HomeMy WebLinkAboutCA FPPC Conflict of Interest Code 2016CITY of Agenda Item No: 4.b
Meeting Date: September 19, 2016
SAN RAFAEL CITY COUNCIL AGENDA REPORT
Department: City Attorney
Prepared by: Eric Davis, Deputy City Attorney II City Manager Approval: P�_
File No.: 9-4-3
TOPIC: CONFLICT OF INTEREST CODE
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THE FAIR POLITICAL PRACTICES COMMISSION'S MODEL CONFLICT OF
INTEREST CODE, WITH AN UPDATED LIST OF DESIGNATED OFFICIAL
AND EMPLOYEE POSITIONS AND DISCLOSURE CATEGORIES, AS THE
CITY'S CONFLICT OF INTEREST CODE
RECOMMENDATION:
Adopt Resolution.
BACKGROUND:
California's Political Reform Act (the "PRA") requires that certain specified state and local agency
officials including, in a city, the mayor, city councilmembers, city manager, city attorney, city treasurer,
and planning commissioners, must file an annual statement disclosing their financial interests that could
be affected by decisions they make as part of their official city duties. (Government Code §§87200-
87210). These statements of economic interest, also known as "Form 700's", are filed with the PRA's
administering agency, the Fair Political Practices Commission (the "FPPC"), in Sacramento, with copies
kept on file in the City Clerk's office for public review.
The PRA also requires that every state and local agency must adopt its own individual Conflict of Interest
Code to specify, by position, which of its other agency officials and employees must file annual "Form
700" statements, in order to disclose any financial interests they have that foreseeably may be affected
materially by decisions they make as part of their official duties or employment. Some of these officials
and employees are required to file disclosure statements because of their position, and others are required
to file because of their duties. Boards and commissions are considered to have "decision-making
authority" if historically the recommendations of those boards and commissions have been routinely
adopted by the agency's legislative body. Additionally, by FPPC regulation, consultants are considered
"public officials" for purposes of the PRA if they either serve in the capacity of a staff member or make
recommendations that are routinely adopted by the legislative body.
By regulation, the FPPC has adopted a model Conflict of Interest Code, which state and local agencies
may adopt by reference, through the approval of a resolution that also includes a list of agency official
and employee positions that will be subject to the requirement to file an annual Form 700, along with the
FOR CITY CLERK ONLY
File No.: 9-4-3
Council Meeting: 09/19/2016
Disposition: Resolution 14188
SAN RAFAEL CITY COUNCIL AGENDA REPORT / Paae: 2
categories of financial interests that those officials and employees must disclose. Copies of all Form
700's are kept on file in the City Clerk's office for public review.
However, in every even -numbered year, the public agency must review and, if necessary, revise that
portion of the agency's Conflict of Interest Code containing the agency's list of designated positions and
disclosure categories. This update serves to incorporate any organizational changes such as the new titles
of recently hired employees, deleted positions, and other organizational restructuring.
ANALYSIS:
The City of San Rafael has for many years adopted the model code as the City's Conflict of Interest Code,
by adoption of a resolution with attached lists of designated employees and officials, and their associated
disclosure categories. (See Attachment 4 for current Resolution No. 13794.) Therefore, in this even -
numbered year, the City is required to update its Conflict of Interest Code.
Accordingly, the City Clerk requested all City departments to review and, if necessary, to revise their
respective lists of designated employees, boards or commissions, and consultants, and their proper
disclosure categories. Staff has prepared the attached resolution that would repeal current Council
Resolution No. 13794 and re -adopt the FPPC's model Conflict of Interest Code with updated position
designations and disclosure categories. (See Attachment 1)
FISCAL IMPACT:
No fiscal impact is anticipated from adoption of this resolution.
OPTIONS:
The City is required to update its Conflict of Interest Code; however, the City Council has the following
options to consider on this matter:
1. Adopt the resolution as presented.
2. Direct staff to return with more information or modifications to the resolution.
RECOMMENDED ACTION:
Adopt the attached Resolution Repealing Resolution No. 13794 and Re -Adopting the Fair Political
Practices Commission's Model Conflict of Interest Code, With a Revised List of Designated Employee
Positions and Disclosure Categories, as the City's Conflict of Interest Code
ATTACHMENTS:
1. Resolution for adoption, including Appendices A and B
2. Deputy City Attorney II - Memorandum dated August 23, 2016
3. Model FPPC Conflict of Interest Code (2 CCR Section 18730)
4. Resolution No. 13794 to be repealed
WACity Clerk- WorkFile\FPPC\Conflict of Int -700 series\FPPC biennial item 09-16 doc
RESOLUTION NO. 14188
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN RAFAEL
REPEALING RESOLUTION NO. 13794 AND RE -ADOPTING THE FAIR
POLITICAL PRACTICES COMMISSION'S MODEL CONFLICT OF
INTEREST CODE, WITH AN UPDATED LIST OF DESIGNATED OFFICIAL
AND EMPLOYEE POSITIONS AND DISCLOSURE CATEGORIES, AS THE
CITY'S CONFLICT OF INTEREST CODE
WHEREAS, pursuant to the Political Reform Act ("PRA"), California Government
Code Sections 81000, et seq., the City Council has adopted by resolution from time to time, most
recently by Resolution No. 13794, the Fair Political Practices Commission's ("FPPC") model Conflict
of Interest Code, contained at Title 2, California Code of Regulations, Section 18730, as the City's
Conflict of Interest Code, including therewith a designation of official and employee positions subject
to that Code and their required disclosure categories; and
WHEREAS, California law requires that in every even -numbered year, each state
agency and local governmental agency is required to review and, if necessary, revise its Conflict of
Interest Code, including the review and revision of its list of designated official and employee positions
and its list of disclosure categories, so as to incorporate necessary changes, such as the new titles of
recently hired employees, deleted positions, and other organizational restructuring; and
WHEREAS, the City Council has determined that the attached Appendices A and B,
which are incorporated herein by reference, accurately set forth those designated official and employee
positions (Appendix A - Designated Employees) and disclosure categories of financial interest
(Appendix B - Disclosure Categories), which should be made reportable under the City's Conflict of
Interest Code; and
WHEREAS, the City Council desires to continue to use the FPPC's model Conflict of
Interest Code, as set forth in Title 2, California Code of Regulations Section 18730, a copy of which is
1
available for public review in the City Clerk's office, as the City's Conflict of Interest Code;
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF SAN RAFAEL
RESOLVES as Follows:
1. The above -recited facts are true and correct.
2. City Council Resolution No. 13794 is hereby repealed.
3. The FPPC's model Conflict of Interest Code, as set forth in Title 2, California Code
of Regulations Section 18730, is hereby incorporated herein by reference and re -adopted as the City's
Conflict of Interest Code.
