HomeMy WebLinkAboutAgenda - Full - Election Code Committee - 12/10/2024 - ECC Agenda Packet12/10/2024 – Agenda Page 1
Agenda
Election Code Committee
December 10, 2024 – 4:00 PM
Colorado River Room, 222 Laporte Avenue and via Zoom https://fcgov.zoom.us/j/98639152564
Remote Participation Available
A) Call Meeting to Order
B) Roll Call
C) Public Participation
D) Public Participation Follow-up
E) Approval of Minutes
1. Approval of Minutes.
The purpose of this item is to approve the minutes of the October 21, 2024, Election Code
Committee meeting.
F) Discussion / Informational Items
2. Revised Potential Code Changes Regarding the Campaign Complaint Process and the
Campaign Contribution Limits.
During the October 21, 2024 meeting of the Election Code Committee (ECC), staff presented
drafted code changes for Sections 7-145 and 7-135. Members of the ECC provided valuable input
and requested edits to both sections. Staff has provided a revised draft of the proposed changes.
3. Enforcement of Local Campaign Regulations
The Election Code Committee requested that staff research examples of an independent process
for campaign compliance oversight, to support a Committee discussion of ways to reduce reliance
on citizen complaints for enforcement.
4. 2024 Workplan Check-In and Election and Ranked Choice Voting Updates
The purpose of this item is to provide updates on the Committee’s Work Plan and to enable
discussion on Work Plan items. The purpose also includes providing updates on the 2024 election
and ranked choice voting efforts.
At its October 21, 2024, meeting, the Committee reviewed the remaining items on the Work Plan
and Code amendments related to campaign finance enforcement and contribution limits.
Changes have been made based on the discussion from that meeting and will be presented at
the December 10 meeting. Discussion is also planned on possible options related to additional
campaign oversight.
Discussion on possible additional Charter amendments will likely be included as part of the
Charter review project that is currently underway.
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12/10/2024 – Agenda Page 2
G) Other Business
H) Adjournment
Next Scheduled Committee Meeting: 4:00 PM, January 27, 2025
Upon request, the City of Fort Collins will provide language access services for individuals who have limited
English proficiency, or auxiliary aids and services for individuals with disabilities, to access City services,
programs and activities. Contact 970.221.6515 (V/TDD: Dial 711 for Relay Colorado) for
assistance. Please provide advance notice. Requests for interpretation at a meeting should be made by
noon the day before.
A solicitud, la Ciudad de Fort Collins proporcionará servicios de acceso a idiomas para personas que no
dominan el idioma inglés, o ayudas y servicios auxiliares para personas con discapacidad, para que
puedan acceder a los servicios, programas y actividades de la Ciudad. Para asistencia, llame al
970.221.6515 (V/TDD: Marque 711 para Relay Colorado). Por favor proporcione aviso previo cuando sea
posible. Las solicitudes de interpretación en una reunión deben realizarse antes del mediodía del día
anterior.
- Page 2 -
Council Committee Agenda Item Summary – City of Fort Collins Page 1 of 1
December 10, 2024
AGENDA ITEM SUMMARY
Election Code Committee
STAFF
Delynn Coldiron, City Clerk
SUBJECT
Approval of Minutes.
EXECUTIVE SUMMARY
The purpose of this item is to approve the minutes of the October 21, 2024, Election Code Committee
meeting.
ATTACHMENTS
1. Draft Minutes, October 21, 2024
- Page 3 -
Section E, Item 1.
City of Fort Collins Page 1
October 21, 2024
ELECTION CODE COMMITTEE MEETING
4:02 PM
COMMITTEE MEMBERS PRESENT: Arndt, Pignataro (remote), Potyondy
STAFF PRESENT: Rupa Venkatesh, Sara Arfmann, Tyler Robbins, Carrie Daggett,
Delynn Coldiron
(Secretary’s Note: The first 30 minutes of the audio recording were not available due to a technical issue;
therefore, that section of the minutes is abbreviated and based on notes from staff.)
A. CALL MEETING TO ORDER
B. ROLL CALL
C. PUBLIC PARTICIPATION
Robbie Moreland discussed former City Clerk Anissa Hollingshead’s comments on problems with
three City-initiated Charter amendments. Moreland requested a discussion as to whether the
concerns have merit, and if so, to outline the path forward.
Melissa Rosas discussed an error in Council’s packet regarding the number of days allowed for a
referendum protest, which was subsequently adopted, and asked what can be done to remedy the
situation.
D. PUBLIC PARTICIPATION FOLLOW-UP
None.
E. APPROVAL OF MINUTES
1. Approval of Minutes
The purpose of this item is to approve the minutes of the September 11, 2024, Election Code
Committee meeting.
Councilmember Pignataro made a motion, seconded by Councilmember Potyondy, to
approve the minutes of the September 11, 2024 meeting of the Election Code Committee.
Yeas: Arndt, Potyondy, and Pignataro. Nays: None.
THE MOTION CARRIED.
F. DISCUSSION/INFORMATIONAL ITEMS
2. Potential Code Changes Regarding the Campaign Complaint Process and the Campaign
Contribution Limits.
Arfmann reviewed the proposed changes to the Code related to the campaign complaint
enforcement process noting egregious errors could still go to court, and any cri minal violation
would go directly to municipal court.
Councilmember Pignataro asked about adding a flowchart to the Code. City Attorney Daggett
suggested the placement of a flowchart on the website as guidance for candidates.
Councilmember Pignataro ask ed about clarifying the timeline for the Clerk’s Office to do stage
one and notify the complainant. She also requested the inclusion of a requirement to provide a
reason for the dismissal of a complaint. Additionally, Councilmember Pignataro requested
- Page 4 -
Section E, Item 1.
