public comments will be available for public inspection before or during the meeting, including both the physical location at the meeting and the online location where comments will be posted.

Fourth, the Committee should direct staff to post timely written public comments for Item 5.1 in a clear, publicly identified electronic location when feasible, before or at the same time those comments are distributed to the Finance Committee, and before the Committee receives and accepts the item.

Fifth, the Committee should direct staff not to treat a physical red binder as a substitute for electronic posting when written public comments are submitted electronically, distributed electronically, not read aloud, and capable of being posted electronically before the Committee acts. 12 Sixth, the Committee should direct staff to stop using only the generic "Supplemental Material" label for written public comments in CivicClerk and instead use a clear label such as "Public Comment - Agenda Item 5.1."
Seventh, the Committee should distinguish between late-distributed City, staff, consultant, or corrected agenda materials, which implicate the Brown Act's less-than-72-hour public-inspection requirements, and timely written public comments submitted under the City's two-hour cutoff, which must still be made visible to the public in a clearly identified location before the Committee acts whenever feasible.

Eighth, the Committee should confirm that written public comments submitted for Agenda Item 5.1 will not be withheld from public view until after the meeting merely because staff delays distribution to the Committee until the dais packet, the red binder, or the moments immediately before the meeting begins.

Ninth, the Committee should confirm that this comment, its attachments, and all other Item 5.1 public comments will be provided to Maze & Associates as part of the Fiscal Year 2026 audit-planning record.

Tenth, the Committee should ask the auditor how the Fiscal Year 2026 audit plan will address the Fiscal Year 2025 Memorandum on Internal Control findings, including bank reconciliations, prior-year audit adjustments, grant tracking, Single Audit timing, journal-entry review, and cash-handling segregation of duties.

Eleventh, the Committee should ask staff whether all corrective actions from the Fiscal Year 2025 Memorandum on Internal Control have been completed; if not, require a written corrective-action matrix detailing responsible staff, completion dates, and current status.

Twelfth, the Committee should ask whether the extended absence of the Accounting Manager affects audit risk, closing procedures, internal controls, management representations, audit timing, audit fees, or the City's ability to complete schedules and data requested on the auditor's closing checklist.

Thirteenth, the Committee should ask how the Fiscal Year 2026 audit will address Measure N revenues, General Fund structural-deficit reporting, Measure N use, and the relationship between Measure N and the City's reserve and Financial Resilience Framework narratives.

Fourteenth, the Committee should require staff to maintain all City audit records under City control and not rely on the auditor's SharePoint, OneDrive, portal, or transmission platform as a substitute for City records retention.

Fifteenth, the Committee should direct staff to post the final Fiscal Year 2026 Annual Comprehensive Financial Report and related audit reports as accessible, searchable, bookmarked, web-ready PDFs.

Sixteenth, the Committee should confirm that the Fiscal Year 2026 Annual Comprehensive Financial Report, Memorandum on Internal Control, Government Auditing Standards report, Single Audit report if required, and other audit deliverables will be presented together to the full City Council, rather than separated across multiple meetings or routed first to the Finance Committee in a manner that delays full Council oversight.
13 • Seventeenth, the Committee should direct that all Fiscal Year 2026 audit materials be tied back to the City Council's Goal 2 regarding a secure financial base, Goal 3 regarding cost-effective and responsive services and risk management, and Goal 5 regarding engagement, communication, website improvement, and public access.

Conclusion
The Finance Committee should not receive and accept Agenda Item 5.1 as a routine consultant communication. This item is the beginning of the Fiscal Year 2026 audit-governance process. It arises after a Fiscal Year 2025 audit cycle that already produced significant concerns regarding internal controls, delayed or separated audit deliverables, a $6,004,488.87 correction, grant-tracking failures, Single Audit timing, Measure N governance risk, and public-access deficiencies.

The public access issue is not solved by assuming that a red binder may exist somewhere in the meeting room. A red binder may provide limited physical inspection for people present. Still, it does not provide meaningful access for the broader public when comments are submitted electronically, distributed electronically, not read aloud, and capable of being posted electronically. Nor does it satisfy the public-facing transparency needed when a two-member Finance Committee receives written comments before acting on an audit-governance item. The agenda should clearly indicate where timely written comments can be reviewed, and the City should, whenever feasible, post those comments online in a clearly labeled location before the Committee acts.

Nor is a generic "Supplemental Material" tab sufficient if the City is relying on electronic posting to provide public access. A posting label should tell the public what the material is and what item it concerns. "Public Comment - Agenda Item 5.1" is clear. "Supplemental Material" is not. If written comments are hidden under a vague heading, separated from the agenda item, posted after the meeting, or made available only in a physical binder minutes before the meeting begins, the public is not being given meaningful access to the written record being provided to the legislative body.

The City has stated that it is pursuing financial resilience, a secure financial base, cost-effective services, improved risk management, better communication, and improved website access. Those commitments must be implemented in the audit process. They cannot remain budget rhetoric or Council goal language disconnected from actual practice.

A proper Fiscal Year 2026 audit process should begin with a complete, clear, and public record. It should correct packet inconsistencies. It should provide timely access to written public comments. It should clearly label public comments as public comments. It should identify where those comments may be viewed. It should not rely solely on a red binder when electronic posting is feasible and consistent with the City's public-comment process. It should preserve audit records under City control. It should provide the auditor with public comments identifying audit-risk concerns. It should address prior internal-control failures directly. It should protect Measure N accountability. It should ensure that the final Annual Comprehensive Financial Report is searchable, accessible, and web- ready. And it should ensure that the full City Council receives the complete audit deliverables together.

The Finance Committee should accept the auditor's communication only if it includes the recorded clarifications and directions. Anything less risks repeating the same procedural, transparency, and audit-governance failures that undermined the Fiscal Year 2025 audit process.

Respectfully submitted,
14 Brian C. Swanson, AICP
San Ramon Voter, Taxpayer, and Resident
On Mon, Jun 1, 2026 at 12:05 PM City of San Ramon <[email protected]> wrote:

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City of San Ramon | 7000 Bollinger Canyon Road, San Ramon, CA 94583 | (925) 973-2500 | www.sanramon.ca.gov 15 M Gmail Brian Swanson <[email protected]>
Public Comment: Agenda Item 9.2 - Audited Annual Comprehensive Financial Report (ACFR) for the City of San Ramon for the Fiscal Year Ended June 30, 2025 - City Council Meeting - January 27, 2026, begining at 7:00 p.m. 1 message
Brian Swanson & Mon, Jan 26, 2026 at 6:27 PM
To: Clerk City <[email protected]>, Council City <[email protected]>, planningcommission <[email protected]>, Jennifer Wakeman <[email protected]> Cc: [email protected], [email protected], [email protected], Jim Blikenstaff <[email protected]>, "Ms. Jessica L.

Blome" <[email protected]>
City Council:

This public comment pertains to Agenda Item 9.2 - Acceptance of the FY 2024-25 Annual Comprehensive Financial Report (ACFR). My remarks address two major areas of concern.

Part 1 examines the January 13, 2026 balance-sheet corrections totaling $6,004,488.87, including negative fund balances, unsupported transfers, unbudgeted expenditures, and multi-year liabilities that required General Fund backfilling. These issues raise not only technical accounting questions but also ethical concerns under the Government Finance Officers Association (GFOA) Code of Ethics and Code of Professional Conduct, as well as the professional standards governing certified public accountants (American Institute of Certified Public Accountants), International City/County Management Association (ICMA) members, and American Institute of Certified Planners (AICP)-certified planners. Part 2 evaluates the ACFR itself, identifying independent taxpayer concerns related to structural deficits, capital spending volatility, fund fragmentation, long-term liabilities, and the absence of clear internal control reporting. Together, these issues demonstrate that the ACR, as presented, does not provide the complete, transparent, and ethically compliant financial picture required for informed Council action.

Access, Transparency, and Administrative Record Requirements As with all of my public comments, I must reiterate the City's obligations regarding public access to the administrative record:
• These public comments must be permanently visible and easily accessible on the City of San Ramon website, in both HTML and searchable PDF formats. • All public materials-—including the staff report, attachments, and all submitted public comments-must be posted together and directly adjacent to the specific agenda item on the main meeting webpage, reachable in one or two clicks.
• Link integrity and accessibility must be actively maintained so that interested parties can locate and verify the administrative record without unnecessary barriers.

Failure to maintain accessible, consolidated, and permanent public records undermines procedural fairness and materially impedes meaningful public participation.

PART 1 - January 13, 2026: Material Balance-Sheet Corrections and Ethical Obligations On January 13, the City Council approved Agenda Item 9.2 documenting $6,004,488.87 in corrections required to close FY 2024-25. These were not routine adjustments; they were material corrections revealing significant internal control, accounting, and fund-management failures.

1. Material accounting errors documented on January 13
The staff report disclosed:
• Negative fund balances in multiple internal service funds. • Unbudgeted expenditures, including a $1.079 million CaPERS UAL payment and $878,000 in salaries and benefits.
• Unsupported transfers, including a $1.768 million transfer that had no identified funding source and had to be reversed.
• A $4.52 million "due to General Fund" liability, including $2.2 million carried forward from the prior year.
• A delayed year-end close, incomplete standard procedures, and loss of institutional knowledge.
• Reliance on an outside CPA consultant (MGO) to unwind "legacy practices." These are material errors, not routine adjustments.

2. Ethical implications under professional standards
A. Government Finance Officers Association (GFOA) Code of Ethics and Code of Professional Conduct
GOA requires finance officers to:
• Provide full, accurate, and timely disclosure of financial information. • Demonstrate integrity, honesty, and accountability in all professional activities. • Avoid any actions that compromise public trust.
• Ensure that financial reports are complete, transparent, and not misleading.

The January 27 ACFR staff report omits the January 13 corrections entirely, raising concerns under these standards.

B. American Institute of Certified Public Accountants (AICPA) Code of Professional Conduct
CPAs must adhere to:
• Integrity, requiring honesty and candor.
• Objectivity, requiring freedom from conflicts of interest. • Due care, requiring competence and diligence.
• Full disclosure of all material facts.

The existence of multi-year liabilities, unsupported transfers, and negative fund balances raises questions about whether due care and integrity were consistently applied.

C. International City/County Management Association (ICMA) Code of Ethics ICMA members must:
• Provide the governing body with full, accurate, and timely information. • Demonstrate honesty and integrity in all actions.
• Ensure transparency in public decision-making.

Omitting the January 13 corrections from the ACR narrative conflicts with these obligations.

D. American Institute of Certified Planners (AICP) Code of Ethics AICP members must:
• Provide full, clear, and accurate information to the public. • Serve the public interest above all else.
• Avoid withholding or distorting information.

Financial conditions directly affect planning, capital improvements, and service delivery. Omitting material fiscal corrections undermines the public interest.