4. The attached list of designated employee/official positions (Appendix A) and list of
disclosure categories (Appendix B) are hereby adopted and incorporated by reference into the City of
San Rafael's Conflict of Interest Code.
5. The officials and employees holding designated positions shall file statements of
economic interests (Form 700) as required by regulations of the FPPC and by Section 4 (C) of the
City's Conflict of Interest Code, with the City Clerk, and the City Council hereby delegates the
authority of filing officer to the City Clerk.
I, ESTHER C. BEIRNE, Clerk of the City of San Rafael, hereby certify that the
foregoing Resolution was duly and regularly introduced and adopted at a regular meeting of the
Council of said City on Monday, the 19th day of September, 2016 by the following vote, to wit:
AYES: COUNCILMEMBERS: Bushey, Colin, Gamblin, McCullough & Mayor Phillips
NOES: COUNCILMEMBERS: None
ABSENT: COUNCILMEMBERS: None
A-- jet,_r -
ESTHER C. BEIRNE, City Clerk
W:\City Clerk- WorkFile\Agenda related\FPPC issues\conflict of int reso 09-16.doc
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APPENDIX A
Desianated EmDlovees
DEPARTMENT
POSITION
City Attorney
Assistant City Attorney
Deputy City Attorney II
City Clerk
City Clerk
Deputy City Clerk
City Manager
Assistant City Manager
Director of Homeless Planning & Outreach
Director of Economic Development and Innovation
Economic Development Program Coordinator
Events Coordinator
Community Development
Community Services
Community Development Director
Planning Manager
Senior Planner
Associate Planner
Assistant Planner
Planning Technician
Code Enforcement Official III
Code Enforcement Official II
Code Enforcement Official I
Chief Building Official
Permit Services Coordinator
Building Inspector II
Building Inspector I
Community Services Director
Senior Recreation Supervisor
Recreation Supervisor
Program Coordinator
Fire Fire Chief
Deputy Fire Chief
Battalion Chief - Operations
Battalion Chief -Administration
Administrative Fire Captain
Deputy Fire Marshal
Fire Prevention Specialist
Fire Prevention Inspector II
Fire Prevention Inspector I
Environmental Management Coordinator
Emergency Management coordinator
Vegetation Management Specialist
Finance Finance Director
Accounting Supervisor
Revenue Supervisor
Management Analyst
DISCLOSURE
CATEGORY
1,2
1,2
3b, 3g
3b, 3g
1,2
1,2
1,2
1,2
1,2
1,2
1,2
1,2
1,2
1,2
1,2
1,2
1,2
1,2
1,2
3e
3e
3f, 3g
3f, 3g
3f, 3g
3f, 3g
2, 3d, 3e, 3g
2, 3d, 3e, 3g
2, 3d, 3e, 3g
2, 3d, 3e, 3g
2, 3d, 3e, 3g
2, 3d, 3e, 3g
2, 3d, 3e, 3g
2, 3d, 3e, 3g
2. 3d, 3e, 3g
2. 3d, 3e, 3g
2, 3d, 3e, 3g
2, 3d, 3e, 3g
1,2
1,2
2, 3 (in entirety)
1,2
Library Library Director 3d, 3g
Assistant Library Director 3d, 3g
Management Services Human Resources Director 3a, 3g
Senior Management Analyst 3a, 3g
Information Technology Manager 3d, 3e, 3g
DISCLOSURE
DEPARTMENT POSITION CATEGORY
Senior Network Administrator
Network Analyst
Parking Services Manager
Parking Operations Supervisor
Administrative Analyst
Police Chief of Police
Police Captain
Police Lieutenant
Civilian Supervisor
Training Officer
Youth Services Program Supervisor
Public Works / Public Works Director
Sanitation District Assistant Public Works Director / City Engineer
Administrative Manager
Associate Civil Engineer
Assistant Civil Engineer
Sr. Associate Engineer
Jr. Engineer
Associate Engineer
Assistant Engineer
GIS Analyst
Engineering Technician I
Engineering Technician II
Traffic Engineer
Traffic Engineering Technician I
Traffic Engineering Technician II
Streets Superintendent
Streets Maintenance Supervisor
Parks Superintendent
Parks Maintenance Supervisor
Garage Shop & Equipment Supervisor
District Manager / District Engineer, Sanitation District
Sr. Civil Engineer, Sanitation District
Associate Civil Engineer
Sewers Maintenance Supervisor
Sewer Maintenance Superintendent
Boards & Commissions Design Review Board
Geotechnical Review Board
Park & Recreation Commission
Consultants **
3d, 3e, 3g
3d, 3g
1,2
2, 3d, 3g
2, 3d, 3g
3d, 3e, 3f, 3g
3d, 3e, 3f, 3g
3d, 3e, 3f, 3g
3d, 3e, 3f, 3g
3f, 3g
3r. 3g
1,2
1,2
1,2
1,2
3g
3g
3g
3g
3g
3g
3g
3g
3g
3g
3g
1,2
1,2
3d, 3e
3d, 3e
3d
1,2
1,2
1,2
3e
3e
1,2
1,2
1,2
1,2
** With respect to Consultants, the relevant department director may determine in writing that a particular consultant is
hired to perform a range of duties that are limited in scope and thus is not required to comply with the disclosure
requirements described in these categories. Such determination shall include a description of the consultant's duties
and, based upon that description, a statement of the extent of disclosure requirements. The department director shall
forward a copy of this determination to the City Clerk. Nothing herein excuses any such consultant from any other
provision of this Conflict of Interest Code.
Designated Employees 2016
1
APPENDIX B
Disclosure Cateqories
Cateqory 1: All investments and sources of income.
Cateqory 2: All interests in real property.
