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“Anti-Corruption” Councilmember David Ryu Can’t Stop Breaking Campaign Finance Laws

In the midst of a close reelection race against a progressive challenger, it looks like Ryu broke the law. A lot.

Los Angeles CD 4 Councilmember David Ryu (Source: Flickr)

Councilmember David Ryu talks a good talk.

His campaign site is full of photos of him marching at protests, helping deliver groceries, and somberly adding his contribution to a BLM mural outside the Laugh Factory in West Hollywood. He even links to his Flickr account, so you can see an entire photostream of how good and progressive he is.

It’s not just his campaign site painting Ryu as forward-thinking and action-oriented, though. The Councilmember’s Annual Report, along with anonymously authored campaign updates and profiles in local publications, also showcase Ryu’s apparently boundless goodwill.

One of the many photos on Councilmember Ryu’s Flickr showing him in performative activist mode.

This media outreach isn’t unusual for a City Councilmember running for reelection, especially in this tight of a race (he won just under 45 percent of the vote in the primary while his challenger, Nithya Raman, won 41 percent despite Ryu raising over three times as much money). What is strange about Councilmember Ryu’s campaign tactics, however, is how they’ve been funded.

KNOCK.LA received a detailed analysis of Ryu’s Officeholder Committee expenses from a concerned Angeleno who submitted a letter to the Los Angeles Ethics Commission. Their investigation, which is backed by publicly available records and communications, reveals that Councilmember Ryu definitively violated several components of the Campaign Finance Rules as outlined by the Ethics Committee, and potentially broke many more.

David Ryu is Not an Idiot

City Councilmembers David Ryu and Monica Rodriguez at the 2019 Women’s March | Luke Harold

It would be generous to suppose Ryu is unaware of the financial laws of his Officeholder Committee. After all, this isn’t the first campaign finance whoopsie he’s made during his short time at City Hall. In November 2019, challengers criticized Ryu for taking campaign contributions from real estate developers after pledging not to do so. He claimed it was a mistake, and these contributions from developers simply went under his ethical radar.

The councilmember invited “anyone and everybody from the press and the community to help me identify errors,” and returned a dozen or so donations. He followed up to complaints saying that, “[t]here’s no perfect system.”

“What we’re trying to do is probably more comprehensive than what the city is going to do,” Ryu added — a low bar considering Los Angeles City Hall is in the thick of a federal investigation for establishing a bribery ring with real estate developers.

Ryu’s office also did not give back donations from architects, consultants, and other contractors involved in development, citing the fact these donors were not involved with “active projects” or did not “regularly pursue projects” in LA. It is worth noting that while Ryu said some real estate donations slipped through the cracks, he was well-versed enough in campaign finance semantics to argue keeping a majority of the donations.

So, at best, Ryu is incompetent. At worst — and, given his shifty campaign finance track record, the more likely reality — Ryu is purposefully misusing funds from his Officeholder Committee to run his reelection campaign.

A Brief Primer on LA City Council’s Campaign Finance Rules

Officeholder Committees are supposed to follow the Campaign Finance Ordinance outlined by the Ethics Committee. The TL;DR of this ordinance is that Officeholder Committees cannot pay for anything to influence any ballot, measure, candidate, or election.

For readers interested, here is the 50-page Campaign Finance Ordinance. Below are summaries of the rules pertinent to Ryu’s Officeholder Committee transgressions:

1. Most candidates are only allowed to have one type of committee to organize and raise funds for their campaign. These campaign committees have to follow regulations put out by the ethics committee, which include parameters like contribution limits. [L.A. Muni. Cod. § 49.7.19(A)]

2. Officeholders (like city councilmembers) are allowed to create an additional committee, known as an Officeholder Committee. These committees are allowed to use funds for things like office supplies, educational seminars for the elected official, and communication materials for district or city-wide events. In short, if it “pay[s] for expenses that relate to carrying out the duties associated with holding elected City office,” it flies. [L.A. Muni. Cod. § 49.7.19(D)]