3. The General Fund absorbed the entire $6 million correction The City transferred:
• $586,753.90 to the Insurance Fund.
• $2,757,067.66 to the Healthcare Fund.
• $46,233.55 to the Infrastructure Fund.
• $845,543.76 to the POB Fund.
• $1,768,890.00 through reversal of an unsupported transfer.

This reduced the General Fund's available balance by $6,004,488.87.

4. Required disclosures under GASB
Material corrections must be disclosed as:
• Prior period adjustments.
• Restatements of beginning balances.
• Corrections of error.
• Explanations in the MD&A.
• Note disclosures in the financial statements.

The ACR contains none of these disclosures.

PART 2 — January 27, 2026: Independent Taxpayer Concerns Within the ACFR Itself Even without the January 13 context, the ACR raises significant taxpayer concerns.

Section 1 — Long-standing structural deficit with no adopted long-term plan The ACR acknowledges:
• A five-year structural deficit.
• A projected $17.6 million shortfall for FY 2024-25.
• Continued imbalance in FY 2025-26.
• Reliance on Measure N, a temporary ten-year tax.

Yet the ACR provides no adopted plan to restore balance before Measure N expires.

SECTION 2A — Misleading Use of Reserves as a Construct
The ACFR repeatedly highlights the General Fund's $29.1 million fund balance and emphasizes that this represents a 45% reserve, exceeding the City's 36% reserve policy. However, this presentation is misleading because it treats the reserve figure as evidence of fiscal strength while ignoring the structural and operational realities that undermine it.

1. The reserve ratio is inflated by one-time corrections, not structural health The General Fund's ending balance includes the effects of the January 13 corrections, which:
• Eliminated negative fund balances in multiple internal service funds. • Absorbed multi-year liabilities.
• Reversed unsupported transfers.
• Covered unbudgeted expenditures.

The ACFR presents the resulting reserve level as a sign of stability, but the reserve is only "high" because the General Fund was forced to absorb $6 million in accumulated problems.

2. A high reserve ratio does not offset a structural deficit A high reserve ratio cannot mask the fact that ongoing revenues do not cover ongoing expenditures. Presenting reserves as evidence of fiscal health is a narrative choice, not a financial reality.

3. The reserve ratio is not contextualized with future obligations The ACFR does not explain how reserves will be affected by:
• Pension contribution volatility.
• OPEB obligations.
• Capital maintenance backlogs.
• Internal service fund pressures.
• Long-term debt service.

Without this context, the reserve figure is not meaningful.

4. The ACFR uses reserves as a rhetorical device, not an analytical one The ACFR emphasizes reserves in ways that:
• Reassure readers about stability.
• Highlight compliance with policy.
• Create an impression of fiscal strength.

But the ACFR does not:
• Show how quickly reserves could be depleted under current trends. • Provide a multi-year reserve projection.
• Explain the relationship between reserves and the structural deficit. • Disclose the impact of the January 13 corrections on reserve levels.

This is why the reserve narrative functions as a "fake construct" — technically accurate but substantively misleading.

5. GOA ethical standards require full context, not selective framing Under the GOA Code of Ethics, finance officers must:
• Present information fairly and objectively.
• Avoid misleading or incomplete representations.
• Ensure that financial reports provide full context for decision-makers.

Highlighting reserves without explaining the structural deficit, the January 13 corrections, or long-term obligations violates the spirit of these standards.

Section 3 — Capital Improvements Fund overspent its budget by nearly $9 million Supplementary schedules show:
• Budgeted expenditures: $9,015,289.
• Actual expenditures: $17,923,415.
• Over budget by $8,908,126.

The ACFR provides no explanation for this extraordinary variance.

Section 4 - Highly fragmented fund structure obscures fiscal stress The City maintains dozens of special revenue, debt service, and internal service funds. The ACFR provides no consolidated explanation of:
• Which funds are structurally healthy.
• Which funds rely on General Fund subsidies.
• How fund interactions affect long-term fiscal stability.

Section 5 - Pension and OPEB liabilities remain significant The ACFR reports:
• A $46.9 million net pension liability.
• A $9.6 million OPEB liability.
• $50.8 million in long-term debt.

But the ACR provides no stress-testing, scenario analysis, or long-range integration.

Section 6 — Internal control transparency is limited
The ACFR emphasizes:
• Awards.
• AAA ratings.
• Positive financial highlights.

But it provides no detail on:
• Internal control weaknesses.
• Auditor-identified deficiencies.
• Process improvements.

The Internal Controls Memorandum is missing, with no summary provided.

Section 7 - Narrative imbalance: optics over substance
The ACFR:
• Highlights accomplishments.
• Emphasizes stability.
• Celebrates awards.
• Reassures readers about reserves.

But it does not:
• Discuss operational risks.
• Explain capital spending volatility.
• Address fund-level imbalances.
• Provide a clear roadmap for fiscal sustainability.

This imbalance undermines transparency and creates a misleading impression of stability and routine operations.

CONCLUSION
Even with the recent creation of a standalone Finance Department and the appointment of a new Finance Director, the City continues a pattern of mischaracterization, incomplete disclosure, inconsistent narrative, and insufficient transparency. The ACR highlights optics over substance, emphasizing awards, reserves, and accomplishments while omitting the operational risks, capital spending volatility, fund-level imbalances, and long-term fiscal challenges that taxpayers deserve to understand.

Given the material corrections disclosed on January 13, the ethical obligations of municipal finance professionals, and the independent taxpayer concerns within the ACR itself, the Council should not accept the ACFR tonight without:
• A reconciliation of the January 13 corrections.
• A summary of internal control findings.
• Required GASB disclosures.
• A corrected narrative.
• An explanation of the Capital Improvements Fund overrun. • A long-term fiscal plan addressing the structural deficit. • Full compliance with public access and transparency requirements.

The public deserves a complete, accurate, and transparent accounting of the City's finances before the ACR is accepted into the record.

Respectfully submitted,
Brian C. Swanson, AICP
San Ramon Voter, Taxpayer, and Resident
On Fri, Jan 23, 2026 at 4:48 PM City of San Ramon <[email protected]> wrote:

The City of
San Ramon San Ramon
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City of San Ramon | 7000 Bollinger Canyon Road, San Ramon, CA 94583 | (925) 973-2500 | www.sanramon.ca.gov Public Comment Script - Finance Committee Meeting -
Agenda Item 5.3 -
FY25 Memorandum on Internal Control
February 18, 2026, beginning at 4 p.m.

Good evening. This comment addresses Item 5.3.

The Internal Controls Memorandum before you is dated
January 12, 2026. If that date is accurate, then the City had two full weeks to include this memo with the Audited Annual
Comprehensive Financial Report (ACFR) presented to the City Council on January 27. And while the staff report and the Finance Director's verbal presentation did acknowledge that the memo was missing, the fact remains: the Council was asked to receive an incomplete audit, and the Internal Controls Memo - the document that explains the six-million-dollar correction — was not provided.

That is a governance failure, not a timing issue.

Further, the ACFR was presented as informational only, with no action requested and no Internal Controls Memo included. An audit presented as "information only" is not an audit. It is a briefing — and it leaves the City without a formal acceptance, without accountability, and without a complete administrative record.

The memo you are reviewing today explains the same failures that produced the six-million-dollar correction disclosed on January 13:
eight months of unreconciled bank statements, unposted prior-year audit adjustments, missed grant tracking, and segregation-of-duties problems. These are foundational internal controls. When they fail, the financial statements fail — and they did.

Other cities handle this correctly. At the Livermore City Council meeting on January 26, 2026, the Internal Controls Report was included directly in the ACFR packet as Exhibit F — provided to the governing body responsible for oversight, exactly as Government Auditing Standards require. San Ramon did the opposite: the Council was given an incomplete audit, and the full deliverables are only now being presented to a committee.

This Committee is now the first governing body to receive the complete audit. That is not acceptable. The Internal Controls Memo must be formally presented to, discussed by, and signed off by the full City Council — not received as "information only," and not weeks after the ACR was already presented.

Accountability requires that the Council confront these findings directly. Anything less leaves the City without a complete audit record and without meaningful oversight.

Thank you.

M Gmail Brian Swanson <[email protected]>
Public Comment: Agenda Item 5.3 - FY25 Memorandum on Internal Control - Finance Committee Meeting Agenda - February 18, 2026
1 message
Brian Swanson Tue, Feb 17, 2026 at 2:24 PM
To: Clerk City <[email protected]>, Council City <[email protected]> Finance Committee Members:

This public comment pertains to Agenda Item 5.3 - FY25 Memorandum on Internal Control.

My remarks address three major areas of concern.

Part 1 explains how the Internal Controls Memorandum presented today directly relates to the January 13, 2026 balance-sheet corrections totaling $6,004,488.87, including negative fund balances, unsupported transfers, unbudgeted expenditures, and multi-year liabilities that required General Fund backfilling. These issues raise not only technical accounting questions but also ethical concerns under the Government Finance Officers Association (GFOA) Code of Ethics and Code of Professional Conduct, as well as the professional standards governing certified public accountants (AICPA).

International City/County Management Association (ICMA) members, and American Institute of Certified Planners (AICP)-certified planners.

Part 2 documents the Brown Act notice failures and administrative-record deficiencies that occurred during the January 27 Annual Comprehensive Financial Report (ACFR) presentation, including the City's failure to disclose in the agenda description that the Internal Controls Memorandum was missing, even though it was acknowledged only in the staff report and verbally during the meeting. It also addresses today's agenda, which fails to inform the public that written public comment is accepted.

Part 3 addresses governance, leadership, and process failures, including the City's repeated characterization of the audit as a "partnership" with the auditors— framing inconsistent with Government Auditing Standards, which require auditors to independently report deficiencies to those charged with governance. This section also addresses the decision to present an incomplete audit to the City Council, withhold the internal control findings, and shift the accountability moment to this Committee weeks later.

This section also incorporates concerns about the City's management of Measure N, the temporary tax that is the only thing preventing the structural deficit from collapsing the General Fund, and the broader implications for upcoming Contra Costa County-wide and region-wide transportation tax measures.

Together, these issues demonstrate that the City's audit process for FY25 was procedurally defective, substantively incomplete, and structurally designed to avoid accountability for both Council and staff.

Access, Transparency, and Administrative Record Requirements As with all of my public comments, I must reiterate the City's obligations regarding public access to the administrative record:

Public comments must be permanently visible and easily accessible on the City's website, in both HTML and searchable PDF formats.

All public materials-including staff reports, attachments, and all submitted public comments-must be posted together and directly adjacent to the specific agenda item, reachable in one or two clicks.

Link integrity must be actively maintained so that the public can locate and verify the administrative record without barriers.

Today's agenda introduces an additional transparency problem:

The Finance Committee agenda does not inform the public that written public comment is accepted, even though written comment is a core component of meaningful participation and a standard practice for all other City bodies. The agenda only references verbal public comment. This omission is neither transparent nor public-serving and raises its own Brown Act compliance concerns.

Failure to maintain accessible, consolidated, and complete public records undermines procedural fairness and materially impedes meaningful public participation.