Cateqory 3: Investments in business entities and sources of income of the type which have or
foreseeably could contract with the City to provide services, supplies, materials,
machinery, or equipment; or which could be enhanced when a designated
employee makes or participates in making a decision.
a. Personnel agencies or personnel consultants;
b. Municode and Marin County newspapers;
c. Financial institutions;
d. Department record forms, communications equipment, safety equipment,
firefighting or fire detection equipment, automotive or rolling stock sales,
automotive parts or equipment, general departmental supplies or equipment;
e. Building supplies or building, contractor, or construction firms;
f. Travel agencies, recreation and athletic supplies, building maintenance and
cleaning supplies;
g. Book, software, and audio-visual publishers and distributors; computer
equipment manufacturers and distributors.
NOTE: PENALTY FOR LATE FILING:
AS REQUIRED UNDER THE POLITICAL REFORM ACT OF 1974, AS AMENDED,
SECTION 91013, IF ANY PERSON FILES AN ORIGINAL STATEMENT AFTER ANY
DEADLINE, HE SHALL BE LIABLE IN THE AMOUNT OF $10.00 PER DAY AFTER
THE DEADLINE UNTIL THE STATEMENT IS FILED, UP TO A MAXIMUM OF
$100.00, WHICHEVER IS GREATER.
T:ACITY COUNCIL AGENDA ITEMS\Agenda Item Approval Process\CC FPPC Bi -Annual Review\Appendix B -Disclosure Categories.2016.docx
CITY OF SAN RAFAEL
San Rafael, California
INTERDEPARTMENTAL MEMORANDUM
DATE: August 23, 2016
TO: ESTHER BEIRNE, City Clerk
FROM: ERIC T. DAVIS, Deputy City Attorney II ,
RE: Amendment of Conflicts of Interest Code
California Government Code §87306.5 requires that the City review and, if necessary,
revise its Conflict of Interest Code every two years. The deadline for the current review and
revision of the Conflict of Interest Code is October')', 2016.
In 2004, the City of San Rafael adopted a Conflict of Interest Code (SRMC Chapter 2.10)
which incorporated by reference the Fair Political Practice Commission's ("FPPC") model Conflict
of Interest Code in 2 Cal. Code Regs. Section 18730. While this Code is automatically amended
whenever the model code is changed, the City is required to review and, if necessary, to revise its
list of "Designated Employees" (those employees required to file statements of economic interest,
Form 700) and its list of "Disclosure Categories" (the economic interests which must be disclosed
on the Form 700). The last review and revision was made on September 2, 2014 by City Council
Resolution No. 13794, and the current lists of Designated Employees and Disclosure Categories are
attached as Appendices "A" and "B" to that Resolution. Because of new positions, changed
circumstances and structural reorganization within City Departments, the list of "Designated
Employees" and the list of applicable "Disclosure Categories" may need to be revised. Please
forward copies of those Appendices to all Department Directors. Department Directors should
review their department employee positions, the disclosure categories applicable to those positions
and, if appropriate, revise both lists. Revised lists should be forwarded to you in sufficient time for
City Council adoption of any changes by its September 19, 2016 meeting.
WHO IS COVERED
Under the Political Reform Act (PRA), all local public officials, who foreseeably may
materially affect their own economic interests through their decisions or participation in decisions
in their official capacity, must disclose their economic interests by completing and filing with the
City Clerk Form 700. Persons required to disclose such economic interests fall into two general
classifications:
Conflict of Interest Code
Page
August 23, 2016
1. Those required to file disclosures because of their position (state constitutional
officers, legislators, county supervisors, mayors, council members, etc.).
Government Code §§87200-87210. Because the Government Code specifically
covers these individuals, they are not covered under the City's Conflict of Interest
Code. These positions include members of the City Council, the Mayor, members
of the Planning Commission, the City Manager, the Finance Director, and the City
Attorney.
2. Those required to file disclosures because of their duties (public officials and
employees who make or participate in the making of governmental decisions).
These include "Designated Employees", those members of City Boards and
Commissions with decision-making authority and certain consultants. These
positions are covered under the City's Conflict of Interest Code, adopted pursuant to
Government Code §§87300-87313, and accordingly, are the focus of this review
and revision.
A. Boards & Commissions:
A basic rule in the FPPC regulations is that the PRA applies to members of all City boards,
committees and commissions with decision-making authority. (2 Cal. Code Regs. § 18700(a)). A
board, committee or commission has decision-making authority if:
It may make a final governmental decision; or
2. It may compel or prevent the making of a governmental decision by its action or
inaction; or
3. Its recommendations are, and historically have been, routinely and regularly
followed
(2 Cal. Code Regs. § 18700(c)(2)(A).
Accordingly, if historically, the recommendations of an advisory board (e.g. Design Review
Board) have been consistently adopted by the Planning Commission or the City Council, the
members of such board, committee or commission must file disclosure statements of their
economic interests. Because a board or commission is titled "advisory" is not determinative of
whether it has "decision-making authority"; only an historical analysis of a board or commission's
'`actions" can determine its status.
B. Designated Emplovees:
The PRA's requirements apply to those officials, employees or consultants who either make
decisions or who participate in the decision-making process. The FPPC has determined that
officials, employees or consultants who negotiate for, or provide advice to the decision -maker by
Conflict of Interest Code
Page 3
August 23, 2016
way of research, reports or analysis, are "'participating in the decision-making process." As such,
these officials, employees and consultants must be included in the list of "Designated Employees"
and must file disclosure statements in the manner detailed in the City's Conflict of Interest Code.
WHAT MUST BE DONE
In order to comply with the PRA's requirement of updating the Conflict of Interest Code,
each City Department Director should do the following:
1. Review his/her duties and the duties of the department/agency employees to
determine whether particular positions should be added or deleted to the list of
"Designated Employees." Delete positions which no longer exist or no longer are
involved in the decision making process and add those new positions which are
involved in the decision making process.
2. Review the functions and duties of any boards, committees or commissions with
which the department/agency interacts to determine whether they meet the criteria to
file disclosure statements of economic interest.
Review the functions and duties of any department -retained consultants to
determine whether they meet the criteria to file disclosure statements.
After determining what positions must be designated, the Department Directors should next
determine which categories shall apply to each position. This determination is fact -driven by the
job -functions of a particular position and their relationship to potential financial interests over
which that position might have some control. In performing this review, department managers
should keep in mind that the City's Conflict of Interest Code and its listed "Designated Employees"
and "Disclosure Categories" must:
Provide reasonable assurance that all foreseeable conflict-of-interest situations will
be disclosed.
2. Provide each affected person a clear and specific statement of his/her duties under
the Code.
3. Provide adequate differentiation between "Designated Employees" with different
powers and responsibilities.