3. These Officeholder Committees are also restricted from spending on certain things, namely communications, consulting services, advertisements, or any aspect of a reelection campaign. These funds cannot be used to support or oppose any candidate or ballot measure. [L.A. Muni. Cod. § 49.7.19(E)]

4. Most communications paid for by Officeholder Committees have to be filed with the Ethics Commission, specifically any time they pay for “independent expenditure communication” that goes out to “200 or more persons.” Paid communications that could fall under this umbrella include educational pamphlets, event flyers, or district newsletters. [L.A. Muni. Cod. § 49.7.32(A) and (F)]

5. Any communication paid for by an Officeholder Committee must have a disclaimer stating so. The exact language required is “Paid for by” followed by the name, address, and city of the candidate. This statement should also direct constituents to ethics.lacity.org if they have further questions. [L.A. Muni. Cod. § 49.7.33(A)]

6. Once an officeholder files a Declaration of Intention to Become a candidate, certain previously permitted expenditures are no longer allowed. This includes (but isn’t limited to) most communications that reach over 200 people, advertisements, consulting, multimedia, polling, and testimonials. Ryu officially declared his candidacy on November 7, 2019. [L.A. Muni. Cod. § 49.7.19(I)]

Councilmember Ryu either skimmed over these Officeholder Committee rules or flat-out ignored them. Not only has Ryu neglected to file a number of mass communication tactics to the Ethics Committee, but he has also used funds from his Officeholder Committee — again, the one you AREN’T allowed to use for election and campaign purposes — for election and campaign purposes.

Let us count the ways.

He Used Officeholder Committee Funds for a Reelection Vanity Project

Pages 18–19 of Councilmember Ryu’s 2018–2019 Annual Report

Ryu’s most egregious offense, a 26-page, self-congratulatory Annual Report, is twofold.

First, the 2018–2019 Annual Report, which he neglected to file with the Ethics Committee, violates a host of codes of the Campaign Finance Ordinance. Ryu bent the rules and sent out an unreported mass communication, paid for said communication with prohibited Officeholder Account funds, and published reelection propaganda under the guise of updating the community.

Secondly, this report contains an obnoxious amount of photos of Ryu virtue signaling. The latter also technically falls under the umbrella of code violations, but deserves emphasis due to the sheer number of images.

Ryu filed his Declaration of Intention to Become a Candidate on November 7, 2019. After he filed, he was no longer allowed to use his Officeholder funds for any form of communications to 200 or more people, unless those communications do not contain his name or photograph, with the exception of contact information.

The 2018–2019 Annual Report features 48 pictures of Ryu and mentions his name 21 times.

In December 2019, Ryu self-published the report on his website and on his Facebook. Newspaper Park Labrea News-Beverly Press printed a piece on the report, and included how to access it online. Park Labrea News-Beverly Press and Larchmont Buzz also posted articles online with direct links to Ryu’s report.

Since he sent out his report on five different mass communication mediums, it’s reasonable to assume he thought it would reach over 200 people, which requires filing with the Ethics Committee. Also, we know Ryu is aware of this code, as he submitted his Annual Report to the Ethics Committee in the past.

Ryu Paid for a Quarter-Page Advertisement with his Officeholder Account

In March 2020 — four months after Ryu declared his candidacy — Larchmont Chronicle published a sizable advertisement paid for by Ryu’s Officeholder Committee.

The ad, found on page 44, features his name, his portrait, and the copy, “Proud to represent the people and places of the Miracle Mile.” Ryu punctuates the ad with his signature. The disclaimer at the bottom of the ad says, “Paid for by David Ryu for City Council 2015 Officeholder Account”

Ryu neglected to file this prohibited expenditure with the Ethics Committee.