City of Fort Collins Page 2
clarification on the timeline for the cure option and asked about a presumptive penalty versus a
fine.
Staff will return with revisions at the next meeting per the discussion.
Regarding campaign contribution limits, Arfmann outlined proposed changes to alter the limits
per the committee’s recommendation and include an automatic adjustment for inflation, as a
starting point.
Mayor Arndt suggested rounding the increases to the nearest $10, rounding up.
Councilmembers Pignataro and Potyondy concurred.
Mayor Arndt noted Councilmember Ohlson feels strongly that if contribution limits are doubled,
that would slightly exceed the impact of inflation.
Councilmember Pignataro noted inflation would increase the $75 limit in 2000 dollars to $140 in
today’s dollars, which is close to doubling.
Mayor Arndt expressed support for doubling the $75 and $100 limits and commented on the fact
that fundraising entails reaching many voters on a personal level.
Councilmember Potyondy expressed support for doubling the limits and including inflation
adjustments.
Councilmember Pignataro commented on the importance of campaign contributions to ensure
candidates who may not have their own money to contribute can compete on a more even playing
field. She also expressed support for doubling the limits or using inflation to calculate appropriate
increases.
Mayor Arndt noted Councilmember Canonico was suggesting higher limits than this and
suggested the full Council could have a discussion with $150 and $200 as a starting point.
Councilmember Potyondy stated Councilmember Canonico had suggested tying the limits to the
state limits.
Councilmember Pignataro commented on the language around joint contributions focusing on
checks and suggested including some clarification around electronic payments. Additionally, she
suggested changing the deadline from 10 days to the next filing period for fixing contributions in
excess of limits.
Councilmember Pignataro noted Council relies heavily on the public to bring complaints forward.
City Attorney Daggett stated her experience has been that the process always involves
responding to issues brought forth from the public.
Councilmember Pignataro requested staff provide information regarding hiring a consultant to
help during the election to investigate violations.
Members discussed the filing forms and whether they could be modified to be simpler. City Clerk
Coldiron noted there are other automated software programs that staff is beginning to research.
3. 2024 Work Plan and Election Updates.
City Clerk Coldiron outlined other possible Code changes the Committee would like to see at the
December meeting, including eliminating write-in candidates. She noted the Secretary of State
does allow up to two write-in candidates as part of ranked choice voting.
City Attorney Daggett noted staff discovered unclear requirements in the Code regarding write -
in candidates which will need to be corrected.
- Page 5 -
Section E, Item 1.
City of Fort Collins Page 3
Mayor Arndt asked how Boulder handled the issue with ranked choice voting. City Clerk Coldiron
replied that the ranked choice voting in Boulder is just for mayor and they did not allow write -in
candidates.
Councilmember Pignataro asked if there is a deadline to be a write-in candidate. City Clerk
Coldiron replied in the affirmative.
Councilmember Pignataro discussed the language Code issues with write-in candidates and
noted there are no secrets regarding who is running for an office. She suggested looking at
eliminating write-in candidates due to concerns about fairness.
Mayor Arndt noted there are issues that arise regarding the ability to serve with write-in
candidates as well.
City Clerk Coldiron stated staff will bring forth language at the next meeting.
City Clerk Coldiron outlined the current redistricting requirements and stated adjustments could
be made that would no longer require redistricting automatically based on the County re -
precincting every other year, which may no longer be occurring. Members discussed placing this
item on hold as other issues are more im portant.
City Attorney Daggett stated there is a Code provision that requires petition circulators to read
the entire petition if asked to do so by a petition signer and asked the Committee if they would
like to look at changing or eliminating that provision.
Mayor Arndt stated the provision was not enforced, but stated she would like to ensure petition
circulators have the petition with them for signers to read if desired.
Members discussed the length of the Land Use Code petition.
Councilmember Potyondy stated some type of material should be available and suggested an
approved summary as a possibility. City Attorney Daggett noted part of the question on the ballot
regarding the initiative and referendum processes wou ld call for a summary to be written by the
City that accurately and succinctly summarizes the measure.
Councilmember Potyondy suggested petition circulators should have the full petition available
and be required to present an approved summary.
Councilmember Pignataro requested staff provide information as to the common length of
petitions and stated any unenforced provision should be removed. City Attorney Daggett stated
many initiatives are five or six pages long.
Councilmember Pignataro requested data to back up any possible changes.
Members opted to continue to discuss the matter at the next meeting.
City Clerk Coldiron noted the Committee will need to examine Code language changes that may
be necessary if any of the ballot measures pass.
City Clerk Coldiron reported on a trip to Boulder to learn about ranked choice voting and stated
a staff project team will be dedicated to work on the effort. She reviewed the education and
communication offered by Boulder staff regarding ranked choice voting. Additionally, she stated
staff will be meeting with Larimer County in December to begin those efforts.
4. Discussion of Issues Related to the Proposed Charter Amendments.
Mayor Arndt stated the intent of one of the Charter amendments was to remove the cure period
and approve an extended signature period, and that amendment was not processed in the
- Page 6 -
Section E, Item 1.
City of Fort Collins Page 4
Council materials and came back under the Consent Agenda. She stated it was not Council’s
intent to reduce the amount of time people have to collect signatures to get an item on the ballot.
If the item passes, Council will need to make some revisions to get the item before voters as it
was intended.
City Clerk Coldiron apologized for the error and discussed the way in which notice has been
provided. She noted that Charter review efforts are underway and the correction could be placed
with those on the 2025 ballot.
G. OTHER BUSINESS
None.
H. ADJOURNMENT
The meeting was adjourned by unanimous consent at 5:27 p.m.
- Page 7 -
Section E, Item 1.