(Government Code §87309).
After making the revisions to their lists of designated employees and disclosure categories,
Department Directors should forward their revisions to your office.
Conflict of Interest Code
Page 4
August 23, 2016
EXAMPLE
In order to assist Directors in their review, the following example may be helpful. An
employee or consultant who negotiates, recommends or otherwise participates in the procurement
of computers should be designated on the list of "Designated Employees" under the above criteria.
Such an employee or consultant would be required to disclose any interests under category 3
("Investments in Business Entities and Sources of Income") but would most likely not be required
to disclose real property interests. As a city official who has authority to purchase goods, the object
of the PRA would be achieved by having this official disclose interests in businesses which sell
computers. The same type of analysis would be applicable to employees or consultants who
participate in the procurement of office supplies, library books, equipment, materials or services.
As an additional aid in determining who to include in a Department's list of "Designated
Employees," I have attached the FPPC's fact sheets on "How to Determine Who Should Be
Designated in a Conflict of Interest Code," and "Conflict -of -Interest Codes — Designating
Positions," and FPPC advice letters on how to determine which consultants are required to file
disclosure statements.
If you have any questions, please contact me.
Attachments
cc: Mayor & Council Members
Jim Schutz, City Manager
Rob Epstein, City Attorney
(Regulations of the Fair Political Practices Commission, Title 2, Division 6, California Code of
Regulations.)
§ 18730. Provisions of Conflict of Interest Codes.
(a) Incorporation by reference of the terms of this regulation along with the designation
of employees and the formulation of disclosure categories in the Appendix referred to below
constitute the adoption and promulgation of a conflict of interest code within the meaning of
Section 87300 or the amendment of a conflict of interest code within the meaning of Section
87306 if the terms of this regulation are substituted for terms of a conflict of interest code
already in effect. A code so amended or adopted and promulgated requires the reporting of
reportable items in a manner substantially equivalent to the requirements of article 2 of chapter 7
of the Political Reform Act, Sections 81000, et seq . The requirements of a conflict of interest
code are in addition to other requirements of the Political Reform Act, such as the general
prohibition against conflicts of interest contained in Section 87100, and to other state or local
laws pertaining to conflicts of interest.
(b) The terms of a conflict of interest code amended or adopted and promulgated pursuant
to this regulation are as follows:
(1) Section 1. Definitions.
The definitions contained in the Political Reform Act of 1974, regulations of the Fair
Political Practices Commission (Regulations 18110, et seq.), and any amendments to the Act or
regulations, are incorporated by reference into this conflict of interest code.
(2) Section 2. Designated Employees.
The persons holding positions listed in the Appendix are designated employees. It has
been determined that these persons make or participate in the making of decisions which may
foreseeably have a material effect on economic interests.
(3) Section 3. Disclosure Categories.
This code does not establish any disclosure obligation for those designated employees
who are also specified in Section 87200 if they are designated in this code in that same capacity
or if the geographical jurisdiction of this agency is the same as or is wholly included within the
jurisdiction in which those persons must report their economic interests pursuant to article 2 of
chapter 7 of the Political Reform Act, Sections 87200, et seq .
In addition, this code does not establish any disclosure obligation for any designated
employees who are designated in a conflict of interest code for another agency, if all of the
following apply:
(A) The geographical jurisdiction of this agency is the same as or is wholly included
within the jurisdiction of the other agency;
(B) The disclosure assigned in the code of the other agency is the same as that required
under article 2 of chapter 7 of the Political Reform Act, Section 87200; and
(C) The filing officer is the same for both agencies. 1
Such persons are covered by this code for disqualification purposes only. With respect to
all other designated employees, the disclosure categories set forth in the Appendix specify which
kinds of economic interests are reportable. Such a designated employee shall disclose in his or
her statement of economic interests those economic interests he or she has which are of the kind
described in the disclosure categories to which he or she is assigned in the Appendix. It has been
determined that the economic interests set forth in a designated employee's disclosure categories
are the kinds of economic interests which he or she foreseeably can affect materially through the
conduct of his or her office.
(4) Section 4. Statements of Economic Interests: Place of Filing.
The code reviewing body shall instruct all designated employees within its code to file
statements of economic interests with the agency or with the code reviewing body, as provided
by the code reviewing body in the agency's conflict of interest code.
(5) Section 5. Statements of Economic Interests: Time of Filing.
(A) Initial Statements. All designated employees employed by the agency on the effective
date of this code, as originally adopted, promulgated and approved by the code reviewing body,
shall file statements within 30 days after the effective date of this code. Thereafter, each person
already in a position when it is designated by an amendment to this code shall file an initial
statement within 30 days after the effective date of the amendment.
(B) Assuming Office Statements. All persons assuming designated positions after the
effective date of this code shall file statements within 30 days after assuming the designated
positions, or if subject to State Senate confirmation, 30 days after being nominated or appointed.
(C) Annual Statements. All designated employees shall file statements no later than
April 1. If a person reports for military service as defined in the Servicemember's Civil Relief
Act, the deadline for the annual statement of economic interests is 30 days following his or her
return to office, provided the person, or someone authorized to represent the person's interests,
notifies the filing officer in writing prior to the applicable filing deadline that he or she is subject
to that federal statute and is unable to meet the applicable deadline, and provides the filing
officer verification of his or her military status.
(D) Leaving Office Statements. All persons who leave designated positions shall file
statements within 30 days after leaving office.
(5.5) Section 5.5. Statements for Persons Who Resign Prior to Assuming Office.
Any person who resigns within 12 months of initial appointment, or within 30 days of the
date of notice provided by the filing officer to file an assuming office statement, is not deemed to
have assumed office or left office, provided he or she did not make or participate in the making
of, or use his or her position to influence any decision and did not receive or become entitled to
receive any form of payment as a result of his or her appointment. Such persons shall not file
either an assuming or leaving office statement.
(A) Any person who resigns a position within 30 days of the date of a notice from the
filing officer shall do both of the following:
(1) File a written resignation with the appointing power; and
(2) File a written statement with the filing officer declaring under penalty of perjury that
during the period between appointment and resignation he or she did not make, participate in the
making, or use the position to influence any decision of the agency or receive, or become entitled
to receive, any form of payment by virtue of being appointed to the position.
(6) Section 6. Contents of and Period Covered by Statements of Economic Interests.
(A) Contents of Initial Statements.