Ryu May Have Funded Illegal Propaganda

The fourth quarterly statement of Ryu’s Officeholder Account lists expenditures for print ads with Park LaBrea-News/Beverly Press ($1,140), the Jewish Journal ($360), and the Los Angeles/Orange Counties Building and Construction Trades Council PAC ($990). Ryu’s failure to submit these mass communication expenditures to the Ethics Committee is a clear violation of campaign finance law.

But that isn’t the most troubling part of these particular offenses. Even though Ryu claimed that he paid for advertising in the Park Labrea News-Beverly Press with his Officeholder account, the publication didn’t run any ads for Ryu during this time.

They did, however, run a series of uncredited articles with Ryu’s key talking points (which more often than not echo opponent Nithya Raman’s, once said talking points are proven effective) and a direct link to his campaign site:

To be clear, there are no records directly connecting the payments from Ryu’s Officeholder Committee to these campaign articles. Still, we could not find any ads for Ryu published by in the Park Labrea News-Beverly Press during the fourth quarter of 2019.

If Ryu did use his Officeholder funds to pay for this content, it would be yet another violation of the Campaign Finance Ordinance. These types of articles are required to have a political advertising disclaimer, which, as the emerging pattern would suggest, the articles do not.

This isn’t the only instance Ryu made it look like a publication endorsed him. On August 29, 2020, Los Feliz Ledger publisher Allison B. Cohen filed a complaint with the Ethics Committee after Ryu’s campaign sent out an email to 30,000 constituents from the address email hidden; JavaScript is required, but the sender name was “Los Feliz Ledger.” Cohen asked the campaign to issue a correction. Ryu declined.

Ryu Donated Over $11,000 to Democratic Organizations That Later Endorsed Him

This one might take the cake. In October 2019, just a month before officially declaring his intent to run for reelection, Ryu used his Officeholder Account to donate $11,450 to seven Democratic organizations, including the Los Angeles County Democratic Party and the Democratic Party of the San Fernando Valley. He listed all of these expenditures in his fourth quarter statement under Schedule D: Summary of Expenditures Supporting/Opposing Other Candidates, Measures and Committees.

Mayor Eric Garcetti speaking at Councilmember Ryu’s swearing in ceremony, June 2015 | Wikimedia Commons

To recap, it is prohibited to use funds from Officeholder Accounts to support or oppose any candidate, measure, or committee. Ryu lists these expenses under those exact parameters.

Five of the seven of the organizations later endorsed Ryu. Board member Cameron Onumah of the San Fernando Valley Young Democrats also endorsed Ryu post-donations.

Ryu Lists “Voter Data” as an Officeholder Account Expense

In his second quarterly statement of 2020, Ryu’s Officeholder Account lists two payments to Political Data Inc (PDI) totaling $524.95. A quick visit to PDI’s site makes it hard to refute that this is an illicit campaign expenditure. Ryu had already declared his intent to run, which prohibits Officeholder Account payments for “consulting, research, polling” or “similar services.”

And, if any of Ryu’s staff is using this data to conduct voter outreach while on the clock, it would be another strike against Ryu’s campaign, as city officials aren’t allowed to engage in “political activity” while “using a city title or position.”

“City Hall is suffering from a cancer of corruption that must be rooted out.”

Ryu was quick to condemn the actions of fellow grifters when all hell broke loose in City Hall in May 2020. He motioned to establish the Office of Anti-Corruption and Transparency (LA-ACT), saying it is “critical that greater accountability and transparency exist between City officials and developers with land use matters and business interests before the City.” On August 12, City Council passed his motion. (Interestingly enough, two local outlets that reported favorably on this are Larchmont Buzz and Park LaBrea News-Beverly Press.)

Ryu’s right, but he’s not the right person to be saying it. Or the right person to be involved in this type of committee. Or to be a public servant, according to his own words:

“Anyone involved in these shameful schemes has no place in public service and must be held accountable to the fullest extent of the law.”

On this, KNOCK.LA and David Ryu agree.