SEI

Form 700 Electronic Filing Solution

Campaign Compass
Response to FPPC Request for Information

CONTACT INFORMATION Campaign Compass 225 Bush Street San Francisco, CA 94107 info@campaigncompass.com (973) 960-5861

RESPONSE TO FPPC REQUEST FOR INFORMATION

Table of Contents
Introduction .......................................................................................................................................................... 3 Our Advantages .................................................................................................................................................... 4 Requirements ........................................................................................................................................................ 5 Security ............................................................................................................................................................... 5 Meets Layered Network Security Guidelines ...................................................................................................... 5 Uses Secured Authentication ..................................................................................................................................... 5 Uses Complex Passwords ............................................................................................................................................. 5 Has Automated Password Recovery System ....................................................................................................... 6 Statement of Economic Interest - Form 700 .......................................................................................... 7 Preface - Configurable Form Builder ...................................................................................................................... 7 User Experience Requirements Covered By the Form Builder ................................................................... 7 Mandatory Fields and Validations ........................................................................................................................... 7 Data Auto-Population (Previous Filing, Assumption of Office, Leaving Office) ................................... 7 Printing and Saving the Form .................................................................................................................................... 7 Blocking Filing Before Filer is Added ..................................................................................................................... 7 Database Management .................................................................................................................................. 8 Preface - MongoDB for Configurability and a CRUD API to Send/Receive Data .................................. 8 Requirements Met By the Above .............................................................................................................................. 8 Certain Notifications are Recorded in Filer History ......................................................................................... 8 Fine Information Fields are Recorded in Filer History ................................................................................... 8 Reports ............................................................................................................................................................... 9 Preface - Analytical Reporting Tool ......................................................................................................................... 9 Requirements Met by the Above .............................................................................................................................. 9 Filing Official Functionality ...................................................................................................................... 10 Filing Official Database Access ............................................................................................................................... 10 Blocking Invalid Filers ................................................................................................................................................ 10 Stop Filings from Being Deleted ............................................................................................................................. 10 Role Management ......................................................................................................................................................... 10 Notifications ................................................................................................................................................... 11 Email Blasts to Filing Officials and Classes of Filers ..................................................................................... 11 Nonfiler, Fine, and Amendment Request Letters to Filers ......................................................................... 11 Fine Management ......................................................................................................................................... 12 Tracking and Logging System for Fines Additional Functionality to Easily Add Notes ................. 12 Tracking system for Franchise Tax Board Fine Referrals .......................................................................... 12 Enforcement Referral Management ...................................................................................................... 13 Email Referral Form Template to Enforcement with Auto-Population of Fields ............................. 13 Tracking System for Status of Enforcement Referrals ................................................................................. 13 Public Reporting and Search Functionality ......................................................................................... 14 Allows Public to Run Pre-Configured Canned Reports ................................................................................ 14 Allows Public to Perform Ad-Hoc Searches ...................................................................................................... 14 Restricts All Redacted Information ...................................................................................................................... 14 Records Retention ....................................................................................................................................... 14 Retention and Auto-Deletion Capability for Forms with Arbitrary Deletion Date .......................... 14 Permanent Retention Capability for Records That Require Permanent Retention ........................ 14 Professional Services .................................................................................................................................. 15 SEI FORM 700 ELECTRONIC FILING SOLUTION 1