Initial statements shall disclose any reportable investments, interests in real property and
business positions held on the effective date of the code and income received during the 12
months prior to the effective date of the code.
(B) Contents of Assuming Office Statements.
4
Assuming office statements shall disclose any reportable investments, interests in real
property and business positions held on the date of assuming office or, if subject to State Senate
confirmation or appointment, on the date of nomination, and income received during the 12
months prior to the date of assuming office or the date of being appointed or nominated,
respectively.
(C) Contents of Annual Statements. Annual statements shall disclose any reportable
investments, interests in real property, income and business positions held or received during the
previous calendar year provided, however, that the period covered by an employee's first annual
statement shall begin on the effective date of the code or the date of assuming office whichever
is later, or for a board or commission member subject to Section 87302.6, the day after the
closing date of the most recent statement filed by the member pursuant to Regulation 18754.
(D) Contents of Leaving Office Statements.
Leaving office statements shall disclose reportable investments, interests in real property,
income and business positions held or received during the period between the closing date of the
last statement filed and the date of leaving office.
(7) Section 7. Manner of Reporting.
Statements of economic interests shall be made on forms prescribed by the Fair Political
Practices Commission and supplied by the agency, and shall contain the following information:
(A) Investment and Real Property Disclosure.
When an investment or an interest in real property s is required to be reported, a the
statement shall contain the following:
1. A statement of the nature of the investment or interest;
2. The name of the business entity in which each investment is held, and a general
description of the business activity in which the business entity is engaged;
3. The address or other precise location of the real property;
4. A statement whether the fair market value of the investment or interest in real property
equals or exceeds $2,000, exceeds $10,000, exceeds $100,000, or exceeds $1,000,000.
(B) Personal Income Disclosure. When personal income is required to be reported,
the statement shall contain:
1. The name and address of each source of income aggregating $500 or more in value, or
$50 or more in value if the income was a gift, and a general description of the business activity,
if any, of each source;
2. A statement whether the aggregate value of income from each source, or in the case of
a loan, the highest amount owed to each source, was $1,000 or less, greater than $1,000, greater
than $10,000, or greater than $100,000;
3. A description of the consideration, if any, for which the income was received;
4. In the case of a gift, the name, address and business activity of the donor and any
intermediary through which the gift was made; a description of the gift; the amount or value of
the gift; and the date on which the gift was received;
5. In the case of a loan, the annual interest rate and the security, if any, given for the loan
and the term of the loan.
(C) Business Entity Income Disclosure. When income of a business entity, including
income of a sole proprietorship, is required to be reported, 6 the statement shall contain:
1. The name, address, and a general description of the business activity of the business
entity;
2. The name of every person from whom the business entity received payments if the
filer's pro rata share of gross receipts from such person was equal to or greater than $10,000.
(D) Business Position Disclosure. When business positions are required to be reported, a
designated employee shall list the name and address of each business entity in which he or she is
a director, officer, partner, trustee, employee, or in which he or she holds any position of
management, a description of the business activity in which the business entity is engaged, and
the designated employee's position with the business entity.
(E) Acquisition or Disposal During Reporting Period. In the case of an annual or leaving
office statement, if an investment or an interest in real property was partially or wholly acquired
or disposed of during the period covered by the statement, the statement shall contain the date of
acquisition or disposal.
(8) Section 8. Prohibition on Receipt of Honoraria.
(A) No member of a state board or commission, and no designated employee of a state or
local government agency, shall accept any honorarium from any source, if the member or
employee would be required to report the receipt of income or gifts from that source on his or her
statement of economic interests. This section shall not apply to any part-time member of the
governing board of any public institution of higher education, unless the member is also an
elected official.
Subdivisions (a), (b), and (c) of Section 89501 shall apply to the prohibitions in this
section.
This section shall not limit or prohibit payments, advances, or reimbursements for travel
and related lodging and subsistence authorized by Section 89506.
(8.1) Section 8.1. Prohibition on Receipt of Gifts in Excess of $460.
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(A) No member of a state board or commission, and no designated employee of a state or
local government agency, shall accept gifts with a total value of more than $460 in a calendar
year from any single source, if the member or employee would be required to report the receipt
of income or gifts from that source on his or her statement of economic interests. This section
shall not apply to any part-time member of the governing board of any public institution of
higher education, unless the member is also an elected official.
section.
Subdivisions (e), (f), and (g) of Section 89503 shall apply to the prohibitions in this
(8.2) Section 8.2. Loans to Public Officials.
(A) No elected officer of a state or local government agency shall, from the date of his or
her election to office through the date that he or she vacates office, receive a personal loan from
any officer, employee, member, or consultant of the state or local government agency in which
the elected officer holds office or over which the elected officer's agency has direction and
control.
(B) No public official who is exempt from the state civil service system pursuant to
subdivisions (c), (d), (e), (f), and (g) of Section 4 of Article VII of the Constitution shall, while
he or she holds office, receive a personal loan from any officer, employee, member, or consultant
of the state or local government agency in which the public official holds office or over which
the public official's agency has direction and control. This subdivision shall not apply to loans
made to a public official whose duties are solely secretarial, clerical, or manual.
(C) No elected officer of a state or local government agency shall, from the date of his or
her election to office through the date that he or she vacates office, receive a personal loan from
any person who has a contract with the state or local government agency to which that elected
0
officer has been elected or over which that elected officer's agency has direction and control.
This subdivision shall not apply to loans made by banks or other financial institutions or to any
indebtedness created as part of a retail installment or credit card transaction, if the loan is made
or the indebtedness created in the lender's regular course of business on terms available to
members of the public without regard to the elected officer's official status.
(D) No public official who is exempt from the state civil service system pursuant to
subdivisions (c), (d), (e), (f), and (g) of Section 4 of Article VII of the Constitution shall, while
he or she holds office, receive a personal loan from any person who has a contract with the state
or local government agency to which that elected officer has been elected or over which that
elected officer's agency has direction and control. This subdivision shall not apply to loans made
by banks or other financial institutions or to any indebtedness created as part of a retail
installment or credit card transaction, if the loan is made or the indebtedness created in the
lender's regular course of business on terms available to members of the public without regard to
the elected officer's official status. This subdivision shall not apply to loans made to a public
official whose duties are solely secretarial, clerical, or manual.
office.
