Local Government Agencies-Adopting & Amending Conflict of Interest Codes

A local agency’s conflict of interest code must reflect the current structure of the organization and properly identify officials and employees who should be filing Statements of Economic Interests (Form 700s). A code tells public officials, governmental employees, and consultants what financial interests they must disclose on their Form 700s. It helps provide transparency in local government as required under the Political Reform Act. 

To ensure conflict of interest codes remain current and accurate, each local agency is required to review its code at least every even-numbered year. The agency should receive a Biennial Notice as a reminder of this obligation from its code reviewing body.

The County Board of Supervisors is the code reviewing body for county agencies and the code reviewing body for city agencies is the City Council.

When determining whether to amend, an agency should carefully review its current conflict of interest code and consider the following:        

• Is the current code more than five years old?
• Have there been any substantial changes to the agency's organizational structure since the current code was adopted?
• Have any positions been eliminated or renamed since the current code was adopted?
• Have any new positions been added since the current code was adopted?
• Have there been any substantial changes in duties or responsibilities for any positions since the current code was adopted?
• If an agency answers “yes” to any of the above questions, most likely its conflict of interest code will need to be amended.

The resources below provide guidance to local agencies about amending codes. The information is categorized based on the jurisdiction of the agency.

• Local Biennial Notice Instructions
• Biennial Notice

• Local Biennial Notice Instructions
• Biennial Notice

The FPPC also offers workshops and webinars on conflict of interest codes for state or local government employees who are tasked with creating or amending their agency's code. The training explains how to adopt or amend a code. Topics include review of the current code, analysis of disclosure categories, how to designate positions, and how to assign categories to those positions. Additional training information is available including an online video on how to amend a local agency's code.

If you have further questions, Ask the FPPC for Advice.

Government Code Sections 87302, 87302.6, 87303, 87306, 87306.5, 87307, 87309, 87310, 87311, and 87314 can be viewed in the Political Reform Act.