While formal advice letters may provide helpful guidance, they do not apply universally.


A formal advice letter provides a defense and immunity only to the person on whose behalf the advice was sought, only for the specific facts identified in the letter, and only under the law in effect at the time the letter was issued.


Please contact the Ethics Commission for advice about your specific situation.

Los Angeles City Ethics Commission
  
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FORMAL ADVICE LETTERS
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CEC #
Date
Issued
Issue
Issue Description: Requestor: Law Section:
08-07 09/24/08 Post-CRA Employment Former CRA officials are subject to a time-based restriction on lobbying the CRA, as well as a ban on lobbying on matters in which they were personally and substantially involved, as long as that matter is still pending. Khan CRA Code §§ II, XI, XV.

LAAC § 24.1.1(f)(2)(K).

LACC § 705.

LAMC § 49.5.19(G)(2).

08-06 09/12/08 Lobbyist Consulting The City's ethics laws do not prohibit a lobbyist from contracting with the City, even when the lobbyist has a client who could be affected by the lobbyist's contract work. However, there may be conflict-of-interests concerns for both the lobbyist and the City, which should be addressed to the City Attorney's office. Oschin Cal. Gov't Code §§ 1090, 87100.

LACC § 222(a).

LAMC §§ 48.02, 48.04, 48.07, 48.08, 49.5.16, 49.5.2.

08-04 05/15/08 Financial Disclosure High-level filers are not required to report the separate income of their spouses on CEC Form 10, unless it is income (including gifts and loans) received from a restricted source. To be considered not reportable, separate income must be maintained in a separate account, the separate income may not be commingled with community funds or used to pay for community expenses, and community efforts may not be used to produce or enhance the separate income. High-level filers are not required to report on CEC Form 10 the investments and the interests in real property that are valued at $2,000 or more and are held by their spouses. Alarcon 2 Cal. Code of Regs. § 18229.

Cal. Gov't Code §§ 81002(c), 82029, 82030(a), 82033, 82034.

LAMC §§ 49.5.2, 49.5.6(C).

08-03 05/08/08 Exploratory Campaign Activities An individual may conduct a poll or survey that meets specific criteria and purchase precinct sheets without qualifying as a candidate for elective City office. An individual does qualify as a candidate for elective City office by participating in a neighborhood meeting--or engaging in any other activity--that provides information to voters about the individual or refers to the individual's potential future candidacy. State and City laws govern the contributions received by, the expenditures made by, and the reporting required of candidates for elective City office. Turovsky (Neumann) 2 Cal. Code of Regs. §§ 18215, 18225.7(a), 18225(a).

Cal. Gov't Code §§ 82007, 82015, 82025, 84200, 84200.5, 84211, 85200.

LACC §§ 470, 471(b).

LAMC §§ 49.7.1.1, 49.7.11, 49.7.13, 49.7.15, 49.7.19, 49.7.26.1, 49.7.6, 49.7.7(A).

08-02 03/06/08 Outside Employment An employee who does not file statements of economic interests is not a city official under the Governmental Ethics Ordinance and is not required to obtain prior written approval for outside employment. Fields (Allen) LAMC §§ 49.5.3, 49.5.5, 49.5.9.

07-07 01/17/08 Post-City Employment Former city officials are subject to a time-based restriction on lobbying the City, as well as a permanent ban on lobbying in matters in which they were personally and substantially involved. Manocchio LAMC §§ 48.02, 49.5.11, 49.5.2, 49.5.3.

07-06 12/17/07 Letter to City residents The City's governmental ethics laws do not regulate a neighborhood council member who sends a letter to City residents to discuss the accomplishments of homeowner associations and neighborhood councils, if the neighborhood council member is not a candidate for elective City office and the letter does not advocate for a particular result in a City election. Vahedi 2 Cal. Code of Regs. § 18701(a)(1).

Cal. Gov't Code §§ 81001(b), 82007.

LACC § 470(c).

LAMC §§ 48.02, 48.08(A)(2), 49.7.1.1, 49.7.11(C), 49.7.26, 49.7.26.1, 49.7.26.2, 49.7.26.3.

07-04 11/30/07 Disgorgement of laundered contributions State law permits the returning of laundered funds to state and city general funds, and city law does not prohibit the disgorgement of funds to the state in response to a state action. Turovsky (Weiss) Cal. Gov't Code §§ 84301, 85701.

LACC §§ 470(c)(9), 470(k).

LAMC §§ 49.7.12, 49.7.7.

07-05 11/14/07 Post-City Employment Former high-level city officials are subject to a time-based restriction on lobbying the City, as well as a permanent ban on lobbying in matters in which they were personally and substantially involved. Gutierrez LAMC §§ 48.02, 49.5.1, 49.5.11, 49.5.2, 49.5.3.

07-03 10/09/07 Post-City Employment Former city officials are subject to a time-based restriction on lobbying the City, as well as a permanent ban on lobbying in matters in which they were personally and substantially involved. Brown LAMC §§ 48.02, 49.5.11, 49.5.2, 49.5.3.

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DISCLAIMER:    Advice issued by the City Ethics Commission (CEC) provides guidance to the person requesting the advice and is based on the specific facts that person has provided and the language contained in the law at the time the advice was issued. As the Charter, ordinances, and related laws are subject to change, we strongly advise you to contact the CEC for advice based on your specific facts and circumstances.


 

2017 Los Angeles City Ethics Commission.