Council Committee Agenda Item Summary – City of Fort Collins Page 1 of 1
December 10, 2024
AGENDA ITEM SUMMARY
Election Code Committee
STAFF
Sara Arfmann, Legal
Delynn Coldiron, City Clerk
Carrie Daggett, Legal
SUBJECT
Revised Potential Code Changes Regarding the Campaign Complaint Process and the Campaign
Contribution Limits.
EXECUTIVE SUMMARY
During the October 21, 2024 meeting of the Election Code Committee (ECC), staff presented drafted code
changes for Sections 7-145 and 7-135. Members of the ECC provided valuable input and requested edits
to both sections. Staff has provided a revised draft of the proposed changes.
BACKGROUND / DISCUSSION
During the last ECC meeting, drafted changes were presented for both Sections 7-145 (campaign
complaint process) and 7-135 (contribution limits) and staff received feedback regarding additional
changes and clarifications from the Committee and a community member. The majority of the changes
made to Section 7-145 reflect the wish to make the steps for the complaint process clearer and more
approachable. A subsection was added outlining the complaint process itself and headings were added to
help with navigating the lengthy section. The timeline for the City Clerk to conduct the preliminary review,
3 days, was clarified, as well as that any dismissal notifications contain the reason for the dismissal.
Section 7-135 includes the requested updated contribution limits. The campaign limits in subsection (a)(1)
were updated to state the limit related to the office of the Mayor was increased from $100 to $200, and the
limit related to the office of Councilmember was increased from $75 to $150. Additionally, there were
clarifications regarding the process for accepting electronic donations/payments, third-party transaction
fees charged by an intermediary service, and changing the timing for remitting any contribution is in excess
of the limits. Finally, a subsection addressing cryptocurrency was added.
ATTACHMENTS
1. Revised proposed Code language for campaign complaint process
2. Revised proposed Code language for contribution limits
3. Presentation
- Page 8 -
Section F, Item 2.
Sec. 7-135. - Campaign contributions/expenditures.
a) Limits.
1) No person may make contributions and/or contributions in kind totaling more than
one two hundred dollars ($2100.) to the candidate committee of any candidate
for the office of Mayor. No person may make contributions and/or contributions in
kind totaling more than seventy-five one hundred and fifty dollars ($75$150.) to
the candidate committee of any candidate for the office of Councilmember. These
limitations shall apply to all contributions or contributions in kind, whether made
directly to a candidate committee or indirectly via earmarked gifts passed through
an intermediary, except that these limitations shall not apply to:
a. Contributions or contributions in kind made by a candidate to his or her
own candidate committee;
b. Independent expenditures;
c. Monetary loans that are: (a) personally guaranteed in writing by the
candidate, the candidate's immediate family or a business entity in
which the candidate owns at least five (5) percent; or (b) secured by
real or personal property owned by the candidate, the candidate's
immediate family or a business entity in which the candidate owns at
least five (5) percent; or
d. Contributions made to a candidate committee by another candidate
committee established by the same individual as a candidate for the
office of Mayor or Councilmember.
2) No person may make contributions and/or contributions in kind totaling more than
one hundred dollars ($100.) to a political committee.
3) No person shall make a contribution or contribution in kind in the name of
another person or knowingly permit one's name to be used by another person to
effect such a contribution or contribution in kind.
4) Inflation Adjustment. The City Clerk will adjust the limit set forth in this Subsection
(1) of this section based upon the percentage change over a two-year period in
the United States Bureau of Labor Statistics Consumer Price Index Denver-
Boulder-Greeley, all urban consumers, or its successor index, rounded to the
nearest ten ($10) dollars. The first adjustment will be done in the first quarter of
2027 and then every two years thereafter.
b) Limited Liability Company Contributions. A limited liability company ("LLC") may make
contributions or contributions in kind to candidate committees or political committees
subject to the following requirements and all other applicable limits of this Section:
1) Any contribution from an LLC shall count against contribution limits for both the
LLC itself and the individual members of the LLC as apportioned according. The
amount a person contributes as an individual member of the LLC shall count
towards the aggregate contribution limit for that person in Subsection (a) herein.
2) The LLC shall provide the candidate committee or political committee with a
written statement affirming the permissibility of the contribution on a form
provided by the City Clerk. The affirmation shall include:
a. The name and address of the LLC and each LLC member;
b. Information on how the contribution is attributed among the LLC
members, which attribution must reflect the capital each member has
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Section F, Item 2.
invested in the LLC relative to the total amount of capital invested in the
company, or the percentage of ownership each member has in the LLC
as of the date of the contribution.
3) No candidate committee or political committee shall accept a contribution from an
LLC unless the LLC provides the written affirmation in compliance with this
Section before the contribution is deposited by the committee.
4) The candidate committee or political committee receiving the contribution shall:
a. List both the individual LLC members' names and the name of the LLC
as contributors on disclosure reports; and
b. Retain the affirmation statements for one (1) year after the date of the
election; provider however, in the event a complaint is filed against the
committee, the committee must maintain the affirmations until the final
disposition of the complaint.