PART 1- January 13 Corrections and the Internal Control Failures Documented Today On January 13, the City disclosed $6,004,488.87 in prior-period corrections. As I documented in my January 27 written comment, these were not routine adjustments. They revealed:

Negative fund balances,
•Unsupported transfers,
• Unbudgeted expenditures,
• Multi-year liabilities requiring General Fund backfilling, and A $4.52 million "due to General Fund" balance, including $2.2 million carried forward from the prior year.

The Internal Controls Memorandum presented today confirms the underlying causes. It identifies:

Three Significant Deficiencies:

Untimely bank reconciliations (no full reconciliations since October 2024), Failure to post prior-year audit adjustments,
Failure to track grants, resulting in a missed Single Audit deadline.

Two Other Matters:

Untimely journal entry review,
Cash-handling segregation-of-duties issues.

These are the exact types of failures that produce multi-million-dollar misstatements like those disclosed on January 13.

Measure N Implications
Measure N revenues flow directly into the General Fund - the same General Fund that absorbed the entire $6 million correction.

If the City cannot:
reconcile bank statements for eight months,
post prior-year audit adjustments,
• track grant funding, or
maintain segregation of duties in cash handling,
then the public has no assurance that Measure N revenues are being managed, safeguarded, or reported with the rigor voters were promised.

This is not a hypothetical concern.

It is a direct governance risk.

PART 2 - Brown Act Notice Failures and Administrative-Record Deficiencies The Brown Act does not require exhaustive detail in an agenda description.

But it does require that the description accurately convey the nature of the business to be transacted.

On January 27, the ACR item was agendized as a routine acceptance item, with no disclosure in the agenda description that:

The Internal Controls Memorandum was missing,
The audit deliverables were incomplete,
• The ACFR was being presented informational only,
• The Council would not be asked to take action,
• The City had not reconciled bank statements since October 2024, or The City had missed the federal Single Audit deadline.

While the staff report stated that the item was informational only and the verbal presentation reiterated this, the agenda description did not. Under the Brown Act, it is the agenda description — not the staff report and not verbal remarks - that must provide the public with sufficient notice of the nature of the business being transacted. Staff reports cannot cure a deficient agenda description. Verbal disclosures cannot cure a deficient agenda description. The omission in the agenda description is therefore the operative Brown Act issue.

Finance Committee Brown Act Obligations
It is also important to note that the Finance Committee is a standing committee of the City Council and, therefore, a full Brown Act legislative body under Government Code § 54952(b). As such, its agendas must meet the same notice and transparency requirements as City Council agendas, including clear agenda descriptions and disclosure of written public comment opportunities. The omission of written public comment instructions on today's agenda is therefore a genuine Brown Act compliance concern, not a procedural preference.

PART 3 - Leadership, Governance, and Process Failure
This is an extraordinarily troubling way for a new Finance Director and a newly created standalone Finance Department to begin their tenure. The first major act of this new department was to present an incomplete ACR to the City Council, missing required audit deliverables and stripped of the Internal Controls Memorandum that explains the very failures that led to the January 13 corrections. The second act was to place that incomplete audit on the agenda as informational only, ensuring that the Council took no action and bore no responsibility. And the third act is what we are witnessing today: the Internal Controls Memorandum being presented weeks later, not to the Council, but to a committee, after the public, the Council, and the administrative record were all deprived of the information required for meaningful oversight. For a new department, whose credibility depends on transparency and accuracy, this is a profoundly damaging start.

Expanded Leadership-Failure Precedent
For the new Finance Director's first major audit decision to be not to include the Internal Controls Memorandum in the ACFR sets an alarming precedent. The auditor was under contract, the deliverable existed, and Government Auditing Standards do not permit management to selectively withhold required audit communications based on internal staffing issues or timing concerns. The City's personnel challenges — real or perceived — do not override the auditor's obligation to report deficiencies to those charged with governance, nor do they justify presenting an incomplete audit to the City Council. When the first major act of a new department is to withhold the document that discloses control failures, it signals a governance posture that prioritizes narrative management over statutory transparency. That is a dangerous precedent for any city, and especially for one managing a structural deficit and relying on Measure N revenues to maintain solvency.

Comparative Governance Failure - Livermore Example
The City's decision to withhold the Internal Controls Memorandum from the Council is even more troubling when compared to standard practice in peer jurisdictions. For example, at the Livermore City Council Meeting of January 13, 2026, the Council considered Agenda Item 6.5 - Acceptance of the FY 2024-25 Annual Comprehensive Financial Report, and the Independent Auditor's Report on Internal Control over Financial Reporting was included directly in the agenda packet as Exhibit F. (See https://granicus_production_attachments.s3.amazonaws.com/livermore/459613cf1d10e6c0553c3bc51edc6 Livermore does not delay the memo, does not route it through a committee, and does not characterize its disclosure as "not possible this year." It is presented alongside the ACR as an integral audit deliverable. San Ramon's deviation from this norm was not driven by necessity; it was a discretionary choice that resulted in the Council receiving an incomplete audit and the public receiving an incomplete record. This comparative evidence underscores how far outside accepted practice San Ramon's process has drifted.

Regional Tax-Measure Risk
These process failures do not occur in a vacuum. Contra Costa County is preparing a county-wide revenue measure, and the Bay Area region is preparing a separate region-wide transportation funding measure for the upcoming ballot. Voters are already skeptical of large-scale tax proposals, and nothing erodes public confidence faster than a city demonstrating that it cannot manage its own financial controls, reconcile its own accounts, or present a complete audit to its governing body.

When San Ramon withholds required audit deliverables, delays internal control disclosures, and characterizes the audit as a "partnership" rather than an oversight function, it sends a message to voters that accountability is optional. That is precisely the kind of behavior that jeopardizes both county-wide and region-wide revenue measures, because voters do not distinguish between jurisdictions - they see a pattern of local government failing to meet basic standards of transparency.

San Ramon's actions here risk undermining broader regional efforts that depend on public trust.

The Partnership Framing Problem
Compounding this is the repeated framing - in both the staff report and the verbal presentation - that the audit process is a "partnership" with the auditors. Government Auditing Standards do not describe the auditor-client relationship as a partnership. They require auditors to independently identify deficiencies and report them to those charged with governance. When staff characterizes the audit as a partnership, it reframes a statutory oversight function as a collaborative exercise, blurring the lines between auditor independence and management narrative. That framing was inappropriate and contributed to the decision to withhold the Internal Controls Memorandum from the Council on January The Finance Committee Is Now the First Governing Body to Receive the Full Audit The Internal Controls Memorandum is addressed to:
"those charged with governance."
That is not staff. That is not optional. That is a professional requirement.

Because the Council never received this memo, this Committee is now the first governing body to receive the full audit deliverables. That makes today's meeting the only accountability moment in the FY25 audit cycle.

Required Actions
If this Committee accepts the memo today, it must also:

Transmit a written summary of the findings to the full Council, including the Significant Deficiencies and Other Matters.

2. Document the connection between these findings and the January 13 corrections.

3. Acknowledge that the ACFR was presented without the required audit deliverables.

4. Correct the Brown Act and administrative-record deficiencies, including the failure to allow written public comment.

5. Ensure that future ACR presentations include the Internal Controls Memorandum and are agendized as action items.

6. Address the Measure N governance risk, including how internal control failures affect the City's ability to safeguard and report Measure N revenues.

7. Acknowledge the regional implications, including the risk that San Ramon's lack of accountability undermines public trust in upcoming county-wide and region-wide tax measures.

The public deserves a complete audit process.

The Council deserves the information it was denied on January 27.

The Finance Committee must not accept this memo quietly without addressing the procedural failures that brought it here.

Thank you,
Brian Swanson, AICP
San Ramon Voter, Taxpayer, and Resident
On Fri, Feb 13, 2026 at 12:56 PM City of San Ramon <[email protected]> wrote:

The City of
San Ramon San Ramon
The Finance Committee Meeting will begin at 4:00 p.m. on Wednesday, February 18.

The meeting agenda is now available for viewing here.
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Public Comment: Request to Pull Agenda Item 5.4 - FY25 Memorandum on Internal Control from the Consent Calendar and Formal Comment - City Council Meeting - March 24, 2026
1 message
Brian Swanson Mon, Mar 23, 2026 at 6:34 PM
To: Clerk City <[email protected], Council City <[email protected] Cc: planningcommission < [email protected]>. Planning Services <[email protected]> City Council:
1 am requesting the removal of Agenda Item 5.4 - FY25 Memorandum on Internal Control from the Consent Calendar because including this audit deliverable on the Consent Calendar demonstrates a serious governance failure. The reasons for requesting removal are the same reasons that form the substance of this comment: the Internal Control Memo contains significant deficiencies, is directly tied to more than six million dollars in prior-period corrections, and represents the City's most consequential audit communication of the year.

It is not routine, it is not ministerial, and it is not appropriate for silent acceptance.

Placing this item on Consent - without discussion, without presentation, and without distinct City Council approval - signals a profound lack of attention to fiscal responsibility and the seriousness of the City's sagging fiscal health.

Enhance Engagement and Communication), the Mayor's campaign platform, and the Mayor's recent State of the City address, which emphasized "fiscal responsibility" and "strong financial management." None of those statements are credible when the City's own audit findings are being buried in Consent.

Formal Incorporation by Reference (All Documents)
Pursuant to the City's obligations under the Brown Act and the requirements for maintaining a complete administrative record, I hereby formally incorporate by reference in full the following previously submitted public comments, all of which will be attached to this comment and incorporated as though fully set forth herein:

My written public comment was submitted January 27, 2026, for the City Council Meeting Agenda Item 9.2 - Audited Annual Comprehensive Financial Report (ACFR) for FY25.

My written public comment submitted February 18, 2026 for the Finance Committee Meeting Agenda Item 5.3 - FY25 Memorandum on Internal Control.

My verbal public comment script delivered February 18, 2026 before the Finance Committee on the FY25 Memorandum on Internal Control.

These documents collectively establish the factual, procedural, ethical, and governance deficiencies that continue into tonight's agenda item.

Access, Transparency, and Administrative Record Requirements As with all of my public comments, I must reiterate the City's obligations regarding public access to the administrative record:

Public comments must be permanently visible and easily accessible on the City's website, in both HTML and searchable PDF formats.

All public materials — including staff reports, attachments, and all submitted public comments — must be posted together and directly adjacent to the specific agenda item, reachable in one or two clicks.

Link integrity must be actively maintained so the public can locate and verify the administrative record without barriers.

Tonight's agenda introduces an additional transparency problem:

The Internal Control Memo — a required audit deliverable — is placed on the Consent Calendar, which prevents neaningtul public engagement and shields the City Council from having to discuss the findings in a public forum.

This is inconsistent with the City Manager's statements in the March 2025 hiring announcement, the City Council Norms, the 2026 Goals & Objectives, the Mayor's campaign platform, and the Mayor's State of the City address, all of which emphasized transparency, accountability, and strong financial management.

The handling of this audit deliverable does not reflect those commitments.

