It’s That Time Again: Annual Disclosure of Economic Interests by City Officials

Every April 1, state and local officials across California are required to file public Statements of Economic Interest (SEI) that disclose certain reportable financial interests. The purpose of financial disclosure is to alert public officials to personal financial interests they have that might be affected while they are performing their official duties. This awareness is important so that officials can avoid acting when they have a conflict between their personal interests and their participation in making a government decision.

Like those in other sectors, individuals in public service can have a variety of financial interests. Simply because an official must publicly report some or all of those interests does not mean a conflict exists, but disclosure of one’s financial interests is a tool to help officials identify when a potential conflict might exist. It then enables the official to seek guidance to assure that he or she does not make, participate in making, or influence a government decision that could affect a financial interest. In this way, government decisions are made without regard to an individual’s personal financial gain, and this process thereby helps create transparency that can promote public confidence in governmental actions.

As one of the building blocks of effective public disclosure, the California Political Reform Act requires each public agency to adopt a Conflict of Interest (COI) Code. This code identifies every position in a department that makes or participates in making governmental decisions. In the City, among other departmental employees, this includes general managers, most board and commission members, and certain contractors. These designated positions are assigned a category for their disclosure requirements, which lists the types of financial interests individuals in those positions must disclose. These interests are the types that could be affected by governmental decisions the official makes or can influence in his or her official capacity. Typical financial interests that are subject to disclosure include income, investments, and interests in real property from sources that are located or doing business in the jurisdiction. An employee who approves contracts for goods or services, for example, may not be required to disclose real estate interests, while an official who manages real property for his department may have to report those kinds of holdings.

All designated City officials must file an SEI on April 1, whether or not they have interests to disclose. Additionally, employees in newly created positions who participate in making government decisions and consultants not yet reflected on an agency's COI Code are required to file SEIs as well. While each departmental Ethics Liaison will assist their agency’s filers in the filing process by soliciting, processing, and forwarding all statements to the City Ethics Commission for the public file, it is each filer’s responsibility to ensure that they have filed properly and on time. Under the law, filing deadlines cannot be extended, and monetary penalties apply to late and incomplete filings.

The City Ethics Commission is glad to be of assistance if you have questions or need guidance in obtaining or completing your SEI. Please contact us during regular business hours at (213) 978-1960.

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