5) As used in this Subsection (b), "limited liability company" shall have the same
meaning as "domestic limited liability company" as defined in Section 7-90-
102(15), C.R.S., or "foreign limited liability company" as defined in Section 7-90-
102(24), C.R.S., as amended.
c) Joint contributions. No person shall make a contribution jointly with another person
through an electronic payment or the issuance of a check drawn on a jointly owned
account unless: (i) the total amount of the joint contribution is less than the maximum
amount that can be contributed by one (1) person under the contribution limits
established in Subsection (a) of this Section or (ii) the check is signed by all owners of
the account or the electronic donation or other documentation provided by the
contributor states it is from both, in which event the amount of the total contribution shall
be allocated equally among all such persons unless a different allocation is specified on
the face of the check or on a document provided by the contributor. No candidate
committee shall knowingly accept a contribution made in violation of this Subsection (c).
d) Contributions in excess of limits. No later than ten (10) business days after receiving
Upon receipt of a contribution or contribution in kind in excess of the limits set forth in
this Section, the committee that received the contribution shall remit the excess to the
contributor or pay to the contributor the value of the contribution in kind before the next
filing deadline.
e) Electronic contributions. A contribution made by credit card, PayPal, or other payment
intermediary service is accepted on the date the contributor authorizes the payment, or if
unknown, on the date the payment intermediary service electronically transfers the
contribution.
f) Third-Party transaction fees. If a third-party transaction fee is charged by an intermediary
service, only the amount the committee receives is attributable to the committee.
g) No candidate committee, issue committee, small-scale issue committee or political
committee shall knowingly accept contributions or contributions in kind from any person
who is not a citizen of the United States, from a foreign government or from any foreign
corporation that does not have authority to transact business in this State pursuant to
Article 115 of Title 7, C.R.S., or who is prohibited from contributing pursuant to the
Charter of the City of Fort Collins or this Article.
h) No issue committee, small-scale issue committee or political committee shall make a
contribution or contribution in kind to any other committee or to any candidate.
i) Contributions from one (1) candidate committee to another.
- Page 10 -
Section F, Item 2.
1) No candidate committee shall make a contribution or contribution in kind to, or
accept a contribution or contribution in kind from, a candidate committee of
another candidate.
2) No candidate committee shall accept a contribution or contribution in kind from a
candidate committee of the same candidate that was established or maintained
for a federal, state or county election campaign or office.
j) Recordkeeping.
1) All contributions and contributions in kind received by a candidate committee,
small-scale issue committee, issue committee or political committee shall be
documented and deposited and maintained in a financial institution in a separate
account that complies with Subsection 7-134(a)(7). Following any election in
which the committee received contributions, the committee shall maintain all
records pertaining to contributions and related accounts for one (1) year following
the date the final disclosure report is due under Section 7-136 or the date the
committee terminates, whichever is later, unless a complaint has been filed under
Subsection 7-145(a) alleging a violation of the provisions of this Article, or the
person or committee has received notice of an investigation or prosecution of a
violation of this Article by the City or other law enforcement authority, in which
case they shall be maintained until final disposition of the complaint and any
consequent court proceedings. Such records shall be subject to inspection in
connection with any investigation or other action to enforce the terms of this
Article.
2) Following any election in which the committee made any expenditure, the
committee shall document all expenditures and shall maintain all records
pertaining to said expenditures, including but not limited to invoices, receipts,
instruments of payment, and copies of any public communications produced as a
result of the expenditure, for one (1) year following the date the final disclosure
report is due under Section 7-136 or the date the committee terminates,
whichever is later, unless a complaint has been filed under Subsection 7-145(a)
alleging a violation of the provisions of this Article, or the person or committee
has received notice of an investigation or prosecution of a violation of this Article
by the City or other law enforcement authority, in which case they shall be
maintained until final disposition of the complaint and any consequent court
proceedings. Documentation shall include the name and address of the
vendor(s) or payee(s) providing the property, materials, or services and the
amount of the expenditure. Such records shall be made available within three (3)
business days upon request of the City and subject to inspection in connection
with any investigation or other action to enforce the terms of this Article.
k) Reimbursements prohibited. No person shall make a contribution or contribution in kind
to a candidate committee, issue committee, small-scale issue committee or political
committee with the expectation that some or all of the amounts of such contribution will
be reimbursed by another person. No person shall be reimbursed for a contribution or
contribution in kind made to any candidate committee, issue committee, small-scale
issue committee or political committee, nor shall any person make such reimbursement.
An unexpended campaign contribution returned to a contributor or compensation for a
contribution in kind by a committee pursuant to § 7-135(c) shall not be considered a
reimbursement.
- Page 11 -
Section F, Item 2.
l) A candidate committee, issue committee, small-scale issue committee or political
committee shall not coordinate its expenditures or activities with, or share information
with, any other committee and shall not conduct its campaign activities in a manner that
has the effect of circumventing any restrictions or limitations on campaign contributions,
expenditures or reporting set forth in this Article.
m) A candidate, candidate committee or political committee shall obtain from each seller a
certification of full fair market value for any purchased goods or services and from the
contributor for any goods or services that constitute a contribution or contribution in kind.
Any seller or contributor asked to provide a certification of value shall provide to the
candidate, candidate committee or political committee a correct and undiscounted
statement of value. Certification of value documentation shall be provided by a
candidate, candidate committee or political committee to the City Clerk, or other
appropriate City official responsible for investigating or reviewing compliance, upon
request.
n) No candidate committee, issue committee, small-scale issue committee or political
committee may accept contributions made in cryptocurrency. Any such contributions
received must be returned immediately upon the committee becoming aware of it.
- Page 12 -
Section F, Item 2.
Sec. 7-145. - Allegation of campaign violation.
a) Filing a Complaint: Any candidate or registered elector of the City ("complainant") who
has reasonable, good faith belief, based on factual information, that any person,
candidate, candidate committee, issue committee, small-scale committee, or political
committee has violated Chapter 7, Article V, of this Code may file a written complaint
with the City Clerk, no later than sixty (60) days after the date of the alleged violation.