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Program Staff Training and Documentation .................................................................................................... 15 IT Training, Documentation and Handoff .......................................................................................................... 15 Plan For Revision of Forms and Instructions If No Built In Revision Functionality ....................... 15 Disaster Recovery ........................................................................................................................................ 16 Full Recovery Within 2 Hours of Non ISP Related Outage ......................................................................... 16 Backups Across the Wire to Offsite Location ................................................................................................... 16 Application Compatibility ......................................................................................................................... 17 Import CSV Files Generated by the FPPC Gift Tracking Application ...................................................... 17 Redaction ........................................................................................................................................................ 17 Requirement for Electronically Posted Forms to Have Redaction Options for Filers .................... 17 Migration ......................................................................................................................................................... 18 Method for Adding or Importing Users .............................................................................................................. 18 Accessibility Requirements ...................................................................................................................... 18 Costs ...................................................................................................................................................................... 19 One Time Costs: $217,000 ......................................................................................................................... 19 Recurring Costs (Includes Service, Maintenance, and Other Costs): $163,206 - $172,464 per year ........................................................................................................................................................... 19 Total Cost of Ownership Over 5 Years: $1,016,740 - $1,079,320 ................................................. 19 Cost per Filing Review ................................................................................................................................ 19 Assumptions ................................................................................................................................................................... 19 Labor .................................................................................................................................................................................. 20 Initial Cost per Filing ................................................................................................................................................... 20 Recurring Cost per Filing .......................................................................................................................................... 20 Total Cost per Filing .................................................................................................................................................... 21 Return on Investment ................................................................................................................................. 22 Based on Labor Costs of Filing Reviews ............................................................................................................. 22 Timeline ............................................................................................................................................................... 24

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Introduction
Campaign Compass is a technology-consulting firm located in downtown San Francisco, CA. After years of experience building cloud technology solutions for universities, large companies, small-businesses, and startups, we want to bring our years of expertise in solving efficiency problems to governments. Our past partners and customers have included Yahoo!, the Center for Advanced Hindsight (Dan Arielys lab), Duke University, Symphony Commerce (formerly Sneakpeeq), and many others, with whom we have had a record of excellence. We believe in solving government problems by using innovative technology. Having spoken to public officials in the state of California, we have understood the inefficiencies of using paper forms first-hand. These professionals could be spending their time in more efficient ways than manually managing filings with mostly non-electronic, time-intensive solutions. In addition to being time-intensive, these workflows often do not promote the levels of transparency that we will provide. Campaign Compass is pleased to offer a response to this Request for Information. We have provided a thorough and high-level explanation of our proposed system. We are confident that we can meet all of the development needs in-house and surpass your expectations. We believe that our advantages detailed below are key considerations that distinguish Campaign Compass from its competitors.

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Our Advantages
1. Cloud. Our solution is in the cloud. This means near-instantaneous disaster recovery, zero maintenance downtime, immediate error reporting to our team, and a fast and fluid service even during times of high traffic. 2. Configurability. We have built a proprietary configuration system that allows anyone to create or edit the form and validations with ease, as well as connect form fields to be automatically filled. The changes to the form are immediately reflected for all of the users. No programmer interaction necessary. 3. On Call. If there is an issue, the team will start working as soon as it is detected. Most issues will be resolved in a few hours after the issue is reported. 4. Full Text Search. Any of the information made available to the solution is immediately indexed for search. This includes any information in filers, agencies, and filings. 5. Amazing Form Validation. Our proprietary form builder application allows us to insert complex rules for form inputs. Besides requiring certain fields, we can also display or hide fields based on user inputs, require certain inputs based on previous inputs, and require certain input values based on previous inputs. 6. Intuitive User Interface. We provide dynamic, on-demand information to the users. These tooltips are tailored to what the filer has entered, making it even easier for filers to file Form 700 and for filing officials to work with them. 7. Electronic Signature. We have a module that allows filers to electronically sign their Form 700 filings, resulting in a totally paperless workflow. 8. Accept Credit Card. When filers are fined, we allow these filers to pay with credit card instead of by mailing a check using a highly secure payments API. 9. Return on Investment on Review Labor Costs alone. This is described in our cost section.

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Requirements
Security

Meets Layered Network Security Guidelines

The network security guidelines state that the system will contain the following: Secured authentication, complex password requirements, secure sockets layer (SSL), Web encryption, enterprise-level network firewalls, database encryption, password encryption, system hardening procedures, a backup and restore process, disaster recovery capability, and the capability to completely redact or omit information from an Internet posting of the form. Thus, our system will run under the HTTPS protocol that operates above SSL and uses web encryption with a certificate signed by VeriSign to meet the above requirements of SSL and web encryption. As our product will run on a cloud hosting solution, it will have enterprise-level firewalls inherently built in. Other benefits of using the cloud solution include system hardening (patches, minimal installed software on servers, and further maintenance), meaning that the quality system vulnerability protections constantly updated by the cloud solution used by thousands of the Internets top web sites will be made available to our service pro bono.1

Uses Secured Authentication

Our solution will utilize standardized password authentication passed over SSL meaning that sensitive login data is automatically encrypted. The passwords are stored hashed using the bcrypt algorithm and a salt, which means they are protected against brute-force rainbow table attacks. An attacker attempting to authenticate would also need to know the underlying salt in order to break in.

