Exhibit 05
Taxes & Financial Compliance
Lives in
Arizona
By her own tax filings.

She lives in Arizona. Why is she running to represent San Francisco?

Brooke claims a primary residence tax exemption on her home in Scottsdale, Arizona— and another one on her home in San Francisco. Arizona law allows one primary residence per person. Both of her claims cannot be true.

She is running to represent District 2 in a city she has filed paperwork saying isn’t her primary home.

Lori Brooke owns property in two states. She claims a homeowner exemption on her San Francisco home at 2628 Greenwich Street. She also receives a primary residence tax credit on a property at 6350 N. 73rd Place, Scottsdale, Arizona. Arizona law is explicit: you can have only one primary residence. So is California’s. Brooke appears to be claiming both.

Meanwhile, the nonprofits she leads have gone years without filing required financial reports, submitted retroactive filings riddled with errors, and structured their finances to avoid almost all public disclosure. For a candidate running on competence and accountability, the financial record tells a different story.

5.1

Dual Homeowner Exemptions

The Brooke family’s San Francisco property at 2628 Greenwich Street carries a homeowner exemption — a tax benefit available only to people who occupy a property as their principal residence. In Arizona, the Scottsdale property at 6350 N. 73rd Place is classified by the Maricopa County Assessor as a “primary residence” for the 2024, 2025, and 2026 tax years. That classification provides a $400.18 annual state tax credit.

The Arizona Department of Revenue is clear on the rules: “A homeowner can have only one primary residence no matter how many homes he or she may own within or outside the State of Arizona.” A property classified as “primary residence” means the owner has represented to the county that it is their principal dwelling. You cannot live primarily in San Francisco and primarily in Scottsdale at the same time.

The history of the Arizona property makes the reclassification more striking. When John Brooke purchased the home in 2012, he filed an affidavit with the Maricopa County Recorder stating the property would be “owner occupied, not a primary residence.” The home was occupied by John’s mother until she passed away in December 2022. In February 2024, the property was transferred into a family trust. Shortly after, it was reclassified as a primary residence — reversing the sworn statement John Brooke made when he bought it.

Finding 5.1 · Dual Exemptions

When John Brooke bought the Arizona property in 2012, he swore under oath it was “owner occupied, not a primary residence.” Twelve years later, after his mother’s death, the property was reclassified as a primary residence — while the family still claims a homeowner exemption in San Francisco.

5.2

Nonprofit Filing Failures

The Cow Hollow Association, where Brooke has served as president since 2005, went 12 years without filing required financial reports with the California Department of Justice — from November 2010 to December 2022. California law requires charitable organizations to file annual reports with the Attorney General’s Registry of Charitable Trusts. For more than a decade under Brooke’s leadership, the Cow Hollow Association simply did not.

When six years of reports were finally filed retroactively in December 2022, they contained errors that suggest the filings were assembled hastily, not drawn from maintained financial records. The balance sheets listed the same number for both total assets and total revenue — two fundamentally different accounting concepts. For fiscal year 2017–18, total expenses were listed as $5,478.94, but the individual line items added up to $6,073.94 — a $595 shortfall that went unnoticed. For fiscal year 2019–20, net revenue was reported as −$2,927.43 when the correct figure was −$2,925.54. These are not rounding differences. They are the mistakes of someone filling in forms from memory or incomplete notes, not from books that were actually kept.

The California DOJ issued a delinquency notice to the Cow Hollow Association in August 2024. The organization Brooke has led for two decades still cannot maintain compliance with the state agency that oversees nonprofits.

RescueSF, the public benefit corporation Brooke co-founded in 2021, does not file its own IRS returns at all. It operates under the tax exemption of its fiscal sponsor, Legacy Global Programs, an Arizona-based organization. RescueSF’s income and expenses are folded into Legacy’s filings, which means the public has no way to see how much money RescueSF raises, how it spends those funds, or who gets paid.

5.3

Limited Financial Transparency

The Cow Hollow Association has never reported more than $50,000 in annual revenue. That keeps it below the threshold for filing a full IRS Form 990, so it files only the Form 990-N — the electronic “postcard” return that requires almost no financial disclosure. Revenue from fiscal year 2016–17 through fiscal year 2022–23 ranged from $5,889.09 to $21,405.68. Expenses exceeded revenue in five of those seven fiscal years, producing negative net revenue year after year. The DOJ filings show an organization that consistently spends more than it takes in but never explains where the money goes beyond a single line item for insurance.

RescueSF’s finances are even more opaque. Because it shelters under Legacy Global Programs’ tax exemption, RescueSF has no public IRS filings of its own. Legacy Global Programs is, by its own description, a fiscal sponsor-for-hire — it charges $20 per month plus 4% of all donations to serve as the legal and financial umbrella for organizations that have not obtained their own 501(c)(3) status. Legacy’s own IRS filings on ProPublica show an organization that sponsors dozens of projects simultaneously. RescueSF’s revenue, expenses, and compensation are buried inside those aggregate numbers, invisible to donors and to the public.

Finding 5.3 · Financial Transparency

Between the Cow Hollow Association’s postcard tax returns and RescueSF’s fiscal sponsorship arrangement, Brooke has structured her organizations so that virtually no financial information reaches the public.

The pattern across Brooke’s financial record is consistent: obligations deferred, disclosures minimized, and compliance treated as optional. The Cow Hollow Association went a decade without filing state reports. RescueSF avoids public filings entirely through a paid intermediary. The family’s properties carry tax benefits in two states under classifications that cannot both be true. Each issue alone might be a paperwork lapse. Together, they describe someone who treats financial accountability as an inconvenience — not the foundation of public trust.

Share this with your District 2 neighbors.

Election Day — June 2, 2026

Paid for by GrowSF Voter Guide. FPPC # 1433436. Committee major funding from: Nick Josefowitz. Not authorized by any candidate, candidate's committee, or committee controlled by a candidate. Financial disclosures are available at sfethics.org.