1) The complaint must contain:
a. The name of the alleged violator;
b. The Code provision allegedly violated;
c. A brief statement or description of the offense allegedly committed and
the basis for the allegation;
d. All documentation or other factual evidence known to the complainant to
support the allegation;
e. Identification of any witnesses or persons with relevant knowledge; and
f. The name, address and telephone number of the complainant.
b) Complaint Process: All complaints filed under this section will be reviewed in the
following manner, however if a complaint is dismissed at any stage it will end at that
stage and will not proceed to the next:
1) Preliminary Review for Sufficiency;
2) Separation of Criminal Complaints from Civil Infractions, only Civil Infractions
proceed to the next stage;
3) Review for Credible Evidence;
4) Investigation; and
5) Referral to Municipal Court.
c) Preliminary Review for Sufficiency: The City Clerk, in consultation with the City
Attorney, will conduct a preliminary review to determine whether the complaint is
sufficient and notify both the complainant and respondent within three (3) working days
of receipt of the complaint. A sufficient complaint must comply with the following:
1) Was timely filed under § 7-145(a);
2) Contains the information required by § 7-145(a)(1); and
3) Properly alleges a violation of Chapter 7, Article V, of this Code.
d) Insufficient Complaints: If the City Clerk, in consultation with the City Attorney,
determines that the complaint is insufficient, the City Clerk will:
1) Notify the complainant that the complaint has been dismissed and provide a brief
explanation of the determination; and
2) Forward the complaint to the person who is the subject to the complaint
(“respondent”) and notify them that the complaint has been dismissed.
e) Conflict: If the respondent to a sufficient complaint is a candidate for an elected position
for municipal office or if the City Clerk, in consultation with the City Attorney, determines
internal review of a sufficient complaint may raise conflict concerns, the City Attorney will
retain special legal counsel to conduct the evaluation of the complaint using the process
described below.
f) Criminal Complaints: If the City Clerk, in consultation with the City Attorney, determines
that the complaint is sufficient and alleges a criminal violation as set forth in § 7-143(b),
the City Clerk will forward the complaint to the respondent and to the City Attorney, who
will evaluate the complaint for probable cause as provided for in this Division 2.
- Page 13 -
Section F, Item 2.
g) Civil Infractions: For sufficient complaints that do not allege a criminal violation, the
complaints will be subject to a civil infraction process as follows:
1) The City Clerk will forward the complaint to the respondent by electronic mail,
notifying the respondent that the alleged violation may be subject to a civil
infraction and of the presumptive fine in accordance with § 7-143(a).
2) Upon receipt of the complaint and at any time prior to filing of the complaint with
Municipal Court, the respondent may:
a. Pay the fine; or
b. Provide any responsive information to the City Clerk regarding the
allegations in the complaint.
3) Review for Credible Evidence: After providing notice to the respondent of the
complaint, the City Clerk, in consultation with the City Attorney, will determine
whether the complainant has provided credible evidence to support a finding that
the respondent violated this Article so as to warrant further investigation. If the
City Clerk determines that the complaint does not contain credible evidence or
that the allegation does not warrant further investigation, the Clerk will dismiss
the complaint and notify both the respondent and the complainant of the
dismissal and the reason for the dismissal.
4) Cure: Upon receipt of the complaint up until the initiation of an investigation, the
respondent may provide evidence of a cure. A “cure” is defined to include
evidence of substantial compliance with the applicable law. Upon receipt of
evidence of a cure, the City Clerk, in consultation with the City Attorney, will
determine whether the provided evidence sufficiently cures the violation. If a cure
is found, the City Clerk will dismiss the complaint. The City Clerk will notify both
the respondent and the complainant. When reviewing the evidence, the City
Clerk, in consultation with the City Attorney, will consider the following:
a. The extent of the respondent's noncompliance;
b. The purpose of the provision violated and whether that purpose was
substantially achieved despite the noncompliance; and
c. Whether the noncompliance may properly be viewed as a knowing
attempt to mislead the electorate or election officials.
5) Investigation: If the City Clerk, in consultation with the City Attorney, determines
that the complaint contains credible evidence and warrants further investigation,
the City Attorney will arrange for any necessary outside or internal investigators
to assist in conducting an investigation. The City Clerk will notify the respondent
and complainant that an investigation has begun, that they may be contacted for
an interview or other information gathering. Any additional information that either
the respondent or complainant wants to provide must be received by the City
Clerk within ten (10) business days. Documentation must be received within the
ten (10) working days in order to be considered during the investigation.
6) Payment of Civil Fine: Upon receiving payment of the presumptive fine, the City
Clerk will close the complaint and notify the respondent and complainant.
7) Based on the outcome of the investigation the City Clerk, in consultation with the
City Attorney, will determine whether a violation under Chapter 7, Article 5, of this
Code occurred.
8) If it is determined that a violation did occur, the complaint will be filed with the
Municipal Court. If the City Clerk, in consultation with the City Attorney,
- Page 14 -
Section F, Item 2.
determines that a violation under Chapter 7, Article 5 did not occur, the City Clerk
will dismiss the complaint and notify the complainant and respondent of the
dismissal and the reason for the dismissal.
9) Referral to Municipal Court: Any complaint filed with the Municipal Court under
this Section will be governed by Article V of Chapter 19 of this Code.
10) A complainant or any other nonrespondent will not be a party to the City
Attorney's initial review, cure proceedings, investigation, or any proceeding in the
Municipal Court. A complainant may request permission from the Municipal
Judge or their designee to file an amicus curiae brief.
11) Any person that commits a violation of this Article will be personally liable for the
penalties imposed. Any candidate will be personally liable for penalties imposed
upon the candidate or the candidate's committee and may use campaign
contributions to pay penalties.
- Page 15 -
Section F, Item 2.
Headline Copy Goes Here
Assistant City Attorney II
Sara Arfmann
Revised Proposed
Changes to the
Campaign
Complaint Process
&
Contribution Limits
Dec 2024
- Page 16 -
Section F, Item 2.