Uses Complex Passwords

We will require the user to create complex passwords that require a minimum of 8 characters, a mixture of uppercase and lowercase letters, and at least one number or symbol. It will also disallow the most common available passwords. This requirement aims to avoid the basic break-in technique of matching the password from a lookup table of passwords (which often includes one such as Password1. 1 Some of the requirements are covered in other sections and thus omitted in Security. 2 See section Form 700 > Preface for more information. 3 Line of best fit connecting data points of variable filing load. Scaling costs result from higher filer load. SEI FORM 700 ELECTRONIC FILING SOLUTION 5

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Has Automated Password Recovery System

Our solution will utilize the industry best-practice password reset system for password recovery. Given a users email address, we will send them an email with a link to create a new password for the account. Our system cannot send unencrypted passwords.

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Statement of Economic Interest - Form 700

Preface - Configurable Form Builder
Our underlying solution provides a proprietary, configurable form builder that allows the user to add, remove, and replace Form 700 web form fields. The user can also add all applicable tooltips, connect fields to be pre-populated, and add required form validations. This form builder automatically converts the form it creates into the currently used web form. This means that there is no programmer interaction necessary to update the form if changes are required. However, we will build the current state of the form 700.

User Experience Requirements Covered By the Form Builder

1. FPPC Instructions must be provided along with help aides in a rollover/hover environment. 2. Revise instructions each year. 3. Revise field headings, add fields, or delete fields each year. 4. Make major revisions, such as adding a new schedule with new fields.

Mandatory Fields and Validations

Using our configurable form builder, we can create both client and server-side form validations that ensure that the data passed will not have to be checked for completeness and for valid data locations (no emails in date fields).

Data Auto-Population (Previous Filing, Assumption of Office, Leaving Office)

Any field that requires data population from the database just needs to be named and an instruction added to the appropriate feed. This will be done by default in our solution.

Printing and Saving the Form

Both options will be available.

Blocking Filing Before Filer is Added

The filer needs to have a unique identifier issued by the FPPC to login, thus cannot file anything until that time.

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Database Management
Preface - MongoDB for Configurability and a CRUD API to Send/Receive Data
Due to the highly configurable nature of the form 700 requirements, a traditional SQL solution is not feasible as the nature of the data is inherently changeable and unstructured. For this reason, we have chosen the NoSQL database called MongoDB. It allows for easy expansion of the form with new schedules and updated fields. Meanwhile, MongoDB still provides the niceties of a SQL solution such as unique identification numbers. Using a CRUD interface (create, read, update, delete) on the backend, most of the requirements of this section are met, as the CRUD provides a schema structure onto the schemaless MongoDB.

Requirements Met By the Above

1. The database must identify a filer with certain data fields. 2. 3. 4. 5. 6. 7. Each filer must be identified with an agency. Each filer is identified through a structured table Each filer is identified with a single unique identification number. Enforcement Fields are Recorded in Filer History Access to each Form 700 field and relevant date, type of statement A filer can be associated with more than one agency

8. The database must program certain flags and business rules. (The will be added to the CRUD)

Certain Notifications are Recorded in Filer History

Currently, the solution stores notifications about the filer. Emails can easily be sent from the system as well.

Fine Information Fields are Recorded in Filer History

The database stores the fines for the filer. It makes them easily accessible through both the filer and through identification-based search.

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Reports
Preface - Analytical Reporting Tool
The solution will include a tool similar to Google Analytics (GA), which allows the users to create reports from any portion of the available data. In the same manner as GA, the solution will include the standard pre-made reports, but will also allow users to create their own with graphs to help visualize the data. All data in the database will be used to generate these reports.

