No one was surprised when San Jose Councilmember Raul Peralez became the first official candidate to announce for Mayor Sam Liccardo’s seat in April. But the politician’s series of professional-grade YouTube video announcements—and their thousand-dollar price-tags—didn’t go unnoticed.

Financing the cost of the videos with an “IOU” for now, Peralez said the announcements sought to reach as many voters as possible while Covid-19-era event restrictions continue.

Peralez’s innovative vision could run afoul of campaign finance regulations, however, by some interpretations.

San Jose is one of a handful of jurisdictions that restricts campaign fundraising to the 180 days preceding a primary election, a rule approved in a 2007 wave of reforms meant to assuage worries about the influence of elected officials.

That means those running in the June 2022 mayoral primary can only use money from their own pockets until December.

Peralez said that effectively disadvantages candidates who don't come from wealth or means. Before proceeding with an “IOU” to pay for the ads come December, he said his legal counsel vetted the procedure and productions—coordinated through his campaign consultant—for conformance with campaign finance laws.

But the question found its way to San Jose’s Board of Fair Campaign and Political Practices weeks later, where Deputy District Attorney Mark Vanni affirmed there’s no rule against incurring expenses but left unanswered the question of whether those dollars turn out to be monetary or “in-kind” contributions.

It seems an FPPC investigation would ultimately have to gauge if Peralez’s videos pose any credible concern, if a complaint ever makes its way to the state watchdog.