Headline Copy Goes Here
2
Overview of Changes –Campaign Violations
•Staff listened to the requested changes from the Committee and reviewed submitted edits from the
community
•A new subsection (b) was added that outlines the stages of a complaint:
Complaint Process: All complaints filed under this section will be reviewed in the following manner,
however if a complaint is dismissed at any stage it will end at that stage and will not proceed to the next:
1)Preliminary Review;
2)Separation of Criminal Complaints from Civil Infractions, only Civil Infractions proceed to the next stage;
3)Evidentiary Review;
4)Investigation; and
5)Referral to Municipal Court.
•Headings were added to assist in navigating the lengthy section
•Clearly states that when a complaint is dismissed the reasoning for the dismissal will be included in the
required notifications
- Page 17 -
Section F, Item 2.
Headline Copy Goes Here
3
Overview of Changes –Contribution Limits
•Updated contribution limits:
•Mayor: $100 -$200
•Councilmember: $75 -$150
•Added clarifications regarding electronic donations/payments, including a new subsection:
Electronic contributions. A contribution made by credit card, PayPal, or other payment intermediary service
is accepted on the date the contributor authorizes the payment, or if unknown, on the date the payment
intermediary service electronically transfers the contribution.
•Added a new subsection addressing third-party transaction fees:
Third-Party transaction fees. If a third-party transaction fee is charged by an intermediary service, only the
amount the committee receives is attributable to the committee.
•Added a new subsection addressing cryptocurrency:
No candidate committee, issue committee, small-scale issue committee or political committee may accept
contributions made in cryptocurrency. Any such contributions received must be returned immediately upon
the committee becoming aware of it.
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Section F, Item 2.
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Questions?
4
- Page 19 -
Section F, Item 2.
Council Committee Agenda Item Summary – City of Fort Collins Page 1 of 2
December 10, 2024
AGENDA ITEM SUMMARY
Election Code Committee
STAFF
Cecilia Good, Senior Deputy City Clerk
SUBJECT
Enforcement of Local Campaign Regulations
EXECUTIVE SUMMARY
The Election Code Committee requested that staff research examples of an independent process for
campaign compliance oversight, to support a Committee discussion of ways to reduce reliance on citizen
complaints for enforcement.
BACKGROUND / DISCUSSION
Proactive Oversight and Enforcement
In discussion, the Committee has expressed concern about the existing campaign finance oversight
mechanism and the extent to which it relies on members of the public identifying alleged violations and
filing complaints to initiate review. The Committee has expressed interest in exploring ways to increase
proactive oversight to reduce the dependence on private complaints for enforcement. Currently, the City
Clerk's office performs only basic verification of submission timing and balance matching. Limited
resources are available for candidate education and public inquiry response. In addition, reliance on City
staff to review campaign submittals and compliance for candidates can put staff in a difficult position and
potentially creates at least an appearance of a conflict of interest.
Staff has evaluated ways to address these limitations and recommends that the City contract with an
outside service provider to independently carry out increased monitoring, review, oversight and
investigation of campaign activities, including:
Regular review of campaign finance submissions
Investigation of potential violations
Response to public inquiries
Documentation of complaint resolutions
The third-party reviewer would carry out the steps necessary to inform committees and others involved in
campaign activities of observed violations, work with them to facilitate cure of violations and work with a
prosecutor (a special prosecutor in the case of a candidate issue) to take enforcement action for uncured
violations.
Funds have not been allocated to this function and further assessment and estimation of the costs for an
outside reviewer are needed.
- Page 20 -
Section F, Item 3.
Council Committee Agenda Item Summary – City of Fort Collins Page 2 of 2
During our review of comparable Colorado cities, two municipalities reported using specialized software for
campaign finance submission to streamline the process and increase transparency. While this represents
a potential operational improvement, it does not address the fundamental oversight needs identified.
However, if the Committee is interested in further exploration of this as an avenue for improvement, staff
can develop estimates and additional information about technology options.
Independent Bodies for Oversight
The Committee and public commenters have inquired about what models other local governments use to
provide oversight of election activities by an independent appointed body. While we were unable to identify
many bodies of this sort, we did identify two local government jurisdictions with established oversight
processes: Santa Fe, New Mexico, and Alameda County, California.
Santa Fe has implemented an Ethics and Campaign Review Board that provides comprehensive oversight
of campaign finance matters as well as ethics matters. We do not have any feedback at this time about the
effectiveness of the Board and the impact it has had. We have learned that in addition to independent
review authority, the Board receives and investigates complaints, carries out regular audits and provides
educational resources for candidates and committees.
Alameda County maintains an Elections Commission that provides systematic review of campaign finance
reports, compliance monitoring and enforcement. Again, we do not have feedback related to the efficacy
of this body compared to a professional staff-driven model.
CITY FINANCIAL IMPACTS
Staff has not assessed the cost associated with resourcing an outside reviewer/investigator model. Funds
are not currently provided for that function, and additional appropriation would be required. Similarly, the
costs associated with forming and staffing an independent commission or board for oversight of campaign
compliance have not been determined.
PUBLIC OUTREACH
The League of Women Voters was consulted for the research of this topic.
ATTACHMENTS
1. Presentation
- Page 21 -
Section F, Item 3.
Headline Copy Goes Here
Cecilia Good,
Senior Deputy City Clerk
Campaign Finance
Research
December 10, 2024
1
- Page 22 -
Section F, Item 3.
Headline Copy Goes HereELECTION CODE COMMITTEE DIRECTIVE
•The Election Code Committee requested that staff
research examples of an independent process for
campaign compliance oversight
•Staff contacted municipalities across Colorado and
found two examples outside of the state
- Page 23 -
Section F, Item 3.
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3
CURRENT STATE
•The City Clerk's Office performs basic verification of
submission timing and balance matching
•Limited resources are available for candidate education and
public inquiry response
•Reliance on City staff to review campaign submittals and
compliance for candidates can create an appearance of a
conflict of interest
- Page 24 -
Section F, Item 3.