(E) This section shall not apply to the following:
1. Loans made to the campaign committee of an elected officer or candidate for elective
2. Loans made by a public official's spouse, child, parent, grandparent, grandchild,
brother, sister, parent -in-law, brother-in-law, sister-in-law, nephew, niece, aunt, uncle, or first
cousin, or the spouse of any such persons, provided that the person making the loan is not acting
as an agent or intermediary for any person not otherwise exempted under this section.
3. Loans from a person which, in the aggregate, do not exceed $500 at any given time.
9
4. Loans made, or offered in writing, before January 1, 1998.
(8.3) Section 8.3. Loan Terms.
(A) Except as set forth in subdivision (B), no elected officer of a state or local
government agency shall, from the date of his or her election to office through the date he or she
vacates office, receive a personal loan of $500 or more, except when the loan is in writing and
clearly states the terms of the loan, including the parties to the loan agreement, date of the loan,
amount of the loan, term of the loan, date or dates when payments shall be due on the loan and
the amount of the payments, and the rate of interest paid on the loan.
(B) This section shall not apply to the following types of loans:
1. Loans made to the campaign committee of the elected officer.
2. Loans made to the elected officer by his or her spouse, child, parent, grandparent,
grandchild, brother, sister, parent -in-law, brother-in-law, sister-in-law, nephew, niece, aunt,
uncle, or first cousin, or the spouse of any such person, provided that the person making the loan
is not acting as an agent or intermediary for any person not otherwise exempted under this
section.
3. Loans made, or offered in writing, before January 1, 1998.
(C) Nothing in this section shall exempt any person from any other provision of Title 9 of
the Government Code.
(8.4) Section 8.4. Personal Loans.
(A) Except as set forth in subdivision (B), a personal loan received by any designated
employee shall become a gift to the designated employee for the purposes of this section in the
following circumstances:
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1. If the loan has a defined date or dates for repayment, when the statute of limitations for
filing an action for default has expired.
2. If the loan has no defined date or dates for repayment, when one year has elapsed from
the later of the following:
a. The date the loan was made.
b. The date the last payment of $100 or more was made on the loan.
c. The date upon which the debtor has made payments on the loan aggregating to less
than $250 during the previous 12 months.
(B) This section shall not apply to the following types of loans:
1. A loan made to the campaign committee of an elected officer or a candidate for
elective office.
2. A loan that would otherwise not be a gift as defined in this title.
3. A loan that would otherwise be a gift as set forth under subdivision (A), but on which
the creditor has taken reasonable action to collect the balance due.
4. A loan that would otherwise be a gift as set forth under subdivision (A), but on which
the creditor, based on reasonable business considerations, has not undertaken collection action.
Except in a criminal action, a creditor who claims that a loan is not a gift on the basis of this
paragraph has the burden of proving that the decision for not taking collection action was based
on reasonable business considerations.
5. A loan made to a debtor who has filed for bankruptcy and the loan is ultimately
discharged in bankruptcy.
(C) Nothing in this section shall exempt any person from any other provisions of Title 9
of the Government Code.
(9) Section 9. Disqualification.
No designated employee shall make, participate in making, or in any way attempt to use
his or her official position to influence the making of any governmental decision which he or she
knows or has reason to know will have a reasonably foreseeable material financial effect,
distinguishable from its effect on the public generally, on the official or a member of his or her
immediate family or on:
(A) Any business entity in which the designated employee has a direct or indirect
investment worth $2,000 or more;
(B) Any real property in which the designated employee has a direct or indirect interest
worth $2,000 or more;
(C) Any source of income, other than gifts and other than loans by a commercial lending
institution in the regular course of business on terms available to the public without regard to
official status, aggregating $500 or more in value provided to, received by or promised to the
designated employee within 12 months prior to the time when the decision is made;
(D) Any business entity in which the designated employee is a director, officer, partner,
trustee, employee, or holds any position of management; or
(E) Any donor of, or any intermediary or agent for a donor of, a gift or gifts aggregating
$460 or more provided to, received by, or promised to the designated employee within 12
months prior to the time when the decision is made.
(9.3) Section 9.3. Legally Required Participation.
No designated employee shall be prevented from making or participating in the making
of any decision to the extent his or her participation is legally required for the decision to be
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made. The fact that the vote of a designated employee who is on a voting body is needed to break
a tie does not make his or her participation legally required for purposes of this section.
(9.5) Section 9.5. Disqualification of State Officers and Employees.
In addition to the general disqualification provisions of section 9, no state administrative
official shall make, participate in making, or use his or her official position to influence any
governmental decision directly relating to any contract where the state administrative official
knows or has reason to know that any party to the contract is a person with whom the state
administrative official, or any member of his or her immediate family has, within 12 months
prior to the time when the official action is to be taken:
(A) Engaged in a business transaction or transactions on terms not available to members
of the public, regarding any investment or interest in real property; or
(B) Engaged in a business transaction or transactions on terms not available to members
of the public regarding the rendering of goods or services totaling in value $1,000 or more.
(10) Section 10. Disclosure of Disqualifying Interest.
When a designated employee determines that he or she should not make a governmental
decision because he or she has a disqualifying interest in it, the determination not to act may be
accompanied by disclosure of the disqualifying interest.
(11) Section 11. Assistance of the Commission and Counsel.
Any designated employee who is unsure of his or her duties under this code may request
assistance from the Fair Political Practices Commission pursuant to Section 83114 and
Regulations 18329 and 18329.5 or from the attorney for his or her agency, provided that nothing
in this section requires the attorney for the agency to issue any formal or informal opinion.
(12) Section 12. Violations.
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This code has the force and effect of law. Designated employees violating any provision
of this code are subject to the administrative, criminal and civil sanctions provided in the
Political Reform Act, Sections 81000-91014. In addition, a decision in relation to which a
violation of the disqualification provisions of this code or of Section 87100 or 87450 has
occurred may be set aside as void pursuant to Section 91003.
1 Designated employees who are required to file statements of economic interests under any
other agency's conflict of interest code, or under article 2 for a different jurisdiction, may expand
their statement of economic interests to cover reportable interests in both jurisdictions, and file
copies of this expanded statement with both entities in lieu of filing separate and distinct
statements, provided that each copy of such expanded statement filed in place of an original is
signed and verified by the designated employee as if it were an original. See Section 81004.
See Section 81010 and Regulation 18115 for the duties of filing officers and persons in
agencies who make and retain copies of statements and forward the originals to the filing officer.
3 For the purpose of disclosure only (not disqualification), an interest in real property does not
include the principal residence of the filer.