Failure to maintain accessible, consolidated, and complete public records undermines procedural fairness and materially impedes meaningful public participation.

The Internal Controls Memo Was Dated January 12, 2026 and Could Have Been Provided to Council on January 27 The Internal Control Memorandum attached to tonight's agenda is dated January 12, 2026. If that date is accurate, then the City had two full weeks to include this memo with the ACFR presented to the City Council on January 27.

Yet the staff report tonight asserts:
"Under normal circumstances the Memorandum on Internal Control would be shared at the same time as the audited Annual Comprehensive Financial Report (ACFR). Since this was not possible this year..." But the memo itself contradicts that claim. It was issued on January 12, well before the January 27 meeting. The Council was not given the complete audit because the memo was withheld, not because it was unavailable.

This omission deprived the City Council of the information needed to exercise oversight — and it deprived the public of a complete administrative record.

This is one of the reasons Agenda Item 5.4 must be pulled from the Consent Calendar.

The Council Failed to Exercise Oversight on January 27
The ACFR was presented to the City Council on January 27 as informational only. The staff report and the Finance Director's verbal remarks acknowledged that the Internal Control Memo was missing, but the Council:
• did not ask for it,
• did not question its absence,
• and did not insist on receiving the complete audit deliverables.

An audit presented as "information only" is not an audit. It is a briefing — and it leaves the City without:
• a formal acceptance,
• a complete audit record,
• and any meaningful accountability
Placing the memo on Consent tonight repeats the same oversight failure.

This is another reason Agenda Item 5.4 must be pulled.

The Finance Committee Received the Memo First, Not the Council Tonight's staff report states:
"This report was first reviewed by the Finance Committee on February 18, 2026 and was recommended to the City Council for acceptance."
This means the Finance Committee - not the City Council - was the first governing body to receive the complete audit.

That is backwards.

Government Auditing Standards require that internal control findings be reported to those charged with governance.

In San Ramon, that is the City Council, not a sub-committee.

The City Council is only now receiving the memo - and only as a Consent item.

This is yet another reason Agenda Item 5.4 must be pulled The Findings Are Serious and Directly Connected to the $6 Million Correction The Internal Controls Memo identifies:
• Three Significant Deficiencies; and
• Two Other Matters.

These failures produced the $6,004,488.87 correction disclosed on January 13 — including negative fund balances, unsupported transfers, unbudgeted expenditures, and multi-year liabilities requiring General Fund backfilling.

These are not minor issues.

They are structural failures that directly affect the City's fiscal stability and the public's trust.

No responsible city buries findings of this magnitude on Consent.

The "Partnership with the Auditors" Framing Is Inappropriate Tonight's staff report repeats the same problematic language used in February:
"The audit process is... about developing a partnership with the auditors..." Government Auditing Standards do not describe the auditor-client relationship as a partnership.

Auditors are independent. Their job is to report deficiencies to the governing body — not to collaborate with management on messaging.

This framing minimizes the seriousness of the findings and undermines the independence of the audit process.

This is another reason Agenda Item 5.4 must be pulled
The City Must Acknowledge Its Actual Fiscal Condition
This is also where the City Council must acknowledge the City's existing fiscal condition honestly and transparently.

The City's own Financial Outlook page states that:
• rising costs were outpacing year-over-year revenue projections, • the June 25, 2024 budget required navigating a $17.6 million shortfall, • the budget included $8.1 million in cuts across City departments, • and unmet staffing, operational needs, and many capital improvement projects remained unfunded.

The fiscal strain became so acute that the City placed Measure N on the November 5, 2024 ballot.

The City's Measure N page states that the measure asked voters whether San Ramon should levy a one-cent sales tax, estimated to provide $16 million annually for 10 years, to maintain City programs, services, and facilities.

The City later reported that Measure N generated $3.45 million in revenue for the April 1-June 30, 2025 quarter, and that the FY 2025/26 budget included $14.8 million in estimated Measure N revenue.

A city in this fiscal condition cannot afford to treat internal control failures as routine or bury them on Consent.

Required Actions
If the Council accepts this memo tonight, it must also:
• Acknowledge that the ACR was presented without the required audit deliverables on January 27.

Formally present and discuss the Internal Controls Memo at a future meeting - not bury it on Consent - providing City residents with a transparent look into the City's financial audit posture and expectations.

This is especially necessary given the commitments made in the City Manager's hiring announcement, the City Council Norms, the 2026 Goals & Objectives, the Mayor's campaign platform, and the Mayor's State of the City remarks.

All the City's rhetoric detailed above is an explicitly reckless and deliberate mischaracterization if there is no accountability from the City Council regarding the ACFR and the Internal Control Memo. • Document the connection between these findings and the $6 million correction. • Direct staff to produce a corrective-action plan with timelines and accountability assignments. • Commit to including all audit deliverables together in future ACR presentations. • Reaffirm the Council's role as the governing body responsible for audit oversight, consistent with:

Norm #1: Do What Is Best for the Community
Norm #5: Be Prepared
Norm #6: Conduct Effective Meetings
Goal #2: Maintain a Secure Financial Base
Goal #5: Enhance Engagement and Communication
The public deserves a complete audit process.

The City Council must not accept this memo quietly.

Doing so would confirm - not correct the City's growing reputation for weak fiscal governance.

Respectfully submitted,
Brian C. Swanson, AICP
San Ramon Voter, Taxpayer, and Resident
On Fri, Mar 20, 2026 at 3:31 PM City of San Ramon <[email protected]> wrote:

The City of
San Ramon San Ramon

CALIFORNIA
The City Council meeting will begin at 7:00 p.m. on Tuesday, March 24, 2026.

The meeting agenda is now available at, https://sanramonca.portal.civicclerk.com/event/24/files/agenda/1204 HOW TO VIEW OR PARTICIPATE IN THE MEETING:

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City of San Ramon | 7000 Bollinger Canyon Road, San Ramon, CA 94583 | (925) 973-2500 | www.sanramon.ca.gov 3 attachments

01.27.2026 - BSwanson - WrittenPublicComment_ Agenda Item 9.2 - Audited ACFR for the City of San 2 Ramon for the FY Ended June 30, 2025 - City Council Meeting.pdf

02.18.2026 - BSwanson_PublicComment_Agendaltem5.3_FY25 Memo on Internal 2] Control_FinanceCommMtg.pdf
299K

02.18.2026 - BSwanson_PublicCommentVerbalScript_FinanceCommittee_Item5.

Z 3FY25InternalControlsMemo.pdf
M Gmail Brian Swanson < [email protected]>
Fwd: Public Comment: Agenda Item 8.1 - Resolution No. 2026-066 - Adopting the Fiscal Year 2026/27 Operating and Capital Budget, Establishing an Appropriations Limit, and Authorizing Carryover Project Appropriations - City Council Meeting - May 26, 2026
1 message
Brian Swanson Tue, May 26, 2026 at 12:29 PM
To: Clerk City < [email protected]>, Council City <[email protected]>, Finance <[email protected]>
Cc: planningcommission <[email protected]>, Planning Services <[email protected]> City Council:

I submit this written public comment regarding Agenda Item 8.1, Resolution No. 2026-066, which would adopt the City of San Ramon's Fiscal Year 2026/27 Operating and Capital Budget, establish the City's appropriations limit, and authorize carryover project appropriations.

Unless otherwise noted, references in this comment to the "Agenda Item staff report," the "proposed budget," the "budget document," or the "Fiscal Year 2026/27 budget" refer to the materials presented under Agenda Item 8.1 for the May 26, 2026 City Council meeting, including Resolution No. 2026-066, the Agenda Item 8.1 staff report, the Fiscal Year 2026/27 Proposed Operating Budget, the Fiscal Year 2026/27 Capital Budget, and the Gann Appropriations Limit calculation.

This comment is also submitted together with, and formally incorporates by reference, my prior written public comments regarding the City's Fiscal Year 2024/25 Annual Comprehensive Financial Report (ACFR) and Fiscal Year 2025 Memorandum on Internal Control. Those attached comments are incorporated as though fully set forth herein because they directly bear on the same issues now before the Council: the reliability of the City's budget numbers, the adequacy of internal controls, the credibility of the City's Financial Resilience Framework, the management of Measure N revenues, the completeness of the administrative record, and the Council's obligation to exercise fiscal oversight consistent with its own Fiscal Year 2026/27 Goals and Objectives.

The incorporated attachments are: (1) my January 27, 2026 written public comment regarding Agenda Item 9.2 Acceptance of the Fiscal Year 2024/25 Annual Comprehensive Financial Report; (2) my February 18, 2026 written public comment regarding Finance Committee Agenda Item 5.3, Fiscal Year 2025 Memorandum on Internal Control; (3) my February 18, 2026 verbal public comment script regarding the same Finance Committee item; and (4) my March 24, 2026 written public comment requesting that City Council Agenda Item 5.4, Fiscal Year 2025 Memorandum on Internal Control, be pulled from the Consent Calendar and formally discussed.

Agenda Item 8.1 is not a routine budget-adoption item. It is the Council's formal decision whether to approve a $150,718,429 operating and capital budget. At the same time, the City continues to rely on Measure N receipts to cover an ongoing structural operating deficit. At the same time, key pieces of the City's Financial Resilience Framework remain incomplete. At the same time, the City has acknowledged an extended absence of an Accounting Manager. In contrast, unresolved internal control findings remain part of the City's recent audit history, and while significant questions remain regarding internal finance capacity, budget verification, economic development, revenue diversification, cost controls, public access, and administrative record transparency.

The Agenda Item staff report directly acknowledges the core fiscal problem. It states that the Fiscal Year 2026/27 budget "continues to show a structural deficit that is alleviated by the use of Measure N receipts" and that efforts on the Financial Resiliency Framework must continue "in earnest" if the City is to achieve a balanced operating budget by Fiscal Year 2035. The same staff report identifies a projected Fiscal Year 2025/26 operational structural deficit of $12.1 million, covered with Measure N revenues, and a Fiscal Year 2026/27 structural deficit of $13.7 million, to which $14.9 million in expected Measure N revenues will be applied
That is the central issue. The City is not adopting a budget based on demonstrated financial resilience. The City is adopting a budget that remains dependent on a temporary voter-approved transactions and use tax while simultaneously presenting a public narrative of "financial resilience," "fiscal accountability," "living within the City's means," "cost-effective services," "revenue generation," and "responsive governance." Those phrases are not self-executing. Measure N may buy time. It does not, by itself, demonstrate that the City has corrected the structural problem.

Transparency, Access, and the Administrative Record
Any materials related to Agenda Item 8.1, whether provided before, during, or after the May 26, 2026 meeting, must be permanently posted on the City's website in HTML and searchable PDF formats directly adjacent to Agenda Item 8.1.

This includes the staff report, Resolution No. 2026-066, the proposed operating budget, the capital budget, the Gann appropriations limit calculation, presentations, workpapers, spreadsheets, fund-balance calculations, Measure N assumptions, Financial Resilience Framework materials, forecast models, consultant materials, internal-control materials, communications with consultants, and all written public comments.

