# Compliance Self-Log Guide — Her Own FPPC Filing Autopilot
**Version:** v1.0 — 2026-10-01
**Jurisdiction:** California (state) + LA / SF / San Diego / San Jose / Oakland (local)
**Page:** `/compliance-self.html` · **Engine:** `js/compliance-self.js` · **Store:** localStorage `silobbyist_compliance_v1`
**Supersedes:** none (initial release)
**Maintainer note:** Limit figures verified against the Political Reform Act, FPPC regulations, and FPPC guidance on 2026-10-01. General information, not legal advice. FPPC advice: advice@fppc.ca.gov, 866-275-3772. This guide compiles into Goldie's brain (via `_core.md`); the page is the lobbyist's private tool.

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## 1. What the autopilot does

She's a filer too. The self-log keeps HER compliant the way the rest of SiLobbyist keeps her practice sharp:

- **Quick-log** expenses, gifts, meals, events, contributions, and lobbying contacts as they happen (date, type, payee, amount, purpose, official + position, client/employer).
- **Running tallies** of per-official gift totals against the verified limits, with the source and year on every figure.
- **Instant "can I do this?" readouts** on every logged gift — "$X of $Y" in plain language.
- **Auto-drafted quarterly reports** in Form 615-style summary + Form 640-style detail, generated from the log as a reviewable **DRAFT**.
- **Deadline reminders** from the FPPC filing data.
- **Privacy:** everything lives in this browser (localStorage `silobbyist_compliance_v1`), exportable as JSON, one-tap delete. Nothing is transmitted anywhere. Excluded from the learning loop like all practice data.

**The standing rule, stated twice because it matters:** *It drafts — she files.* The page generates drafts; she reviews and files with the Secretary of State. Nothing here is a filing, and SiLobbyist never claims to file with the SOS on anyone's behalf, never claims accredited or filing-agent status.

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## 2. Limit tables (with sources)

### 2a. Gift limits — the ones that bind her directly

| Limit | Figure | Scope | Source | Effective |
|---|---|---|---|---|
| Lobbyist $10/month gift ban | **$10** per person per calendar month | Gifts by a lobbyist or lobbying firm to one person (state candidates, elected state officers, legislative officials, covered agency officials) | Gov. Code §86203 | Current; no CPI adjustment |
| General gift limit | **$630** per source per calendar year | Gifts to a public official from any single source | Gov. Code §89503; FPPC Reg 18940.2 | 2025–2026 (odd-year CPI adjustments) |
| Next general-limit adjustment | **figure not yet published** (as of 2026-10-01) | — | FPPC Reg 18940.2 | Takes effect 1-1-2027 |
| Gift-notice threshold | **$50+** paid for an official's event attendance | Lobbyist must give the official a written gift notice within 30 days | FPPC Lobbying Manual Ch. 4 | Current |
| Post-deregistration survival of the $10 ban | **~6 months (approximate)** | The §86203 ban continues after a lobbyist deregisters | FPPC Lobbying Manual Ch. 4; `data/compliance.json` | Treat the exact end date as approximate — confirm with the FPPC |

**Which one binds her?** The **$10/month** ban is her hard line: gifts, meals, and event spending for an official aggregate against it each calendar month. The $630/year figure governs gifts from non-lobbyist sources — the self-log shows it as context for the employers and clients she advises. (Meals, entertainment, and travel paid by lobbyists count as activity expenses **and** gifts — FPPC Lobbying Manual Ch. 4 — so official-attended meals/events feed both tallies.)

### 2b. Filing thresholds

| Threshold | Figure | What it triggers | Source |
|---|---|---|---|
| E-filing trigger | **$2,500+/quarter** in any reportable category | Must file electronically (SOS Cal-Online, free); all future filings stay electronic | FPPC Lobbying Manual Ch. 2 |
| §86115(b) $5,000 filer | **$5,000+/quarter** in qualifying payments, no lobbyist or firm | Form 645, electronic only; file only in quarters with ≥$5,000 | Gov. Code §86115(b) |
| Contract-lobbyist qualification | **$2,000+/month** economic consideration for direct communication | Must register as a lobbyist (Form 601/604) | Gov. Code §82039 |
| In-house lobbyist qualification | **≥1/3** of compensated time in a month in direct communication | Employer's employee qualifies as a lobbyist | Gov. Code §82039 |
| Late-fine math | **$10/day**, capped at the cumulative amount in the late filing or **$100**, whichever is greater | Late statements/reports | Gov. Code §91013 |
| Record retention | **5 years** from the date reported | All contribution/expenditure records (journal/ledger; $25+ contributions need cancelled checks or bank records) | Gov. Code §§86110–86117; FPPC Reg 18610 |

### 2c. Contribution & honoraria rules (for the self-log's contribution type)

- A lobbyist may not contribute to an elected state officer or candidate **if registered to lobby that officer's agency** — and the officer/candidate may not accept (Gov. Code §85702; FPPC Reg 18572).
- No person may receive or personally deliver a contribution in the State Capitol or a state/local government office building (Gov. Code §84309).
- Honoraria ban: elected state officers, candidates, board/commission members, and designated employees (where the source is reportable) may not accept honoraria — payment for speeches, articles, or event attendance (Gov. Code §89502, as amended by AB 378 (2021)).
- Contingency fees banned: no compensation dependent to any degree on a legislative/administrative outcome (Gov. Code §86205(f); FPPC Reg 18626, operative 1-12-2023).