4 Investments and interests in real property which have a fair market value of less than $2,000
are not investments and interests in real property within the meaning of the Political Reform Act.
However, investments or interests in real property of an individual include those held by the
individual's spouse and dependent children as well as a pro rata share of any investment or
interest in real property of any business entity or trust in which the individual, spouse and
14
dependent children own, in the aggregate, a direct, indirect or beneficial interest of 10 percent or
greater.
5 A designated employee's income includes his or her community property interest in the income
of his or her spouse but does not include salary or reimbursement for expenses received from a
state, local or federal government agency.
6 Income of a business entity is reportable if the direct, indirect or beneficial interest of the filer
and the filer's spouse in the business entity aggregates a 10 percent or greater interest. In
addition, the disclosure of persons who are clients or customers of a business entity is required
only if the clients or customers are within one of the disclosure categories of the filer.
Note: Authority cited: Section 83112, Government Code. Reference: Sections 87103(e), 87300-
87302, 89501, 89502 and 89503, Government Code.
HISTORY
1. New section filed 4-2-80 as an emergency; effective upon filing (Register 80, No. 14).
Certificate of Compliance included.
2. Editorial correction (Register 80, No. 29).
3. Amendment of subsection (b) filed 1-9-81; effective thirtieth day thereafter (Register 81,
No. 2).
4. Amendment of subsection (b)(7)(B)1. filed 1-26-83; effective thirtieth day thereafter (Register
83, No. 5).
5. Amendment of subsection (b)(7)(A) filed 11-10-83; effective thirtieth day thereafter (Register
83, No. 46).
6. Amendment filed 4-13-87; operative 5-13-87 (Register 87, No. 16).
15
7. Amendment of subsection (b) filed 10-21-88; operative 11-20-88 (Register 88, No. 46).
8. Amendment of subsections (b)(8)(A) and (b)(8)(B) and numerous editorial changes filed
8-28-90; operative 9-27-90 (Reg. 90, No. 42).
9. Amendment of subsections (b)(3), (b)(8) and renumbering of following subsections and
amendment of Note filed 8-7-92; operative 9-7-92 (Register 92, No. 32).
10. Amendment of subsection (b)(5.5) and new subsections (b)(5.5)(A)-(A)(2) filed 2-4-93;
operative 2-4-93 (Register 93, No. 6).
11. Change without regulatory effect adopting Conflict of Interest Code for California Mental
Health Planning Council filed 11-22-93 pursuant to title 1, section 100, California Code of
Regulations (Register 93, No. 48). Approved by Fair Political Practices Commission 9-21-93.
12. Change without regulatory effect redesignating Conflict of Interest Code for California
Mental Health Planning Council as chapter 62, section 55100 filed 1-4-94 pursuant to title 1,
section 100, California Code of Regulations (Register 94, No. 1).
13. Editorial correction adding History 11 and 12 and deleting duplicate section number
(Register 94, No. 17).
14. Amendment of subsection (b)(8), designation of subsection (b)(8)(A), new subsection
(b)(8)(B), and amendment of subsections (b)(8.1)-(b)(8.1)(B), (b)(9)(E) and Note filed 3-14-95;
operative 3-14-95 pursuant to Government Code section 11343.4(d) (Register 95, No. 11).
15. Editorial correction inserting inadvertently omitted language in footnote 4 (Register 96,
No. 13).
16
16. Amendment of subsections (b)(8)(A)-(B) and (b)(8. 1)(A), repealer of subsection (b)(8. 1)(B),
and amendment of subsection (b)(12) filed 10-23-96; operative 10-23-96 pursuant to
Government Code section 11343.4(d) (Register 96, No. 43).
17. Amendment of subsections (b)(8.1) and (9)(E) filed 4-9-97; operative 4-9-97 pursuant to
Government Code section 11343.4(d) (Register 97, No. 15).
18. Amendment of subsections (b)(7)(13)5., new subsections (b)(8.2)-(b)(8.4)(C) and amendment
of Note filed 8-24-98; operative 8-24-98 pursuant to Government Code section 11343.4(d)
(Register 98, No. 35).
19. Editorial correction of subsection (a) (Register 98, No. 47).
20. Amendment of subsections (b)(8.1), (b)(8. 1)(A) and (b)(9)(E) filed 5-11-99; operative
5-11-99 pursuant to Government Code section 11343.4(d) (Register 99, No. 20).
21. Amendment of subsections (b)(8.1)-(b)(8.1)(A) and (b)(9)(E) filed 12-6-2000; operative
1-1-2001 pursuant to the 1974 version of Government Code section 11380.2 and Title 2,
California Code of Regulations, section 18312(4) and (e) (Register 2000, No. 49).
22. Amendment of subsections (b)(3) and (b)(10) filed 1-10-2001; operative 2-1-2001.
Submitted to OAL for filing pursuant to Fair Political Practices Commission v. Office of
Administrative Law, 3 Civil C010924, California Court of Appeal, Third Appellate District,
nonpublished decision, April 27, 1992 (FPPC regulations only subject to 1974 Administrative
Procedure Act rulemaking requirements) (Register 2001, No. 2).
23. Amendment of subsections (b)(7)(A)4., (b)(7)(B)1.-2., (b)(8.2)(E)3., (b)(9)(A)-(C) and
footnote 4. filed 2-13-2001. Submitted to OAL for filing pursuant to Fair Political Practices
Commission v. Office of Administrative Lavv, 3 Civil C010924, California Court of Appeal, Third
17
Appellate District, nonpublished decision, April 27, 1992 (FPPC regulations only subject to 1974
Administrative Procedure Act rulemaking requirements) (Register 2001, No. 7).
24. Amendment of subsections (b)(8.1)-(b)(8.1)(A) filed 1-16-2003; operative 1-1-2003.
Submitted to OAL for filing pursuant to Fair Political Practices Commission v. Office of
Administrative Law, 3 Civil C010924, California Court of Appeal, Third Appellate District,
nonpublished decision, April 27, 1992 (FPPC regulations only subject to 1974 Administrative
Procedure Act rulemaking requirements) (Register 2003, No. 3).
25. Editorial correction of History 24 (Register 2003, No. 12).
26. Editorial correction removing extraneous phrase in subsection (b)(9.5)(B) (Register 2004,
No. 33).