Public comments must not be fragmented across multiple pages, buried behind excessive navigation, or placed under vague platform labels that do not tell the public what the document is. In particular, the CivicClerk platform should not place public comments under a generic or nondescript "Supplemental Materials" tab or subheading without a clear "Public Comment" label. "Supplemental Materials" is not an adequate public-facing label for public testimony. It leads residents to infer that written comments may be hidden in a generic materials bucket, diminishing transparency, discouraging review, and weakening the public's ability to understand the full record before the Council acts.

The City's own agenda instructions state that written comments received up to two hours before the meeting will be emailed to the City Council, placed in the red binder at the meeting, and posted online at https://www.sanramon.ca.gov/ public_comment. The City should implement that process in a way that is clear to the public, not merely convenient for internal document management. Public comments should be clearly labeled as "Public Comment - Agenda Item 8.1," posted directly adjacent to the item, and maintained in searchable, durable, and easily accessible form.

The City must also maintain link integrity and ensure that the budget administrative record remains accessible in perpetuity. Any materials distributed at or shortly before the meeting must be posted online immediately and made available to the public at the same time they are provided to the City Council. The administrative record for this item should include all documents, emails, spreadsheets, working papers, revenue assumptions, fund-balance calculations, financial models, consultant inputs, presentations, and materials considered by the City Council, City Manager, Finance Director, Budget Manager, Budget Program Manager, or staff.

The same requirement applies to the incorporated attachments. My prior ACR and Internal Controls comments should be posted with this comment, not separated from it, not buried in a generic materials folder, and not disconnected from Agenda Item 8.1. Those comments are part of the budget record because the Fiscal Year 2026/27 budget relies on the same General Fund, the same Measure N revenue stream, the same accounting systems, the same reserve narrative, the same internal control environment, and the same Financial Resilience Framework that the Annual Comprehensive Financial Report and Internal Controls Memorandum identified.

Communication with Residents and Business Community" It is also inconsistent with Goal 5's specific objectives to refresh the City website to improve user experience, conduct community engagement, and complete a comprehensive assessment of the San Ramon economy within the broader Tri-Valley and Bay Area context.

A budget process that hides public comments under vague "Supplemental Materials" labels, separates comments from the item they address, or fails to preserve workpapers and assumptions in an accessible form does not implement Goal The Budget Must Be Judged Against the Council's Own Goals and Objectives, Not Merely Against Budget This comment is not based only on disagreement with isolated statements by the Mayor, the City Manager, or individual staff members. The more important issue is that the proposed budget must be tested against the City Council's own adopted Fiscal Year 2026/27 Goals and Objectives.

The proposed budget states that Council goals and objectives "guide" the City's work and resource allocation, provide direction to the City Manager and staff, and identify where and how public funds will be expended. That means the Council's goals are not aspirational branding. They are the policy framework for this budget.

The proposed budget does not yet demonstrate consistency with that framework.

Goal 2 is to "Maintain a Secure Financial Base." Its objectives include evaluating the 36 percent reserve policy and alternatives; developing and implementing a Parks and Community Services Cost Recovery/Sustainable Subsidy Policy; and enhancing financial forecasting while exploring revenue growth options alongside broader cost-saving strategies.

Those may be the right objectives. But the budget before the Council still relies on Measure N to cover an ongoing structural deficit, still applies approximately $14.9 million of Measure N to a $13.7 million operating gap, still identifies the Financial Forecast Model and five-year projection as future deliverables, and still leaves major internal-control work to be completed after adoption. This isn't a complete implementation of Goal 2. It is evidence that Goal 2 remains substantially unresolved.

Goal 3 is to "Provide Cost-Effective and Responsive Services to Sustain Quality of Life." One of its objectives is to standardize how departments analyze and report service data, ensuring consistent metrics for evaluating program performance and resource needs. That objective directly relates to this budget. If the City is relying on Measure N to maintain existing service levels, the public should be shown clear service-level metrics, cost drivers, department-by- department performance measures, and alternatives for maintaining quality of life at lower cost. The City should not simply describe current service levels as necessary and then treat Measure N as the default solution. A cost-effective services goal requires measurable service analysis, not merely expenditure authorization.

Goal 4 is to "Build and Maintain Quality Facilities and Infrastructure." That goal is important, but it cannot be treated as a blank check. The City maintains 65 parks, extensive trails, aquatics facilities, community centers, landscape areas, streets, drainage infrastructure, public buildings, and other facilities. A budget claiming financial resilience should disclose how maintenance levels, deferred maintenance, capital needs, tiered maintenance options, and long-term infrastructure obligations will be managed. Goal 4 must be reconciled with Goal 2's requirement to maintain a secure financial base and Goal 3's requirement to provide cost-effective services.

Goal 5 is to "Enhance Engagement and Communication with Residents and Business Community." This goal directly supports the transparency, public-comment labeling, administrative-record, and economic-development concerns raised in this comment. If public comments on Agenda Item 8.1 are placed behind a vague "Supplemental Materials" tab rather than clearly labeled as "Public Comment," that is inconsistent with Goal 5. If the City discusses revenue generation and economic development without publishing the assumptions, workpapers, consultant materials, public comments, and alternatives that support that discussion, it is inconsistent with Goal 5. If the City dissolved its Economic Development Advisory Committee and has not yet shown the public a clear replacement process for business-community engagement, that is also inconsistent with Goal 5.

Goal 6 is to "Balance Land Use Planning for Housing, Retail, Jobs, and Open Space." Its first objective is to work with stakeholders on new infill development opportunities within the city core and existing commercial centers. That objective is directly relevant to the City Manager's narrow economic-development rhetoric. A city that says it wants to balance housing, retail, jobs, and open space cannot treat economic development as though only a Costco-scale use matters.

Nor can it dismiss ordinary retail, restaurant, service, hotel, entertainment, office-reuse, medical-office, family-dining, and commercial-center opportunities as if they are beneath San Ramon. Goal 6 requires a serious, all-of-the-above approach to San Ramon's existing commercial context, including Bishop Ranch, City Center, Crow Canyon Road, San Ramon Valley Boulevard, border-area retail leakage, existing shopping centers, office reuse, and the City's current retail anchors.

The Council should therefore require staff to reconcile Resolution No. 2026-066 with the Council's own goals before adoption. The budget should not be approved merely because the numbers balance after applying Measure N. It should be approved only if the Council can explain how the budget actually advances Goal 2, Goal 3, Goal 4, Goal 5, and Goal 6 in measurable, accountable, and transparent terms.

The Budget Is Being Presented as "Financial Resilience" While the City Remains Dependent on Measure N The City's proposed budget should be understood in the context of the Financial Resilience Framework, not apart from it.

The City's Fiscal Year 2026/27 budget process materials state that the structural deficit is driven by expenditures outpacing revenues, with revenues increasing by approximately 4 percent per year and expenditures increasing at a much higher rate. Those materials also describe budget guidelines, including "No new programs or positions without tradeoffs," "No spending money the City doesn't have," and "No unsustainable commitments." (City of San Ramon, Fiscal Year 2026/27 Budget Process webpage, https://www.sanramon.ca.gov/cms/One.aspx?pageld=21250320& portalld=10826130.)
Those guidelines may be sound as written. The problem is that the budget now before the Council does not demonstrate that the City is actually meeting them. The Agenda Item staff report states that General Fund expenditures, excluding transfers out, are projected at $76.8 million, or 6.6 percent higher than the Fiscal Year 2025/26 projected budget. The City's fiscal-sustainability narrative has identified a need to dramatically slow expenditure growth if the City is to reach structural balance by the time Measure N expires. A 6.6 percent increase in expenditures does not demonstrate that the City is on that path.

That is why describing this budget as "financial resilience" is misleading. The budget is balanced on paper because Measure N is being applied to the structural deficit. But Measure N is a temporary 1 percent transactions and use tax scheduled to expire in 2035. The proposed budget identifies Measure N as the City's second-largest projected General Fund revenue source, at approximately $14.9 million.

The City is not "living within its means" when it relies on a temporary tax to fund ongoing service levels while the underlying expenditure curve remains above the revenue curve. The City is not demonstrating fiscal accountability when the operating gap grows from $12.1 million to $13.7 million, and the solution remains to apply Measure N. And the City is not proving financial resilience when its own framework shows that critical implementation tools remain unfinished.

The Agenda Item staff report states that the Financial Resilience Framework includes completed new and expanded financial norms and budget guidelines. Still, it also states that the forecasting model remains "In Progress." That policy and operational discussions remain to be conducted regarding infrastructure maintenance, reserves, pension funding, other post-employment benefits, department programming, and revenue generation. The Finance Department's major action plan similarly states that staff will continue work on the Financial Resilience Framework through June 2027, implement the Fiscal Year 2025 Memorandum on Internal Controls recommendations by October 2026, develop the Financial Forecast Model by October 2026, and develop a five-year financial projection as part of the long-term fiscal sustainability framework by October 2026.

That sequencing is backward. The City is asking the Council to adopt the budget now. At the same time, the internal control recommendations, financial forecast model, five-year projection, and major fiscal policy discussions remain as future work items. The Council should not approve the budget as if these questions have been resolved, even though the budget itself says they remain pending.

The Prior Annual Comprehensive Financial Report and Internal Controls Comments Are Directly Relevant to This Budget
The incorporated ACR and Internal Controls comments are not background noise. They are directly relevant to the Council's ability to approve this budget as presented responsibly.

In my January 27, 2026 written public comment on Agenda Item 9.2, I explained that the City had recently disclosed $6,004,488.87 in corrections required to close Fiscal Year 2024/25. Those corrections were not routine adjustments.

They included negative fund balances in multiple internal service funds, unbudgeted expenditures, unsupported transfers, a $4.52 million "due to General Fund" liability, a $2.2 million balance carried forward from the prior year, a delayed year- end close, incomplete standard procedures, loss of institutional knowledge, and reliance on an outside certified public Plund intastic ture Fund, all Pension Obligation Bond Fund, as wel as the reversa of an unsupported transfer.

That history matters because the Fiscal Year 2026/27 budget again asks the public to rely on General Fund projections, reserve calculations, internal-service-fund assumptions, transfers, projected actuals, Measure N revenues, and claims of fiscal resilience. The City cannot treat the earlier $6 million correction as an isolated historical matter while relying on the same financial architecture to support the current budget.

In that same ACFR comment, I also explained that the ACR's reserve narrative was misleading because it emphasized the General Fund's fund balance and reserve ratio without adequately contextualizing the structural deficit, the January 13 corrections, pension volatility, other post-employment benefit obligations, capital maintenance backlogs, internal-service- fund pressures, long-term debt service, and the speed with which reserves could be depleted under current trends. That concern carries directly into Agenda Item 8.1. The current budget again emphasizes fund balance and reserve-target compliance while relying on Measure N to cover an operating structural deficit. Reserve-target compliance is not the same thing as structural balance. A reserve ratio can be technically accurate and still substantively misleading if it is presented without the surrounding fiscal risk.

