Ethical Lines Blurred or Crossed? Councilmember Tammy Kim’s Conflict of Interest?

The Irvine Watchdog started a new series titled, Ethical Lines Blurred or Crossed, presenting real life situations that our city has or is facing pertaining to our current City Councilmembers, and then asking our readers to be the judge. The first article was regarding Councilmember Mike Carroll’s misappropriation of tax dollars. This article will take a look at Councilmember Tammy Kim’s apparent conflict of interest.

Councilmember Tammy Kim Awards Center for Asian Americans in Action Grant Money While Serving on Its Advisory Council 

It is perfectly acceptable for a councilmember to award city grants to organizations doing important work for our community. But what if that same councilmember has significant ties to the organization she is awarding money to?

Councilmember Tammy Kim is one of the founders of Asians Americans in Action (A3), a nonprofit advocating to raise awareness of Asian American issues and support Asian Americans running for public office. A3 then formed Asian Americans in Action PAC (A3 PAC) in order to make financial contributions to political campaigns. PAC stands for political action committee and is created for the purpose of raising and spending money to elect and defeat candidates. Councilmember Kim was one of the endorsed candidates of the A3 PAC.

According to their FEC filings, the A3 PAC contributed to 10 candidates. Only two received the maximum allowed, more than any other candidates — Councilmember Tammy Kim and Mayor Farrah Khan.

Not to be confused with A3 or the A3 PAC, Center for Asian Americans in Action (Center for A3) is a sister organization to A3. The Center for A3 is a nonprofit that does policy research and advocacy. As of the date of the screenshot below, Councilmember Kim was on the Advisory Council for the Center for A3. The below screenshot was taken on January 22, 2022, the same day that Councilmember Kim denied having any involvement with the Center for A3 in the Irvine Watchdog Facebook Group. After Kim’s involvement with Center for A3 was questioned on social media, her bio was deleted from their website, though it had been available at the time of both expenditures in April and November of 2021, as described below.

Requests for Community Partnership Grants

Each Irvine Councilmember is given $10,000 in Community Partnership Grants to allocate to nonprofits throughout each year. On average, Councilmembers grant anywhere from $500 – $1,000 to numerous nonprofits, typically located in Irvine, to support the work they do for the community.

On April 6, 2021, Councilmember Kim requested $6,000 for the Orange County Asian Pacific Islander Community Alliance (OCAPICA), which is located in Garden Grove and does great work serving the Asian American community by providing medical services and mental health counseling to underserved, low-to-moderate income Asian families amongst many other services. The Founder and Executive Director of OCAPICA was appointed by Councilmember Kim to the Irvine Children Youth Family Advisory Committee.

OCAPICA is a fiscal sponsor for the Center for A3. A fiscal sponsor provides financial oversight and IRS compliance for nonprofits. Any money raised by or for a sponsored organization (in this case, Center for A3), is directed to the fiscal sponsor (OCAPICA), to be held for the use of the sponsored organization (Center for A3).


At the December 14, 2021 City Council meeting, Councilmember Kim requested $3,000 to be awarded to, again, OCAPICA, this time clearly indicating “in support of” Center for A3. But her ties to the organization were not disclosed or mentioned.

Both the April $6,000 and November $3,000 expenditures were approved under the Consent Calendar.  Consent Calendar items are voted on all at once without Council discussion unless an item is “pulled”. Therefore, Kim’s funding requests passed under the radar without any public knowledge of Kim’s involvement with the Center for A3.

Were Ethical Lines Blurred or Crossed?

  1. Is it ethical for a public official to use taxpayer money to benefit an organization on whose board she sits or formerly sat?
  2. Was it ethical for Councilmember Kim not to disclose that she had been or was on the Advisory Board for the Center for A3 to which she awarded public money?
  3. Was it ethical for Councilmember Kim to allocate $6,000 to OCAPICA, which is run by the same person that Councilmember Kim appointed to an Irvine committee without disclosing this relationship?
  4. Was it ethical for Councilmember Kim to allocate $3,000 to the Center for A3, which is a sister organization to an organization that Councilmember Kim founded, whose PAC ultimately endorsed and contributed financially to her 2020 campaign?

Correction: Center for A3 informed Irvine Watchdog that Councilmember Kim no longer sits on their Advisory Board. Also, the website for the Center for A3 did not have Councilmember Kim’s bio up in April of 2021. Questions 1-3 are clarified accordingly. 

Disclaimer: This article is in no way questioning the good and much needed work being done by OCAPICA and Center for Asian Americans in Action, or whether or not these important organizations deserve financial support. The article is about the process, ethics, and transparency surrounding the way the decisions were made. A focused discussion on the issues presented is appreciated.

To make a donation to the Center for Asian Americans in Action click here.

To make a donation to Orange County Asian Pacific Islander Community Alliance click here.