Requirements Met by the Above

1. Ability for FPPC to run pre-made reports. 2. Ability got FPPC personnel to generate new reports types.

Figure 1 - Example of a Report

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Filing Official Functionality

Filing Official Database Access
The CRUD interface described in the Database Management section will allow the filing officials to have database access for enumerated tasks.

Blocking Invalid Filers

The CRUD interface will block filers without an assuming office date or election year. Backend schemas take care of this.

Stop Filings from Being Deleted

The FPPC and filing officials can mark a filing as misfiled in order to not have it show up in search results or reports. Additionally, we will add validation to our CRUD interface that prohibits a filer from being deleted if there is a filing associated with that filer.

Role Management
Modifiable role management will be made available to the entire system with an ability to change privileges given to filing officials, the FPPC, and users.

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Notifications
Email Blasts to Filing Officials and Classes of Filers
All of the emails available to the solution will be segmentable, which means that any particular portion of the mailers can be selected, from a single filer, to all filing officials. A web dashboard will be provided where the FPPC will be able to find and view old sent emails.

Nonfiler, Fine, and Amendment Request Letters to Filers

Sending emails to particular filers after a fine has been issued, an amendment requested, or a nonfiler letter needed will also be made available. These letters will be auto-populated, but can be edited on a case-by-case basis, if desired.

Figure 2 - Example of Notification Service

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Fine Management
Tracking and Logging System for Fines Additional Functionality to Easily Add Notes
We have already built a system to log any action on the platform, including fines owed, due dates, and amount received. We can also increase accountability by attaching these logged events to the specific administrators who generated the events. We also have a notes module already built that can be used to add notes to a filer, filing, deadline, fine, or anything else that is desired. These notes are attached to the objects that they describe and are an additional field in our database.

Tracking system for Franchise Tax Board Fine Referrals

If fines are not collected within the required time frame, the fine will remain outstanding in the system, but additional attributes will be added to the fine, such as date referred, amount, and date intercepted. Once the fine payment is intercepted, it will be easy for an administrator to fill out these additional attributes and enter that the fine has been paid in full. Any additional notes can be added as well.

Figure 3 - Example of Fine Management

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Enforcement Referral Management

Email Referral Form Template to Enforcement with Auto-Population of Fields
We have already built a highly scalable and reliable emailing service into our product. The emailing console auto-completes filer email addresses, making it easy for an administrator to send an email to any filer. Adding additional auto-completed information into emails would simply require querying additional fields from the database.

Tracking System for Status of Enforcement Referrals

Every filing has a status associated with it, and each status is clearly displayed in the filing management dashboard. If a filing requires an enforcement referral, the status of the filing is changed to an enforcement referral. Once that is done, the agency professional can select the date that the referral was made via a date picker. Once the case is closed, the agency can record the date that it was closed, which will simultaneously log that in the filer history.

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Public Reporting and Search Functionality

Allows Public to Run Pre-Configured Canned Reports
The public viewing portal will have certain canned reporting options, such as reports showing all filers in a specific year or filers sorted by agency. When a user clicks on a filing, the filing will open in a new window, and there will be an option to print the filing, if desired.

Allows Public to Perform Ad-Hoc Searches

Full-text search is built into the portal. We index every single piece of data that is entered into the Form 700 filing, which makes everything searchable. However, redacted information is not searchable. As searches are being typed, the system will guess at what the user is trying to search for by displaying some autocomplete options.

Restricts All Redacted Information

Any information that is redacted, such as a home address, will not be shown in the filings on the public portal. We will flag all redacted information in the database and these fields will be omitted.

Records Retention
Retention and Auto-Deletion Capability for Forms with Arbitrary Deletion Date
The auto deletion capability will be built in and administered by the FPPC as one of the options in the product. We would simply wipe the existing data from the database and thus meet the retention plan.

Permanent Retention Capability for Records That Require Permanent Retention

Permanent retention is the default unless the FPPC changes the options described above.

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Professional Services
Program Staff Training and Documentation
Our product will come with a detailed user manual and YouTube video tutorials. The manual will outline all of the features of our product and will explain how to use all of the features. We will also record screencast videos of how to use the product, which will be a very effective teaching tool for new users.