The February 18, 2026 Finance Committee written comment and verbal script further explained that the Fiscal Year 2025 Memorandum on Internal Control was dated January 12, 2026. It therefore appeared to have been available before the January 27 AFR presentation. Yet the Council was asked to receive the ACR without the Internal Controls Memorandum - the document that explained the very failures that produced the $6 million correction. As stated in the attached verbal comment, an audit presented as "information only" without the Internal Controls Memorandum is not a complete audit; it is a briefing that leaves the City without formal acceptance, accountability, or a complete administrative record.

The Internal Controls Memorandum identified three Significant Deficiencies and two Other Matters, including untimely bank reconciliations, failure to post prior-year audit adjustments, failure to track grants resulting in a missed Single Audit deadline, untimely journal-entry review, and cash-handling segregation-of-duties issues. Those are foundational controls.

When they fail, the financial statements fail. When they are still being implemented after budget adoption, the budget's Those internal control issues have direct implications for Measure N. Measure N revenues flow into the General Fund, which is the same General Fund that absorbed the $6,004,488.87 correction and the same General Fund now being used to cover the structural deficit. If the City had recent failures involving bank reconciliations, prior-year audit adjustments, grant tracking, journal-entry review, and cash handling, then the Council should not adopt a Measure N-dependent budget without publicly explaining what controls are now in place to safeguard, track, reconcile, report, and forecast Measure N revenues.

My March 24, 2026 City Council comment requested that the Fiscal Year 2025 Memorandum on Internal Control be pulled from the Consent Calendar because it was neither routine nor ministerial, and was not appropriate for silent acceptance.

That comment also emphasized that the Finance Committee, not the full City Council, received the complete audit deliverables first; that the Internal Controls Memorandum should have been presented and discussed by the full Council; and that the City should document the connection between the findings and the $6 million correction, produce a corrective-action plan with timelines and accountability assignments, and commit to including all audit deliverables together in future Annual Comprehensive Financial Report presentations.

Those requests remain relevant tonight. The Finance Department's major action plan for the Fiscal Year 2026/27 budget states that implementation of the Fiscal Year 2025 Memorandum on Internal Controls recommendations will occur by October 2026. That means the Council is being asked to adopt the budget before the City has completed the corrective actions necessary because of the audit and internal control failures identified earlier this year. This isn't just a finance department workflow issue. It is a governance issue under Goals 2, 3, and 5.

The City's rhetoric on fiscal responsibility, financial resilience, transparency, and strong financial management cannot be reconciled with a budget process that treats the unresolved implementation of internal controls as a future task while adopting a Measure N-dependent budget now. The prior ACR and Internal Controls comments are therefore incorporated not simply as exhibits, but as substantive evidence that the current budget rests on unresolved audit, control, fund-balance, reserve, and administrative-record issues.

The City Manager's Budget Message Is Missing From the Proposed Budget The proposed budget also contains a basic accountability problem that should not be overlooked. The "Guide to Budget Document" section states that the budget is both a spending plan for the City's available financial resources and the legal authority for City departments to spend resources for public purposes. It further states that the primary goal of the City Manager's Budget Message is to communicate the major issues facing the City, explain how those issues affect the City's financial plan, outline the City's fiscal status, summarize the actions being recommended to meet the legal requirements for a balanced budget, describe program impacts and modifications, and address the City's financial outlook.

Yet the proposed budget page for the City Manager's Budget Message states only that the "City Manager's message will be added to the Adopted Budget Document."
This isn't a minor formatting issue. The City Council is being asked to adopt the budget before the public has the benefit of the very message that the City's own budget guide says is supposed to explain the City's major issues, fiscal status, recommended actions, program impacts, and financial outlook. If the City Manager's Budget Message is described in the budget guide as the place where the City's major issues and financial outlook are communicated, it should be available before adoption rather than added afterward.

This omission is particularly troubling because the City Manager has repeatedly suggested that another tax measure may be necessary, perhaps after Measure N expires or even sooner. If that is the City Manager's management assumption, it belongs in the budget message before adoption, not in scattered oral remarks, post-adoption narratives, or later consultant presentations.

A budget message added only after adoption cannot provide meaningful public accountability before the Council acts.

That is inconsistent with Goal 5's engagement and communication objectives, inconsistent with Goal 2's secure-financial- base objective, and inconsistent with the budget document's own explanation of what a budget message is supposed to The Acknowledged Extended Absence of the Accounting Manager Undermines Confidence in the Budget Numbers
During the April 28, 2026 budget presentation, the City acknowledged an "existing extended absence" of the Accounting That disclosure is significant. The April 28 presentation was not a minor administrative update. The City's budget- process page describes that meeting as the expenditure and Capital Improvement Program presentation, including the fiscal sustainability guidelines and balancing strategy, the draft Fiscal Year 2026/27 General Fund expenditures and transfers out, projected reserve calculations, Dougherty Valley County Service Area and other fund budgets, outstanding debt service, and capital improvement changes.

The absence of an Accounting Manager is therefore directly relevant to the reliability of the numbers presented to the Council and the public. The proposed budget states that Finance staff reviewed, analyzed, and compiled preliminary budget amounts for Fiscal Year 2026/27 and made recommendations to the City Manager before the budget's presentation to the City Council. At the same time, the Finance Department staffing table identifies one Accountant, one Director, one Division Manager, two Administrative Analysts, three Office Specialists, and two Program Managers for Fiscal Year 2026/27.

This is not merely a personnel matter. The City's operations are tracked in no fewer than 70 funds, and the budget includes General Fund revenues, expenditures, transfers, reserve calculations, Measure N assumptions, special revenue funds, internal service funds, debt service, capital projects, and the Gann appropriations limit. The proposed budget's own Budgetary Principles state that budget information should be understandable to the public, that projected expenses should reflect operations and market conditions rather than simple escalators, that one-time and ongoing costs should be acknowledged, and that projected revenues should reflect expected revenues generated from existing businesses and Those principles require a strong accounting and management function. They require internal controls. They require clear responsibility for fund balances, reconciliations, transfers, projected actuals, accruals, grant accounting, capital carryovers, Measure N assumptions, and budget-to-actual analysis. They also require the City to disclose when a consulting firm is supplementing that function because of an extended absence.

It appears disingenuous and amateurish for the City to present precise fund-balance, reserve, revenue, expenditure, transfer, Measure N, debt-service, and Gann-limit calculations without clearly explaining who is performing the accounting-manager-level review, what consultant is filling the gap, what scope of work that consultant performed, whether any budget numbers were prepared or validated by the consultant, and whether the absence affected timing, accuracy, internal controls, or confidence in the budget.

The concern is heightened because the Finance Department's own major action plan lists several core financial-resilience items as future deliverables rather than completed safeguards. The budget states that the Finance Department will implement the Fiscal Year 2025 Memorandum on Internal Controls recommendations, develop the Financial Forecast Model, and develop a five-year financial projection by October 2026. The City is asking the Council to adopt the budget before completing the internal control and forecasting work that should support its credibility.

Rhetoric, Approval, and Accountability Must Be Reconnected to the Council's Goals This budget also illustrates a broader governance problem in San Ramon: rhetoric from elected officials and City leadership too often takes on a life of its own, disconnected from the actual action being approved. The public hears phrases such as "financial resilience," "fiscal accountability," "living within our means," "responsive governance," "revenue generation," "economic development," "strong financial management," and "community engagement." But those phrases do not establish accounting controls. They do not close the structural deficit. They do not replace an absent Accounting Manager. They do not complete the five-year forecast. They do not implement the Internal Controls Memorandum. They do not correct the ACR process. They do not create a functioning economic-development program. And they do not make a Measure N-dependent budget fiscally sustainable merely because the City describes it that way.

The City's own budget document recognizes that the budget is not just a communications document. It is both a spending plan and the legal authority for City departments to spend public resources. That means the Council should judge the budget by what it actually authorizes, not by the rhetoric used to sell it.

If the City approves a budget that continues to rely on Measure N to cover an ongoing structural deficit, then City leadership should not later characterize that approval as proof that San Ramon is "living within its means." If the City approves a budget while the Financial Resilience Framework remains incomplete, then City leadership should not present the framework as though it has already solved the problem. If the City approves a budget while internal-control recommendations, the forecast model, and the five-year projection remain future deliverables, then City leadership should not claim a level of fiscal discipline that has not yet been demonstrated. If the City approves a budget while the City Manager's Budget Message is missing and promised only for the adopted budget, then leadership should not claim that the public had the full fiscal explanation before adoption.

This is also why the administrative record matters. A public agency should not be able to approve one thing, describe it as something else, and then allow the rhetoric to become the public narrative without accountability.

The actual approval before the Council is Resolution No. 2026-066, which would adopt the Fiscal Year 2026/27 Operating and Capital Budget, establish the appropriations limit, and authorize carryover project appropriations. That is the action.

The question is whether that action is consistent with the City's stated goals, the Financial Resilience Framework, the Mayor's fiscal-accountability campaign message, the City Manager's public representations, and the City's claimed commitment to engagement and transparency.

On this record, the answer is no. The action being approved is not a completed financial-resilience plan. It is a Measure N-supported budget that continues to carry a structural operating deficit, relies on future policy discussions, relies on future operational discussions, relies on future internal-control implementation, relies on future forecast-model development, relies on future revenue-generation work, and rests against a recent audit history that included material corrections, incomplete audit presentation, missing audit deliverables, and unresolved internal-control implementation.

The City should not allow words like "resilience" and "accountability" to obscure that reality.

At a minimum, the Council should direct staff to include in the final adopted budget a plain-language reconciliation table showing each applicable Council goal, the corresponding budget action, the funding source, the measurable implementation step, the completion date, and the responsible department or official. The City should also identify which portions of the Financial Resilience Framework are complete, which remain pending, which are funded in this budget, which are merely conceptual, and which depend on future tax proposals. That is the only way to prevent rhetoric from replacing accountability.

The Mayor's Campaign Promises Reinforce the Same Accountability Problem, But the Obligation Belongs to the Full Council
Mayor Armstrong's public campaign materials identify "Fiscal Accountability" as one of his stated priorities, and public reporting on his re-election campaign describes a platform that includes fiscal responsibility, responsible budgeting, long- term planning, and the protection of taxpayer dollars. (Mark Armstrong for San Ramon Mayor campaign website, https://armstrong4sanramon.com/; Patch, "San Ramon Mayor Announces Re-Election Campaign," March 24, 2026, https://patch.com/california/sanramon/san-ramon-mayor-announces-re-election-campaign; Danville San Ramon, "Armstrong launches bid for second term as San Ramon mayor," March 29, 2026, https://www.danvillesanramon. com/election/2026/03/29/armstrong-launches-bid-for-second-term-as-san-ramon-mayor/.) Those campaign statements reinforce the concern raised here. However, the problem is broader than a single campaign message or a single elected official. Resolution No. 2026-066 is a decision of the full City Council. All Councilmembers are responsible for determining whether the budget before them actually implements the Council's adopted goals and objectives.

