The FPPC should adopt regulations that clarify whether the analysis in the
McEwen advice letter is intended to apply to the factual circumstances presented in this audit.
In October 2012 the FPPC informed the California State Treasurer that, pursuant to its McEwen advice letter and other advice letters it has issued in the past, the compensation models of the joint powers authorities included in the audit (California Communities and Municipal Finance) do not violate the political reform act. (See 2013-406, p. 32)
Agency responses received after June 2013 are posted verbatim.