Melillo says CFB cannot support T2026-2554's shared enforcement structure
Melillo says T2026-2554 by Council Member Feliz raises fundamental concerns because designating the CFB as an enforcing agency over other city agencies is misaligned with its charter role, and the proposed shared enforcement with the Conflicts of Interest Board would create complexity and inconsistent standards.
Lastly, T2026-2554, introduced by Councilmember Feliz, would require
government agencies to disclose their partnerships on certain third-party public communications.
As currently drafted, the bill raises fundamental concerns that prevent the CFB from supporting it.
Designating the CFB as an enforcing agency is misaligned with our current charter role, our existing role and charter mandate.
The CFB does not investigate or regulate other city agencies.
The proposed shared enforcement structure with the Conflicts of Interest Board compounds this problem.
Dividing responsibility between two agencies would create unnecessary complexity in rulemaking, enforcement procedures, and administration, potentially producing inconsistent standards and undermining effective enforcement.