Approving a budget that still relies on Measure N to close a growing operating deficit is difficult to reconcile with Goal 2's commitment to maintaining a secure financial base unless the Council also requires concrete implementation of revenue alternatives, cost-saving strategies, service-level metrics, internal controls, and financial forecasting. Approving the budget before the forecast model, five-year projection, and internal-control recommendations are finalized is inconsistent with Goal 3's commitment to cost-effective and responsive services. Approving the budget while public comments remain difficult to locate under vague CivicClerk labels is difficult to reconcile with Goal 5's engagement and communication objectives. And approving the budget while the City Manager continues to articulate a narrow economic-development approach is difficult to reconcile with Goal 6's commitment to balance housing, retail, jobs, and open space.

The Mayor's campaign promises are therefore relevant, but they are not the only benchmark. The controlling benchmark is the Council's own adopted policy framework. The Council should not allow campaign rhetoric, budget rhetoric, or staff rhetoric to substitute for measurable implementation of the goals the Council itself adopted.

The City Manager's Reliance on Taxes Is Not a Fiscal Strategy, and the Economic Development Approach Is Inadequate Under the Council's Own Goals
The proposed budget must also be evaluated in light of the City Manager's role. The City Administration section states that the City Manager provides professional leadership in managing the City and implementing City Council policies, and that the office ensures effective municipal services by coordinating and directing all City activities. City Administration includes the City Manager's Office, City Clerk's Office, Communications, Council Relations, Economic Development, Information Technology, and Legislative Affairs.

That means the City Manager is not merely an observer of the structural deficit. The City Manager is responsible for the execution of management. If the City Manager repeatedly suggests that another tax measure will be necessary, perhaps after Measure N expires or even sooner, while also presenting an underdeveloped economic-development strategy, then the issue is not simply a revenue problem. It is a management accountability problem under the Council-Manager form of government.

The City Manager's economic-development posture should be evaluated under the Council's Goals, not merely as a matter of management style. Goal 2 requires revenue growth options alongside cost-saving strategies. Goal 5 requires engagement with residents and the business community, as well as a comprehensive assessment of the San Ramon economy within the Tri-Valley and Bay Area contexts. Goal 6 requires balanced land-use planning for housing, retail, jobs, and open space, including work with stakeholders on new infill development opportunities within the city core and existing commercial centers.

Those goals require more than repeated statements that only a Costco-type use "moves the needle." They require a practical and comprehensive economic-development strategy for the City of San Ramon, actually: currently, a suburban employment center with existing retail anchors, office reuse challenges, City Center, Bishop Ranch, aging commercial centers, border-area retail leakage, hotels, restaurants, service businesses, and major ongoing land-use transitions.

The proposed budget shows only $146,058 for Economic Development within the City Manager Division. The same budget lists, as a Fiscal Year 2025/26 City Administration accomplishment, that the City "reduced the current number of city committees for greater government efficiency," and separately states that the City worked with the San Ramon Chamber of Commerce and the business community to promote growth and retail development. But that vague description does not amount to a serious revenue strategy.

The City dissolved its Economic Development Advisory Committee on November 12, 2024, by Minute Order No. 2024- 007 under Agenda Item 8.1, along with the Housing Advisory Committee, Innovation and Technology Advisory Committee, and Transportation Demand Management Advisory Committee. That matters here because the City is now adopting a budget that relies on Measure N, continues to show a structural deficit, and says operational discussions will include "revenue generation." Yet the City eliminated its dedicated economic-development advisory body and has not shown the public a comprehensive replacement structure for business attraction, business retention, site readiness, retail leakage analysis, restaurant recruitment, hotel-market strategy, office reuse, commercial vacancy reduction, or sales-tax diversification. (Danville San Ramon, "San Ramon council to consider dissolving four advisory bodies," November 11, 2024, https://www.danvillesanramon.com/city-government/2024/11/11/san-ramon-council-to-consider-dissolving-four- advisory-bodies/.)
The City Manager has claimed economic-development experience. But in public discussions, he has repeatedly conveyed the message that only a Costco-type use "moves the needle" for the City, while also making dismissive comments to the effect that San Ramon is too good for an "Olive Garden." This isn't an adequate economic-development strategy for a city facing a structural deficit. It is especially inadequate in a city whose existing revenue context is heavily tied to retail, restaurants, hotels, commercial services, office employment, and destination activity.

The issue is not whether San Ramon should have a Costco warehouse, an Olive Garden, or any other specific business.

The issue is whether the City is pursuing an all-of-the-above economic-development strategy that takes seriously every lawful, compatible, revenue-producing opportunity to diversify the General Fund. A city that is structurally dependent on Measure N does not have the luxury of civic vanity. It cannot afford to dismiss mid-market family dining, neighborhood- serving retail, service retail, hotels, entertainment, experiential uses, business services, office reuse, and smaller cumulative revenue opportunities merely because each opportunity is not a Costco.

The City's own budget undercuts any overly narrow "only Costco moves the needle" narrative. The budget's "Top 20 Businesses" list includes Target Corporation, Home Depot, Safeway, Whole Foods Market, ClubSport, Chevron, Five, Robert Half, San Ramon Regional Medical Center, and other major employers or sales-tax-relevant businesses. Target Corporation alone is listed in the City's business-license records as one of the City's top 20 businesses, with 215 listed employees. The existence of a Target "Greatland" within the City limits should not be ignored in discussions of retail context, sales-tax exposure, public safety, and revenue resilience.

Public reports also show that the Target on Bishop Drive was the site of an improvised explosive device used to access an automated teller machine, causing damage and at least temporary closure or operational disruption. That incident is not offered here as a public-safety argument. It is a fiscal-resilience example. If a single major retail anchor is disrupted, the City should be able to quantify the fiscal exposure. It should know what sales-tax impact results from closure, partial closure, reduced foot traffic, insurance reconstruction, or loss of consumer confidence. The City should not treat anchor retail as stable while simultaneously dismissing smaller yet cumulatively meaningful economic development opportunities. (SFGATE/Bay City News, "Arrest made in robbery ring that nabbed $4 million, bombed Target ATM," August 1, 2025, https://www.sfgate.com/bayarea/article/bomb-solves-target-atm-heist-20797775.php; United States Department of Justice, Eastern District of California, "Fugitive Member of Chilean ATM Crew Arrested after ATM Bombing in San Ramon," July 31, 2025, https://www.justice.gov/usao-edca/pr/fugitive-member-chilean-atm-crew-arrested-after-atm- bombing-san-ramon.)
The Costco example also illustrates the problem. A Costco warehouse exists in Danville, immediately at the San Ramon border, while the Costco gas station is located at 3111 Fostoria Way in San Ramon. (Costco Danville Warehouse listing, https://www.costco.com/warehouse-locations/warehouse-21.html; Costco Gas Station listing, 3111 Fostoria Way, San Ramon.) That geography should prompt a more sophisticated border-area revenue strategy, not repeated resignation that only a Costco warehouse "moves the needle." The City should be asking what revenue it captures, what revenue leaks to Danville, Dublin, Pleasanton, and other jurisdictions, and what realistic opportunities exist in San Ramon's existing commercial centers, Bishop Ranch, City Center, Crow Canyon Road, San Ramon Valley Boulevard, and other retail and employment areas.

At some point, repeated reliance on taxes is not a strategy. Management has not adequately performed the economic development, revenue diversification, and fiscal management work required by the Council's goals. If the City Manager's answer to the structural deficit is essentially Measure N now and another tax later, while economic development remains narrow, dismissive, and underdeveloped, then the Council should confront that management failure directly rather than treat it as an unavoidable fiscal condition.

Resident-Identified Revenue and Cost Alternatives Must Be Addressed Before Any Future Tax Measure Is Normalized
A recent public comment by San Ramon resident Mr. Yohannes Tilahun on NextDoor crystallizes the same concern from a resident perspective. His point is straightforward: San Ramon spends more than it brings in every year; the gap is $13.7 million this year and $12.1 million last year; Measure N is covering that gap; and the City has not publicly exhausted a full range of revenue and cost-management alternatives before discussing another possible voter tax measure. (https://nextdoor.com/p/k7gGFfH43gRb?view=detail)
That is not an anti-service argument. It is a fiscal-governance argument. The City's own documents confirm the core of the concern. The Agenda Item staff report states that the projected Fiscal Year 2025/26 operational budget continues to show a $12.1 million structural deficit, covered by Measure N revenues, and that Fiscal Year 2026/27 anticipates a $13.7 million structural deficit, to which expected Measure N revenues will be applied. The proposed budget allocates approximately $14.9 million to Measure N for Fiscal Year 2026/27.

This is not a theoretical concern. If Measure N is covering ordinary ongoing operations, the City must demonstrate that it is using the Measure N window to reduce the structural deficit, not merely to postpone the next request for taxes. The City must publicly evaluate revenue and cost alternatives before any future tax measure becomes the default assumption.

On the revenue side, San Ramon should publicly evaluate whether its current business license and business tax structure remain appropriate. San Ramon requires businesses to obtain a business license. Still, the City should explain whether it has evaluated a broader business tax model, including gross receipts, employee-based, square footage, or a hybrid approach. (City of San Ramon Business License webpage, https://www.sanramon.ca.gov/business/business_license.) Pleasanton's Fiscal Year 2025/26-Fiscal Year 2026/27 Budget-in-Brief identifies $6.2 million in Business License Tax revenue. (City of Pleasanton, Budget-in-Brief Fiscal Year 2025/26-Fiscal Year 2026/27, https://www. cityofpleasantonca.gov/assets/our-government/finance-department/budget-overview/2025-26fy-2026-27fy-budget-in- brief.pdf.) That does not mean San Ramon should automatically copy Pleasanton. It does mean San Ramon should publicly analyze business-tax options before normalizing another resident-facing tax measure.

The same is true for the transient occupancy tax. San Ramon's budget identifies the City's transient occupancy tax rate as 7.25 percent. Pleasanton's current hotel tax rate is 8 percent, and Pleasanton has publicly explored increases to 10 percent and 12 percent. (City of Pleasanton, Potential Hotel Tax webpage, https://www.cityofpleasantonca.gov/our- government/city-manager/hotel-tax/.) Again, this does not mean San Ramon should automatically raise its transient occupancy tax. It means the City should publish a San Ramon transient occupancy tax comparison and revenue estimate that shows the fiscal effects of the 8 percent, 10 percent, and 12 percent options, including competitiveness and hotel- market considerations, before suggesting that residents may need to approve another broad tax measure.

The City should also provide a public grant-replacement strategy. The proposed budget states that Police Department revenues decrease by $542,992, or 22.8 percent, primarily due to the conclusion of the Organized Retail Theft Prevention Grant. If grant revenue is expiring, the budget should not simply absorb that loss. The City should identify every material grant that expired, every grant that was not renewed, every grant that was not replaced, the reason replacement funding was not obtained, and whether staffing or consultant resources are being used effectively to pursue recurring grant opportunities. This is directly relevant to Goal 1's public-safety objectives and Goal 2's secure-financial-base objective.

