Melillo gives preliminary CFB feedback on the four bills
Melillo notes the CFB had one week to review the four bills and says T2026-2553 by Council Member Wong duplicates existing CFB disclaimer rules, T2026-2555 by Carr broadens existing blackout law with no formal position, and T2026-1440 by Carr would disperse reporting obligations to individual public servants rather than agencies.
Turning to the bills before the committee today, I want to note that the CFB has had one week to review the
proposed four pieces of legislation, so our feedback at this stage is preliminary, and we look forward to providing more detailed comments and suggested edits to the council after conducting a more detailed analysis of the impact on CFB operations.
However, from initial review, several of these bills raise serious concerns and as currently drafted would have unintended negative consequences for the agency's work.
The first bill I will discuss is T2026-2553 introduced by Councilmember Wong, which would codify paid-for-by disclaimer requirements on online and digital campaign expenditures.
CFB Rule 6-06 has required these disclaimers on all campaign advertising since the 2017 election cycle and was expanded in 2024 to cover additional communication types, including paid influencer content.
Such expenditures are already disclosed and documented like any other campaign advertising spending.
Rule 14-04 similarly requires disclaimers, uncovered communications by independent spenders, and visual, video, or audio formats.
This legislation appears to duplicate the existing disclaimer requirements without changing the current obligations of
campaigns and we don't believe these changes are necessary to the charter.
T2026-2555 introduced by Councilmember Carr would prohibit candidates for office from appearing in certain digital or online government funded public communication during the 90 days preceding an election.
The CFB already enforces the existing part of this law, which prohibits using governmental resources for mass mailings during this period.
This bill would simply broaden the scope of communication types required under this law.
We have no substantive feedback at this time and have no formal position on this bill.
T-2026-1440, sponsored by Councilmember Carr, would require public servants to report spending on public communications paid for with government resources.
As drafted, the reporting obligation falls on the individual public servant who authorizes the use of government funds, which could unnecessarily disperse responsibilities across an agency and lead to duplicative or missed reports.
We believe agency-level reporting through existing advertising spending reporting would better achieve this goal while consolidating reporting obligations.
Given these concerns, the CFB does not support the bills currently drafted, but we welcome further discussion with the Council to share our perspectives as an agency that funds public communications.