Between 2014 and 2015 Confirmation Hearings, Ethics Commissioner Ana Dahan Dropped Mention of NBCUniversal Lobbying And Campaign Funding Work From Her Résumé

Los Angeles City Ethics Commissioner Ana Dahan on August 9, 2016.
Los Angeles City Ethics Commissioner Ana Dahan on August 9, 2016.
A few days ago I wrote about Ethics Commissioner Ana Dahan’s day job at NBCUniversal’s so-called Legal & Governmental Affairs Unit, which turns out to be their lobbying department. The point was that it’s hard to see how she can create at least the appearance of impartiality in regulating lobbyists when she works for a bunch of lobbyists and employers thereof.

In any case, it turns out that Commissioners have to be confirmed by the City Council, and that creates a Council File (CF 14-1464). Dahan was appointed by Eric Garcetti in 2014 to fill a vacancy, and then again in 2015 for a full term. Thus she had two confirmation hearings just one year apart, and she made an interesting change in her résumé between the two.

Here is the 2014 version, and it lists her title in the NBCUniversal Legal & Governmental Affairs Unit as “Legal Clerk” and her duties required her to:

  • Review, analyze and respond to proposed and enacted legislation that impacts NBCU’s business interests
  • Assist with the reporting and legal compliance of NBCU’s political contributions and lobbying


So in 2014 she was working with NBCU’s lobbying and campaign funding, both of which are regulated by the Ethics Commission. It really doesn’t seem reasonable.

And here is the 2015 version. Her new title is “Legal Intern,” and her new responsibilities require her to:

  • Facilitate political engagement and community outreach to foster goodwill and promote NBCUniversal
  • Review, analyze and respond to proposed and enacted legislation that impacts NBCUniversal’s business interests
  • Identify and establish strategic partnerships to increase NBCUniversal’s corporate citizen profile


So between 2014 and 2015 she dropped the lobbying and the campaign funding from her résumé. Maybe this reflects a change in her duties, although as I said before, it’s hard to see how this makes much of a difference, given that she’s still working closely with people responsible for NBCU’s lobbying efforts. Or maybe it reflects a consciousness that it doesn’t look so good that one of the City’s top enforcers of the Municipal Lobbying Ordinance is a lobbyist or professional associate of lobbyists. There’s no way to tell at this point. Although her new duties are so vaguely described that they might well include lobbying, which certainly “foster[s] goodwill” and has to do with “respond[ing] to proposed and enacted legislation” and so forth.

Finally, Ethics Commissioners are required to file Form 700s (financial disclosure) and here are Ana Dahan’s from her two confirmations: 2014 and 2015. The salient point is that in 2014, when she was explicitly working with NBCU’s lobbyists, she was paid between $1,001 and $10,000. The next year, when lobbying vanished from her résumé, she was paid between $10,001 and $100,000. So she got at least a $1 raise. Who knows what it means..


Image of Ana Dahan is ©2016 MichaelKohlhaas.org.

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