27. Amendment of subsections (b)(2)-(3), (b)(3)(C), (b)(6)(C), (b)(8.1)-(b)(8.1)(A), (b)(9)(E) and
(b)(11)-(12) filed 1-4-2005; operative 1-1-2005 pursuant to Government Code section 11343.4
(Register 2005, No. 1).
28. Amendment of subsection (b)(7)(A)4. filed 10-11-2005; operative 11-10-2005 (Register
2005, No. 41).
29. Amendment of subsections (a), (b)(1), (b)(3), (b)(8.1), (b)(8. 1)(A) and (b)(9)(E) filed 12-18-
2006; operative 1-1-2007. Submitted to OAL pursuant to Fair Political Practices Commission v.
Office of Administrative Law, 3 Civil C010924, California Court of Appeal, Third Appellate
District, nonpublished decision, April 27, 1992 (FPPC regulations only subject to 1974
Administrative Procedure Act rulemaking requirements) (Register 2006, No. 51).
30. Amendment of subsections (b)(8.1)-(b)(8.1)(A) and (b)(9)(E) filed 10-31-2008; operative
11-30-2008. Submitted to OAL for filing pursuant to Fair Political Practices Commission v.
Off ce of Administrative Law, 3 Civil C010924, California Court of Appeal, Third Appellate
District, nonpublished decision, April 27, 1992 (FPPC regulations only subject to 1974
Administrative Procedure Act rulemaking requirements and not subject to procedural or
substantive review by OAL) (Register 2008, No. 44).
31. Amendment of section heading and section filed I 1-15-2010; operative 12-15-2010.
Submitted to OAL for filing pursuant to Fair Political Practices Commission v. Office of
Administrative Law, 3 Civil C010924, California Court of Appeal, Third Appellate District,
nonpublished decision, April 27, 1992 (FPPC regulations only subject to 1974 Administrative
Procedure Act rulemaking requirements and not subject to procedural or substantive review by
OAL) (Register 2010, No. 47).
32. Amendment of section heading and subsections (a) -(b)(1), (b)(3)-(4), (b)(5)(C),
(b)(8.1)-(b)(8.1)(A) and (b)(9)(E) and amendment of footnote 1 filed 1-8-2013; operative
2-7-2013. Submitted to OAL for filing pursuant to Fair Political Practices Commission v. Office
of Administrative Law, 3 Civil C010924, California Court of Appeal, Third Appellate District,
nonpublished decision, April 27, 1992 (FPPC regulations only subject to 1974 Administrative
Procedure Act rulemaking requirements and not subject to procedural or substantive review by
OAL) (Register 2013, No. 2).
33. Amendment of subsections (b)(8.1)-(b)(8.1)(A), (b)(8.2)(E)3. and (b)(9)(E) filed 12-15-2014;
operative 1-1-2015 pursuant to section 18312(e)(1)(A), title 2, California Code of Regulations.
Submitted to OAL for filing and printing pursuant to Fair Political Practices Commission v.
Office ofAdMblistrative Law, 3 Civil C010924, California Court of Appeal, Third Appellate
District, nonpublished decision, April 27, 1992 (FPPC regulations only subject to 1974
Administrative Procedure Act rulemaking requirements) (Register 2014, No. 51).
19
RESOLUTION NO. 13794
A RESOLUTION OF THE CITY COUNCIL OF THE
CITY OF SAN RAFAEL REPEALING RESOLUTION NO. 13402,
RE -ADOPTING THE FPPC MODEL CONFLICT OF INTEREST CODE
AS THE CITY'S CONFLICT OF INTEREST CODE, AND ADOPTING A
REVISED LIST OF DESIGNATED EMPLOYEE POSITIONS AND
DISCLOSURE CATEGORIES, TO BE INCORPORATED INTO THE
CITY'S CONFLICT OF INTEREST CODE
WHEREAS, pursuant to California Government Code Sections 81000, et seq.
(The Political Reform Act, or PRA), the City Council has adopted by Resolution from time to time the
Fair Political Practices Commission's model Conflict of Interest Code, contained at Title 2, California
Code of Regulations, Section 18730, as the City's Conflict of Interest Code, and adopted therewith
designated employee positions and disclosure categories for incorporation into the City's Conflict of
Interest Code, most recently by Resolution No. 13402; and
WHEREAS, every even -numbered year every state agency and local governmental
agency is required to review and, if necessary, revise its Conflict of Interest Code including review
and revision of its list of designated employee positions and its list of disclosure categories, so as to
incorporate such changes as the new titles of recently hired employees, deleted positions, and other
organizational restructuring; and
WHEREAS, the Council has determined that the attached Appendices A and B
accurately set forth those designated employee positions (Appendix A - Designated Employees) and
disclosure categories of financial interest (Appendix B - Disclosure Categories), which should be
made reportable under the City's Conflict of Interest Code; and
WHEREAS, the City Council desires to continue to use the FPPC's model Conflict of
Interest Code, as set forth in Title 2, California Code of Regulations Section 18730, as the City's
1
Conflict of Interest Code, a copy of which is available for public review in the City Clerk's office;
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF SAN RAFAEL
RESOLVES AS FOLLOWS:
1. The above -recited facts are true and correct.
2. Resolution 13402 is hereby repealed.
3. The FPPC's model Conflict of Interest Code, as set forth in Title 2, California Code
of Regulations Section 18730, is hereby re -adopted as the City's Conflict of Interest Code.
4. The attached list of designated employee positions (Appendix A) and list of
disclosure categories (Appendix B) are hereby adopted and incorporated into the City of San Rafael's
Conflict of Interest Code.
5. The officials and employees holding designated positions shall file statements of
economic interests (Form 700) as required by regulations of the FPPC and by Section 4 (C) of the
City's Conflict of Interest Code, with the City Clerk, and the City Council hereby delegates the
authority of filing officer to the City Clerk.
I, ESTHER C. BEIRNE, Clerk of the City of San Rafael, hereby certify that the
foregoing Resolution was duly and regularly introduced and adopted at a regular meeting of the
Council of said City on Tuesday, the 2nd day of September, 2014 by the following vote, to wit:
AYES: COUNCILMEMBERS: Bushey, Colin, Connolly, McCullough & Mayor Phillips
NOES: COUNCILMEMBERS: None
ABSENT: COUNCILMEMBERS: None
ESTHER C. BEIRNE, City Clerk
WACity Clerk- WorkHlMgenda related\FPPC issueslconf ict of int reso 09-I4.doc
2