IT Training, Documentation and Handoff

We will explain all of the technologies that we are using in the product and how they are used. We will provide any necessary system administration passwords for access to the databases and servers. We will also thoroughly comment our code for easier readability.

Plan For Revision of Forms and Instructions If No Built In Revision Functionality

We have developed a proprietary form builder tool that allows anyone to change the fields and validation of a web form. No programming is needed.2

2 See section Form 700 > Preface for more information.

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Disaster Recovery
Full Recovery Within 2 Hours of Non ISP Related Outage
If the service crashes, it will be immediately brought back online by the automatic disaster recovery tool used by the cloud solution. The service will not crash due to high loads and will automatically scale to a sustainable size. The cloud service solution guarantees at least 99.9%, which means worst-case performance is a downtime of 43 minutes per month from the ISP. In addition, if a bug should be detected for some users, there will be no downtime for users not experiencing the bug. Our service will simply replace the servers sequentially so that they will not experience any of it. Bug detection is also not an issue, as our service automatically tracks error rates and reports the precise nature of the errors to us. If there is a bug, we will immediately detect it and be notified.

Backups Across the Wire to Offsite Location

All of our data backups are automatically stored in a cloud service solution at an offsite location. If there should there be a security breach or data corruption, the most recent backup will automatically be loaded.

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Application Compatibility
Import CSV Files Generated by the FPPC Gift Tracking Application
We have built a CSV to MongoDB conversion tool already. Once we know the exact layout of the CSV, we can accurately map it into our database. This tool is a user facing tool that accepts a CSV file via a web form input and inserts the data into the database.

Redaction
Requirement for Electronically Posted Forms to Have Redaction Options for Filers
Our system inserts all of the Form 700 user inputs into the MongoDB database. If a redaction option is requested, we will simply not display the sensitive address fields of the filing. This is a huge time-savings for the FPPC because redaction no longer means using manual redaction. Additionally, any fields that are redacted will no longer be searchable in the public portal. In the database, these redacted fields will be flagged, thus redacting them in the public portal.

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Migration
Method for Adding or Importing Users
As was outlined in the Application Compatibility section above, administrators will be able to import a CSV into a web form. The CSV converter tool will take the CSV and import it into the MongoDB database.

Accessibility Requirements
The system will meet all state and federal accessibility requirements for impaired users. ...Proposed systems must meet all state and federal accessibility requirements for impaired users as detailed in section 508 of the Rehabilitation Act and Title II of the Americans with Disabilities Act and California Government Code 11135. The solution will have the following features to make the product more accessible: 1. For every image, we will use the alt attribute of the HTML img tag to describe the information in the image or graphic. 2. We will provide captioning for any audio and descriptions of any video. The entire website will be able to be operated without a mouse and solely with a keyboard. Every input will be able to be reached by using the tab key.

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Costs
One Time Costs: $217,000
Includes employee salaries for building the product, migrating the old documents, and travel to communicate with the FPPC in person.

Recurring Costs (Includes Service, Maintenance, and Other Costs): $163,206 - $172,464 per year
The formula for recurring costs is as follows3: Recurring Cost per Year = $(0.019 * number of filings per year + 162,718) This includes employee salaries, cloud services, and travel costs. The cost depends on the number of filings per year with the low end of 25,000 annual filings costing $163,206 per year and 500,000 annual filings costing $172,464 per year.

Total Cost of Ownership Over 5 Years: $1,016,740 - $1,079,320

The total cost of ownership includes both the one time cost and the recurring cost of ownership and can be calculated via the following formula: Total Cost for Five Years = $(0.095 * average number of filings per year + 1,003,590) The cost of ownership decreases after five years as the initial costs are no longer included.

Cost per Filing Review

Assumptions
A processor is paid at least $38 per hour ($76,000 per year) to handle the reviews. 80% of reviews will remain basic, facial reviews. The proportion of quick (5 minute) and long (20 minute) complex reviews is 15% and 5%, respectively.