Headline Copy Goes HereINDEPENDENT CONTRACTOR OPTION
Staff evaluated ways to address these limitations and recommends the City contract
with an outside service provider for increased monitoring,review,oversight and
investigation of campaign activities, including:
•Regular review of campaign finance submissions
•Investigation of potential violations
•Response to public inquiries
•Documentation of complaint resolutions
•Inform committees and others involved in campaign activities of observed violations
•Facilitate cure of violations
•Work with a special prosecutor to take enforcement action for uncured violations
Funds have not been allocated to this function and further assessment and
estimation of the costs for an outside reviewer are needed.
- Page 25 -
Section F, Item 3.
Headline Copy Goes HereTECHNOLOGY IMPROVEMENTS
•Two Colorado municipalities reported using specialized software for campaign
finance submission to streamline the process and increase transparency
•This represents a potential operational improvement in receiving financial
information from candidates
•It does not address the fundamental oversight needs identified
If the Committee is interested in further exploration of this as an avenue for
improvement, staff can develop estimates and additional information about
technology options.
- Page 26 -
Section F, Item 3.
Headline Copy Goes HereINDEPENDENT BODIES FOR OVERSIGHT
•Staff identified two local government jurisdictions with established oversight
bodies: Santa Fe, New Mexico, and Alameda County, California.
•Santa Fe, New Mexico
•Implemented an Ethics and Campaign Review Board that provides
comprehensive oversight of campaign finance and ethics matters
•The Board receives and investigates complaints, carries out regular audits and
provides educational resources for candidates and committees
•Alameda County, California
•Has an Elections Commission that provides systematic review of campaign
finance reports, compliance monitoring and enforcement
Staff does not have feedback related to the efficacy of these bodies compared to
a professional staff-driven model.
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Section F, Item 3.
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QUESTIONS?
- Page 28 -
Section F, Item 3.
Council Committee Agenda Item Summary – City of Fort Collins Page 1 of 3
December 10, 2024
AGENDA ITEM SUMMARY
Election Code Committee
STAFF
Delynn Coldiron, City Clerk
Rupa Venkatesh, Assistant City Manager
Carrie Daggett, City Attorney
Sara Arfman, Assistant City Attorney
SUBJECT
2024 Workplan Check-In and Election and Ranked Choice Voting Updates
EXECUTIVE SUMMARY
The purpose of this item is to provide updates on the Committee’s Work Plan and to enable discussion on
Work Plan items. The purpose also includes providing updates on the 2024 election and ranked choice
voting efforts.
At its October 21, 2024, meeting, the Committee reviewed the remaining items on the Work Plan and Code
amendments related to campaign finance enforcement and contribution limits. Changes have been made
based on the discussion from that meeting and will be presented at the December 10 meeting. Discussion
is also planned on possible options related to additional campaign oversight.
Discussion on possible additional Charter amendments will likely be included as part of the Charter
review project that is currently underway.
GENERAL DIRECTION SOUGHT AND SPECIFIC QUESTIONS TO BE ANSWERED
1. Does this meet the Committee’s expectations regarding these items?
2. Are there any additional items the Committee is interested in pursuing for this election term?
BACKGROUND / DISCUSSION
For the January 27, 2025, meeting, staff will be prepared to discuss:
Draft code changes that would eliminate write-in candidates;
Draft code changes that would eliminate having petition circulators read an entire petition if requested;
Draft code changes that would enable the City to use the Secretary of State’s rules related to ranked
choice voting for any special elections that are not coordinated with the County; and
Draft code changes that are needed based on the Charter changes that passed.
- Page 29 -
Section F, Item 4.
Council Committee Agenda Item Summary – City of Fort Collins Page 2 of 3
Code changes agreed to at the December meeting, together with a summary of items the Committee
approved at the October meeting, will be reviewed at the January 27, 2025, ECC meeting. Approved items
will then be prepared for Council consideration. If no work session is needed, the items could be brought
forward for first reading as early as February 18, followed by second reading on March 4, 2025. An earlier
meeting in January could be scheduled if the Committee desires to do so.
Additional items remaining on the Committee’s Work Plan include:
1. Education for Ranked Choice Voting and Sign Code requirements
2. Additional Code Amendments
a. Redistricting.
3. Other Topics: “Bike Rack” Items:
b. Public Financing of Campaigns
Staff will provide updates on remaining items as information is available.
Election Update:
Related to the 2024 Election:
Larimer County has certified final election results, and the report has been filed with the State
Department of Legal Affairs (DOLA) as required;
The cost of the election was estimated to be $164,337.27. We expect to receive the finalized cost by
December 6 and can report out on this at the December 10 meeting.
Candidate information for the 2025 election is being received. Here is what we have so far:
Mayor: No Candidates
District 1: Nick Armstrong (needs to provide updated information) and Christopher Bramhall-Conway
District 3: No Candidates
District 5: Amy Hoeven
Staff is working on finalizing Candidate Guidelines and other materials for the 2025 election. We are
expecting to schedule a Candidate Information Session towards the end of Q1 which will include some
information about the new ranked choice voting process.
Ranked Choice Voting Efforts
A core staff team has been established that includes members from the City Clerk, City Attorney and
Communications teams. Many efforts are underway including developing a communications/outreach plan
and associated timelines, working on branding, website and material development, event planning, etc.
Collaboration with CSU (ASCSU and Strayer Center) is already underway. The team plans to reach out to
Poudre School District and Front Range Community College as well to determine how best to reach their
students.
Collaboration with Larimer County is underway with a kick-off meeting scheduled for Friday, December 13.
Collaboration with the League of Women voters is planned.