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## 3. What's reportable (Form 615 + Form 640 fields)

**Form 615** — individual lobbyist quarterly report (Gov. Code §86113): activity expenses, gifts, honoraria received, contributions made/delivered, sub-vendor payments, other payments to influence.

**Form 640** — activity-expense detail attached to the quarterly report: **date · payee · beneficiary and official position · amount attributable to each beneficiary · description.** The self-log collects exactly these fields so the quarterly draft is field-complete.

**Reportable from the log:** gifts, meals, events/travel/entertainment, activity expenses, contributions made/delivered, lobbying contacts (narrative). Behested payments ($5,000+ at an official's request) are reported by the officer on Form 803 — flag them to the official's team; employers also report them on Form 635 when lobbying support is the primary purpose.

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## 4. Filing cadence (state)

| Quarter | Period | Due | Forms |
|---|---|---|---|
| Q1 | Jan 1 – Mar 31 | **Apr 30** | 615 · 625 · 635 · 630 · 635-C |
| Q2 | Apr 1 – Jun 30 | **Jul 31** | 615 · 625 · 635 · 630 · 635-C |
| Q3 | Jul 1 – Sep 30 | **Oct 31** | 615 · 625 · 635 · 630 · 635-C |
| Q4 | Oct 1 – Dec 31 | **Jan 31** | 615 · 625 · 635 · 630 · 635-C |

File **every quarter even with zero activity** (except §86115(b) $5,000 filers, who file only quarters with ≥$5,000). A deadline on a weekend or state holiday rolls to the next business day — no other extensions. Source: `data/compliance.json` (verified 2026-10-01); FPPC Lobbying Manual Ch. 5–6.

**Note:** the legislative session calendar (`data/legislative-calendar.json`) carries session deadlines only — it contains no FPPC lobbying filing dates. Filing dates live in `data/compliance.json`.

### Local regimes (stack on top of state)

| City | Registration trigger | Reporting | File with |
|---|---|---|---|
| Los Angeles | 30+ hrs in 3 months **and** 1+ direct contact | Quarterly (via LEFS; exact due date — verify with the LA City Ethics Commission) | City Ethics Commission |
| San Francisco | 5+ contacts/mo for employer, or 1+ for a client | Quarterly, due **the 15th** (Apr 15 · Jul 15 · Oct 15 · Jan 15) | SF Ethics Commission |
| San Diego | Firm: any compensation + 1 contact; org: 10+ contacts/60 days | Quarterly, due **last day of the month after the quarter** (Apr 30 · Jul 31 · Oct 31 · Jan 31) | City Clerk |
| San Jose | (see SJMC §12.12.400) | **Weekly**, due Monday 5:00 PM | City Clerk |
| Oakland | $1,000/month compensation — register **before** lobbying | Quarterly (exact due date — verify with the City Clerk) | City Clerk |

Full detail: `kb/local-lobbying.md` (LA/SF/SD) and `kb/local-lobbying-addendum.md` (San Jose/Oakland).

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## 5. Enforcement context (why the autopilot exists)

Real 2026 FPPC actions the self-log guards against (`data/fppc-enforcement.json`):

- **Late lobbyist-employer quarterly reports** (Form 635s): $16,980 and $10,800 for ten chronically late quarters each — file every quarter, even with zero activity.
- **Recordkeeping failures**: FTB audits found missing records — keep the 5-year paper trail the log backs up.
- **Four years of non-filed Statements of Economic Interests**: proposed $18,000 penalty — annual, non-negotiable.
- Cash is radioactive: contributions of $100+ must not be cash (Gov. Code §84300); use one designated bank account (§85201).

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## 6. Goldie integration

- Deep-links per screen: quick-log, tallies, quarterly draft, deadlines, and the general compliance question — all via `/assistant.html#ask=` (the convention used across the site).
- Goldie prompt section **COMPLIANCE SELF-LOG** (in `functions/api/chat.js`) covers: the localStorage store, the verified limits to quote, "it drafts — she files," and citation of this guide.
- Goldie never sees the log contents — the store is client-side only; she answers from this guide's limits plus the user's questions.

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*End of v1.0. If the FPPC publishes the 2027 general gift-limit figure, update §2a. If CARS certification changes the filing mechanics, update §4.*