3 Line of best fit connecting data points of variable filing load. Scaling costs result from higher filer load.

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Labor
We estimate that the time taken per basic review is about a minute per filing, which, if a staff member is paid about $38 per hour, prices the current review at $0.63. 80% of all reviews are basic reviews as of this time. Since these are eliminated, our labor cost per basic filing review is $0. The more complex review is said to take between 5 minutes for an amendment-less review and at least 20 minutes for one with at least one amendment4. This means that the current labor price per review is between $3.17 and $12.67. We estimate that with our system, we can make the procedure at least 5x faster, reducing the amount of time required to do a complex review to between 1 and 4 minutes. Thus the labor cost drops to between $0.63 and $2.53 per complex review. On average, with the proportions listed in the assumptions, the cost of labor drops from $1.63 per filing under the current practice to $0.22 per filing. There is a 8-fold labor cost decrease using Campaign Compass.

Initial Cost per Filing

The cost per filing is created by the following equation. The initial cost is spread across all five years to more accurately understand the long-term benefits: Initial Cost per Filing = $217,000 initial cost / 5 years / number of filings per year This cost is only applied to the first five years. At 25,000 annual filings, the cost per filing is $1.74; at 500,000 annual filings, it is $0.09 per filing.

Recurring Cost per Filing

The formula to calculate the price per filing for the recurring costs of the software is as follows5: $(0.019 * number of filings per year + 162,718) Recurring Cost per Filing = number of filings per year In terms of recurring costs, the cost is at $6.53 per filing when the total number of filings stands at 25,000 per year. If the number of filings reaches a projected maximum of 500,000, the cost drops to $0.34 per filing for our software.
4 Data derived from Reviewing Statements section of Current Practices in FPPC RFI (page 7) 5 Derived from the Recurring Cost per Year equation on the previous page

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Total Cost per Filing

The formula to calculate the price per filing is the following:

First Five Years6:

Total Cost per Filing = $(0.239 * number of filings per year + 206,118) number of filings per year

After Five Years:

Total Cost per Filing = $(0.239 * number of filings per year + 162,718) number of filings per year

During the first five years, the cost includes the initial cost spread evenly over the five years. At year five, the initial cost is recouped. Thus, during the first five years, at 25,000 annual filings, the cost is $8.48 per filing and, at 500,000, it is $0.65 per filing. After the first five years, at 25,000 annual filings, the cost per filing becomes $6.75 and, at 500,000, it is $0.56.

6 Derived by adding Recurring Cost per Review + Initial Cost per Review + 22 per filing for labor cost. The

22 per filing labor cost is calculated in the Labor section above.

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Return on Investment
Based on Labor Costs of Filing Reviews
Once there are 148,180 filings annually7, the FPPC breaks even on the cost of Campaign Compass on review labor alone, assuming that the initial costs are spread evenly across the first five years. As the FPPC current practice costs contain price of postage, technology costs, and labor costs not associated with reviews, the number of filings needed to receive a return on investment is much lower.

After the first five-year of using Campaign Compass, the number of annual reviews required to break even on labor costs drops to 116,979 filings8, because the initial costs have been recouped.
7 Based on Total Cost Per Review > First Five Years above. 8 Based on Total Cost Per Review > After Five Years above.

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The overall formula to estimate the difference in cost between labor costs and Campaign Compass is as follows9:

Difference in Costs for First Five Years

Difference in Costs per Year = 1.391 * number of filings per year - 206,118

Difference in Costs after Five Years

Difference in Costs per Year = 1.391 * number of filings per year - 162,718 What this means is that if Campaign Compass were to be used at full capacity (500,000 filings per year), it would save a whopping $489,382 for the FPPC each year if only review labor costs are included.

9 1.391 is derived from the current labor cost of $1.63 per filing - 22 labor per filing with Campaign Compass

- .019 recurring cost per filing.

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Timeline
We are confident that the platform will be completed and deployed within five months of being given the contract. To build the best possible product, we would love to have your input at all stages of the development process. Time Award After Three Weeks Activity Backend development begins. Backend development completed. Frontend development begins. Close cooperation with the FPPC to build a wonderful user experience starts. Frontend development completed. Beta testing begins and error handling begins. Beta testing is completed. Migration of older FPPC data begins. Deployment to servers begins. Integration with the current FPPC website begins. Migration of data completed. Servers deployed. Integration with FPPC website completed.

After 2 Months After Three Months After Four Months After Five Months

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