City Of Los Angeles Bans Campaign Contributions From Property Owners And Developers With Pending Projects – Real Estate

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On June 8, 2022, new campaign contribution restrictions took
effect in the city of Los Angeles. Enacted as part of Ordinance No.
186477, city law now prohibits property owners and developers with
“significant planning entitlement” applications pending
before the city from making campaign contributions to the Mayor,
City Attorney, City Council, or candidates or controlled committees
for any of these offices. The types of entitlement applications
subject to the ban include general plan amendments, development
agreements, density bonuses, site plan reviews, tentative tract
maps and zone changes.

The contribution restriction runs from the date that the
entitlement application is submitted to the city until 12 months
after the city issues a final determination letter related to the
entitlement or, if no letter is issued, the date the decision on
the application is final. In addition to property owners and
developers, the restriction applies to their
“principals,” including their 20%-plus owners, board
chair, president, CEO, CFO, COO and anyone who serves in the
functional equivalent of one of those positions and anyone
authorized to represent the owner or developer before the city
planning department. Although not evident from the statutory
language, the City Ethics Commission has informally opined that
general board members are also covered. Applicants must notify
owners and principals that they are subject to the ban.

The law further requires entitlement applicants to register with
the City Ethics Commission through the city’s Restricted
Developer Filing System ( This registration
—which is publicly searchable on the commission’s
website (—requires
applicants to disclose owner contact information and the names and
titles of all principals. According to the commission, the
registration requirement applies to every pending project, even if
the entitlement application was submitted prior to June 8,

Penalties for violating the ban can be harsh. In addition to
monetary fines, willful conduct is subject to potential misdemeanor
charges, and those who violate the law are prohibited from
submitting new entitlement applications for 12 months unless there
are mitigating circumstances.

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Mayer Brown article provides information and comments on legal
issues and developments of interest. The foregoing is not a
comprehensive treatment of the subject matter covered and is not
intended to provide legal advice. Readers should seek specific
legal advice before taking any action with respect to the matters
discussed herein.

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