Outreach is expected to start during Q1 2025. We are expecting to take a “bite, snack, meal” approach to
this, similar to what the City of Boulder did.
- Page 30 -
Section F, Item 4.
Council Committee Agenda Item Summary – City of Fort Collins Page 3 of 3
Bite – social media posts, early website development, postcard creation, Coloradoan information;
Snack – Candidate Information Session, postcard mailing, utility bill stuffer, continued social media
posts, added information on the website, development of slides and a video;
Meal – Full flyer mailing, cable TV information, QR code that links to a ballot for practice, fully built out
website, events, mock elections, elections blue book.
We expect to have all items except for the elections blue book developed and ready to go by the
Summer of 2025, prior to attending events.
Events we have identified include:
State of the City (postcard developed and available)
Candidate Information and Orientation Sessions (postcard and video developed and available)
Open Streets
Lagoon Series
Farmer’s Markets
Library (when they have other events planned)
Super-Issue meetings
CSU events
Senior Center Outreach
Town Hall and/or similar meetings
League of Women Voter and County events
Other events will be added as wanted/needed.
The election blue book is expected to be developed in the August/September timeframe. It is unknown at
this time whether this will solely be an online resource or mailed to registered households. It is expected
that a full mailing for something like this would cost approximately $85K. Alternatively, a link to the online
version could be included on the last flyer that is mailed and perhaps on the voter instructions that go out
with ballots.
We plan to collaborate with the City’s Equity Office and the League of Women Voters to ensure effective
outreach and training to underserved populations within the community. There are a lot of great ideas
being generated in this space that we plan to explore. All ranked choice voting materials will be available
in English and Spanish.
Staff will continue to keep the Committee and Council apprised of related efforts.
ATTACHMENTS
1. Presentation
- Page 31 -
Section F, Item 4.
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City Clerk
Delynn Coldiron
2024 Work Plan
Check-In and
Election and
Ranked Choice
Voting Updates
Dec 2024
- Page 32 -
Section F, Item 4.
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2
Committee Priorities
Discussed Today
Campaign Finance Enforcement
and Contribution Limit Code
Changes
Campaign Oversight Options
Code Changes (Jan 27)
Eliminate Write-In Candidates
RCV
Charter Changes –Circulation
Period
Reading Petitions
Education Efforts
Ranked Choice Voting
(update today)
Additional Code
Amendments
Redistricting
Other?
Other Topics –“Bike
Rack”
Public Financing of
Campaigns
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Section F, Item 4.
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Code Changes –Campaign Enforcement and Contribution Limits
Campaign Enforcement:
•Reviewed code language today.
•Will make changes based on today’s discussion.
•Will prepare information for Council consideration in February.
Contribution Limits:
•Reviewed proposed code language.
•Will make changes based on today's discussion.
•Will prepare information for Council consideration in February
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Section F, Item 4.
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Campaign Oversight
Outside Service Provider:
•Contracted to provide increased proactive review
•Regular review of campaign finance submissions
•Investigation of potential violations
•Response to public inquiries
•Documentation of complaint resolutions
Independent Bodies:
•Santa Fe, NM –Ethics & Campaign Review Board
•Alameda County, CA –Elections Commission
Other:
•Specialized software/technology enhancements - Page 35 -
Section F, Item 4.
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5
Coming Code Changes –Eliminate Write in Candidates
Section 7-103 –Write-in candidates:
•Currently allowed if the candidate has filed an affidavit of intent with the City Clerk.
•The affidavit must be filed no later than the 64th day prior to the election.
•The affidavit must indicate that the person desires and is qualified for the office.
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Coming Code/Charter Changes
Charter Changes:
•Circulation period related to initiatives –77 days
•Will be its own ballot question
•Other Code changes needed based on the Charter Amendments that
passed
RCV
•Add provisions to Code for conducting an RCV special elections
Recommend following SOS rules
Petition Circulation:
•Eliminate the provision that circulators have to read a petition when
requested to do so
Getty Images
New Jersey State Bar
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Section F, Item 4.
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Additional Charter Amendments and Other Topics
•Redistricting
•Other?
Additional
Code
Amendments
•Public Financing
of CampaignsOther Topics
- Page 38 -
Section F, Item 4.
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Election Update
Election has been certified by the County
Election report has been sent to DOLA
Election Cost: Estimated at $164K
Website is being updated for 2025 Effort
RCV will have its own page
Receiving candidate information already!
Mayor, District 1 (2 Candidates), District 3, District
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Section F, Item 4.
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Ranked Choice Voting Update
•Core Team has been identified and is meeting
(City Clerk, City Attorney and CPIO staff)
•Collaboration with CSU and the County is underway
(Meeting scheduled with the County on December 13)
•Collaboration with League of Women Voters planned
•Website pages are being updated and prepared
•Communication Plan is being developed
•Q1 –will start outreach (Bite, Snack, Meal approach)
•Bite –social media, website, postcard, Coloradoan
information
•Snack –Candidate Information Session, postcard
mailing, utility bill stuffer, continued social media
posts, added information on website, slides, video
•Meal –Full flyer mailing, cable tv information, QR
code that links to a ballot for practice, fully built out
website, events, mock elections, elections blue book
League of Women Voters
- Page 40 -
Section F, Item 4.
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Ranked Choice Voting Update
•Video and postcard will be available at Candidate
Information Session
•Events
•State of the City
•Candidate Information and Orientation Sessions
•Open Streets
•Lagoon Series
•Farmer’s markets
•Library (when they have events planned)
•Super-Issue meetings
•Collaboration with League of Women Voters
•CSU events (ASCSU, Strayer Center)
•Senior Center Outreach
•Collaboration with the Equity Office and related
events
Better Ballot North Carolina
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Section F, Item 4.
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Questions?
11
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Section F, Item 4.