On the cost side, residents are also right to ask whether San Ramon's service model has been publicly evaluated with enough specificity. The budget identifies 65 parks, including 18 school parks, as well as two libraries, four community centers, two service centers, two aquatic centers, two theaters, and extensive public facilities. The Public Services performance measures identify 65 parks, 400.6 acres of parks, 403.1 acres of landscape, 53 miles of trails, 35 soccer fields, 40 baseball fields, three cricket pitches, tennis courts, dog parks, skate parks, rest nodes, and other facilities.

A tiered model for parks, trails, facilities, and landscape maintenance should be evaluated publicly. That does not mean closing parks or cutting services people rely on. It means distinguishing between high-use parks, specialized facilities, neighborhood parks, landscape zones, trails, rest nodes, sports fields, and lightly used areas so that maintenance frequency and service levels can be matched to actual use, risk, equity, and cost. The Public Works budget already identifies reductions carried over from last year, including facilities carpet cleaning, facilities floor refinishing, and parks janitorial services at approximately a 50 percent reduction, as well as the elimination of twice-yearly facilities window cleaning. If reductions are already occurring, the public should see a formal service-level strategy rather than scattered budget notes.

The same scrutiny is needed for contract services. The proposed budget shows City Administration contract services increasing from $1,193,738 in Fiscal Year 2022/23 actuals to $2,810,814 in Fiscal Year 2026/27 proposed expenditures. That increase may include legitimate technology, cybersecurity, communications, agenda, records, and other costs, but it still warrants a public accounting. The City should provide a contract-services inventory showing each contract, amount, scope, term, whether the cost is one-time or ongoing, whether the contract substitutes for vacant or absent staff capacity, and whether the contract is related to the Accounting Manager's absence, internal controls, budget modeling, records management, website improvements, or policy development.

The City should not describe public concern over these issues as opposition to public services. The point is not to cut essential services. The point is to ask questions that the City has not yet answered publicly. The Council's own Goal 2 requires revenue growth options alongside cost-saving strategies. Goal 3 requires cost-effective and responsive services supported by consistent metrics. Goal 4 requires quality facilities and infrastructure. Goal 5 requires engagement and communication. The current budget does not yet show that those goals have been fulfilled. It shows that the City intends to keep working on them after adoption.

The July 14 Financial Plan Presentation Should Not Become a Presentation of Preselected Conclusions If the July 14, 2026 presentation by an outside consultant is intended to present the full 10-year financial plan, then that presentation should be treated as one of the most important fiscal-governance meetings of the year. The Council should not allow that meeting to become a presentation of preselected staff and consultant conclusions.

The full scope of work, baseline assumptions, revenue alternatives, expenditure alternatives, Measure N drawdown control assumptions, ACFR assumptions, and consultant workpapers should be posted in advance in searchable form.

The public should be able to see whether the City modeled real alternatives or merely modeled a pathway toward another tax measure. A credible 10-year financial plan should include alternatives showing what happens with no new taxes, with business-tax options, with transient-occupancy-tax options, with stronger economic development, with different service- level assumptions, with tiered maintenance, with contract-service controls, with grant replacement, with cost recovery, with internal-control implementation, and with different Measure N drawdown schedules. coman: Pres armans had a man ne superman seal
Specific Requests Before Adoption
Before approving Resolution No. 2026-066, I respectfully request that the City Council require staff to answer the following questions on the record or continue the item until written responses can be posted directly under Agenda Item First, the City should identify the current status of the Accounting Manager position or function. The City should state when the "existing extended absence" began, whether the position is vacant, filled but absent, temporarily backfilled, reclassified, or otherwise inactive, what consulting firm was retained to supplement the function, what the contract amount and scope of work are, and whether the consultant prepared, reviewed, reconciled, or validated Fiscal Year 2025/26 projected actuals, Fiscal Year 2026/27 proposed budget figures, fund balances, transfers, Measure N assumptions, reserve calculations, Gann appropriations-limit figures, or capital carryover appropriations.

Second, the City should disclose the status of the Fiscal Year 2025 Memorandum on Internal Controls, identify which recommendations remain outstanding, and explain why the budget should be adopted before those recommendations are fully implemented.

Third, the City should specifically reconcile the Fiscal Year 2026/27 budget with the attached public comments from January 27, February 18, and March 24 regarding the Annual Comprehensive Financial Report and Internal Controls Memorandum. That reconciliation should explain how the City has corrected or is correcting the $6,004,488.87 correction, negative fund balances, unsupported transfers, unbudgeted expenditures, "due to General Fund" liability, delayed year-end close, missing Internal Controls Memorandum, untimely bank reconciliations, failure to post prior-year audit adjustments, grant-tracking failures, missed Single Audit deadline, untimely journal-entry review, and cash-handling segregation-of-duties issues.

Fourth, the City should explain how the Council can credibly rely on the Financial Resilience Framework when the forecast model and five-year financial projection are still listed as October 2026 deliverables, when the broader policy and operational discussions remain pending, and when implementation of Internal Controls Memorandum recommendations is still scheduled for after adoption of the budget.

Fifth, the City should clarify whether the City Manager or staff are assuming that another tax measure will be necessary, when such a measure is being contemplated, and what operational reductions, cost-containment measures, revenue alternatives, service-level choices, program-prioritization actions, audit-correction actions, and economic-development actions will be pursued before any new tax is considered.

Sixth, the City should publish a comprehensive economic development work plan that ties revenue diversification to reduced dependence on Measure N. That work plan should include business retention, business attraction, retail leakage, restaurant recruitment, hotel-market strategy, office reuse, commercial vacancy, border-area revenue capture, City Center, Bishop Ranch, Crow Canyon Road, San Ramon Valley Boulevard, and existing commercial-center strategies.

Seventh, the City should explain why the Economic Development Advisory Committee was dissolved before the City completed the comprehensive assessment of the San Ramon economy, now listed as a Fiscal Year 2026/27 objective, and how the public will participate in the economic development strategy now that the dedicated advisory body has been eliminated.

Eighth, the City should evaluate business-tax options, transient-occupancy-tax options, grant-replacement strategies, tiered maintenance models, contract-service controls, cost-recovery alternatives, and internal-control improvements before any further discussion of tax measures is normalized.

Tenth, the City should include in the final adopted budget a plain-language Council Goal reconciliation table showing each applicable Council goal and objective, the corresponding budget action, the funding source, the measurable implementation step, the completion date, and the responsible department or official.

Eleventh, the City should ensure that all public comments on Agenda Item 8.1, including the attached ACR and Internal Controls comments incorporated by reference, are clearly labeled as public comments, not buried under "Supplemental Materials," and that all budget-related materials remain permanently accessible in searchable form.

Conclusion
The Council should not adopt Resolution No. 2026-066 as though the only question is whether the budget document balances on paper. The deeper question is whether the budget actually implements the Council's own Fiscal Year 2026/27 Goals and Objectives.

On the current record, the budget remains materially incomplete as an implementation document. It relies on Measure N to cover an ongoing structural deficit while the Financial Resilience Framework remains unfinished. It asks the public to trust budget numbers even as the City has acknowledged an extended absence of the Accounting Manager and internal-control recommendations remain pending. It generates revenue, while the City has dissolved its Economic Development Advisory Committee and has not yet produced a comprehensive economic development strategy. It references engagement and communication, while public comments risk being hidden under vague "Supplemental Materials" labels rather than clearly identified as public testimony. And it discusses cost-effective services without providing enough public analysis of service-level alternatives, contract-service growth, tiered maintenance, grant replacement, or economic-development alternatives.

Those deficiencies are inconsistent with Goal 2's secure financial base, Goal 3's cost-effective and responsive services, Goal 4's quality facilities and infrastructure, Goal 5's engagement with residents and the business community, and Goal 6's balanced planning for housing, retail, jobs, and open space.

The incorporated ACFR and Internal Controls comments make the problem more serious, not less. They show that this budget is being adopted in the shadow of a recent $6,004,488.87 correction, missing audit deliverables, significant internal control deficiencies, unresolved corrective actions, and a prior failure to provide the Council and the public with a complete audit record when the ACFR was presented. Those issues cannot be separated from a Measure N-dependent budget and a Financial Resilience Framework that remains incomplete.

Mayor Armstrong's campaign promises regarding fiscal accountability and responsible budgeting reinforce this concern, but the obligation belongs to the entire City Council. The Council adopted these goals. The Council is being asked to adopt this budget. The Council should therefore require staff to reconcile the proposed budget with the Council's own objectives before approving Resolution No. 2026-066, or approve it only with explicit direction for a public accounting- capacity, internal-control, ACFR-correction, financial-resilience, contract-services, revenue-alternatives, and economic- development implementation report tied directly to each applicable Council goal and objective.

A budget supported by Measure N may be legally adoptable. But a budget that relies on Measure N to cover an ongoing structural deficit, while the City has acknowledged an extended absence of the Accounting Manager, while internal-control recommendations remain unfinished, while the forecast model and five-year projection remain future deliverables, while the City Manager continues to normalize future tax dependence, while the City's economic-development strategy remains narrow and underdeveloped, and while prior audit and internal-control failures remain unresolved as governance issues, should not be presented to the public as proof that San Ramon is living within its means.

I respectfully request that the City Council either continue Agenda Item 8.1 for additional disclosure and written responses, or adopt the budget only with explicit direction that staff returns with a public accounting-capacity, internal- control, ACFR-correction, financial-resilience, contract-services, revenue-alternatives, service-level, and economic- development implementation report before the City makes any further public claim that another tax measure may be necessary.

Respectfully submitted
Brian C. Swanson, AICP
San Ramon Voter, Taxpayer, and Resident
On Fri, May 22, 2026 at 2:48 PM City of San Ramon < [email protected]> wrote:

The City of
San Ramon
San Ramon
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City of San Ramon | 7000 Bollinger Canyon Road, San Ramon, CA 94583 | (925) 973 2500 | www sanramon ca gov 4 attachments

02.18.2026 - BSwanson_PublicCommentVerbalScript_FinanceCommittee_Item5.

Z 3FY25InternalControlsMemo.pdf
94K

03.24.2026 - CityCouncil_Public Comment_ Request to Pull Agenda Item 5.4 - FY25 Memorandum on 2 Internal Control from the Consent Calendar and Formal Comment.pdf

02.18.2026 - BSwanson_PublicComment_Agendaltem5.3_FY25 Memo on Internal 2 Control_FinanceCommMtg.pdf

01.27.2026 - BSwanson - WrittenPublicComment_ Agenda Item 9.2 - Audited ACFR for the City of San Ramon for the FY Ended June 30, 2025 - City Council Meeting.pdf

City Council Finance CommitteeJune 3, 2026

City Council Finance Committee
June 3, 2026