4.1. Amendments to Union City Municipal Code Chapter 2.05 (Campaign Reporting Requirements) to Align Electronic Filing Thresholds with State Law
Legislation and Policy Committee Staff
Report Page 1 of 2 November 10, 2025
Agenda Item No. 4.1
DATE: November 10, 2025
TO: Members of the Legislation and Policy Committee
FROM: Thai Nam Pham, City Clerk
SUBJECT: Amendments to Union City Municipal Code Chapter 2.05 (Campaign Reporting Requirements) to Align Electronic Filing Thresholds with State Law
EXECUTIVE SUMMARY
Staff recommends that the Legislation and Policy Committee review and discuss a proposed amendment to Union City Municipal Code Chapter 2.05 (Campaign Reporting Requirements) to ensure consistency with current provisions of the California Political Reform Act (Government Code § 84615). The proposed change would adjust the monetary threshold that determines which filers are exempt from mandatory electronic filing of campaign disclosure statements, lowering the exemption level from $2,000 to $1,000, in alignment with state law.
BACKGROUND
In April 2024, the City Council adopted Ordinance No. 921-24 updating Chapter 2.05 of the Union City Municipal Code to include a mandatory electronic filing requirement for campaign statements and reports. Section 2.05.050(A) currently requires all candidates, committees, and elected officials to file electronically, except those who both receive less than $2,000 in contributions and make less than $2,000 in expenditures in a calendar year.
Under Government Code § 84615, a local government agency may require online or electronic filing of campaign disclosure statements. Still, it must exempt filers who receive less than $1,000 in contributions and make less than $1,000 in expenditures in a calendar year. The statute establishes this $1,000 figure as the minimum threshold for exemption.
Because the City’s ordinance sets a higher exemption threshold ($2,000), it currently exceeds the level contemplated by state law. While the intent was to simplify filing obligations for small filers, maintaining a different standard could expose the City to potential conflicts with the Political Reform Act or confuse filers and enforcement agencies.
Agenda Item No. 4.1
Legislation and Policy Committee Staff
Report Page 2 of 2 November 10, 2025
DISCUSSION
Amending Section 2.05.050(A) to reflect the state-mandated threshold would ensure compliance and uniformity with the Political Reform Act. The proposed language revision is as follows:
Current:
“... except an elected officer, candidate, committee, or other person who receives contributions totaling less than $2,000 and makes expenditures totaling less than $2,000 in a calendar year ...”
Proposed Amendment:
“... except an elected officer, candidate, committee, or other person who receives contributions totaling less than $1,000 and makes expenditures totaling less than $1,000 in a calendar year ...”
This change would align the City’s ordinance with Government Code § 84615(a) and reduce the risk of inconsistency with state regulations governing local electronic filing systems.
Additionally, staff will ensure that any conforming edits maintain the existing requirements for data integrity, compatibility with the Secretary of State’s standardized format, and public access provisions.
FISCAL IMPACT
None. The City’s existing electronic filing platform (NetFile) will continue to operate within current licensing costs.
RECOMMENDATION
That the Legislation and Policy Committee:
1. Review and discuss the proposed amendment to UCMC § 2.05.050(A); and
2. Provide direction to staff on whether to prepare a formal ordinance amendment for City Council consideration.
Prepared by: Thai Nam Pham, City Clerk
Attachments:
1. Current UCMC § 2.05
CHAPTER 2.05
CAMPAIGN REPORTING REQUIREMENTS
§ 2.05.010. Campaign filing and reporting requirements. (Ord. 921-24, 4/23/2024)
§ 2.05.015. Acknowledgment of requirements.
Each candidate shall sign and submit a form provided by the City Clerk acknowledging receipt of Union City Municipal Code Chapter 2.05 and understanding of the campaign filing and reporting requirements specified in the Union City Municipal Code. (Ord. 921-24, 4/23/2024)
§ 2.05.020. Contributions included in report.
The reports submitted in accordance with this chapter shall include contributions received and expenditures made by candidates up to midnight of the Wednesday before the scheduled general municipal election.
(Ord. 410-93 § 3, 1993; Ord. 921-24, 4/23/2024)
§ 2.05.030. Applicable definitions.
All definitions included in the Political Reform Act of 1974 as they relate to reporting requirements shall be used by candidates in submitting this additional report. (Ord. 410-93 § 4, 1993; Ord. 921-24, 4/23/2024)
§ 2.05.040. (Reserved)
(Ord. 410-93 § 5, 1993; Ord. 921-24, 4/23/2024)
A. Standard Reporting. All candidates for elective office in the City of Union City must adhere to the campaign reporting requirements established under the Political Reform Act of 1974, including the filing of campaign statements as prescribed by state law.
B. Additional Pre-Election Statement Requirement.
1. Filing Requirement. In addition to the State law required filing of campaign statements, each recipient committee formed in conjunction with an election for a municipal office shall file one additional recipient committee pre-election campaign statement with the City Clerk.
2. Filing Deadline. This statement must be filed four calendar days before the election, no later than 2:00 p.m.
3. Coverage Period. The additional pre-election statement shall cover the period from the day after the last date of the most recent pre-election statement required by State law to seven calendar days before the election.
C. Definitions: For the purposes of this chapter, all definitions included in the Political Reform Act of 1974 as they relate to reporting requirements shall apply.
City of Union City, CA
§ 2.05.010 § 2.05.050
Downloaded from https://ecode360.com/UN5025 on 2025-10-27 § 2.05.050. Electronic filing.
(Ord. 894 § 3, 2022; Ord. 921-24, 4/23/2024)
A. Any elected officer, candidate, committee, or other person required to file statements, reports, or other documents required by Government Code Chapter 4 (commencing with Section 84100), except an elected officer, candidate, committee, or other person who receives contributions totaling less than $2,000, and makes expenditures totaling less than $2,000 in a calendar year, shall file those statements, reports, or other documents online or electronically with the City Clerk.
B. In any instance in which an original statement, report or other document must be filed with the California Secretary of State and a copy of that statement, report or other document is required to be filed with the City Clerk, the filer may, but is not required to, file the copy electronically.
C. If the City Clerk's electronic system is not capable of accepting a particular type of statement, report, or other document, an elected officer, candidate, committee or other person shall file that document with the City Clerk in an alternative format.
D. The electronic filing system will operate securely and effectively and will not unduly burden filers. Specifically, the electronic filing system will ensure the integrity of the data and includes safeguards against efforts to tamper with, manipulate, alter, or subvert data; the electronic filing system will only accept a filing in the standardized record format developed by the Secretary of State and compatible with the Secretary of State's system for receiving an online or electronic filing; and the electronic filing system will be available free of charge to filers and to the public for viewing filings.
City of Union City, CA
§ 2.05.050 § 2.05.050
Downloaded from https://ecode360.com/UN5025 on 2025-10-27