By Todd Spitzer, Chairman of the O.C. Board of Supervisors
This week, the Orange County Board of Supervisors approved critical reforms in the way the County handles filing rules for financial conflict of interest disclosure forms, known as the Form 700 filing code.
“The Board’s action will reduce the risk of financial conflicts of interest in government and will provide greater transparency to the public,” Chairman Todd Spitzer said. “Orange County is leading the way for all local governments to bring more sunshine to what we do.”
The Board of Supervisors approved a “Conflict of Interest Code Disclosure and Filing Policy” that clarifies the obligations of each County agency and department in keeping its Form 700 filing code up to date.
This policy requires:
- Code amendments be submitted within 90 days of changes that require amendments (for example, when a new position is created)
- Biennial reviews of the Form 700 code with appropriate amendments
Each agency/department must send a representative to the Board of Supervisors meeting where the code amendment is being considered
- Each code amendment must include more detailed written justifications and explanations for all changes because these explanations were quite vague and unclear previously
- Each agency/department must ensure that its own employees has met the Form 700 filing requirement; previously, each department decided for itself whether it would check on its employees
At the Board’s direction earlier this year, County Counsel began the first-ever comprehensive review of the Form 700 filing requirements in each of the County’s agencies and departments. In their review of top level executives, County Counsel has determined five departments need to make changes in disclosure categories, four departments need to add positions to the list of people who should file the Form 700, and two departments need to rename positions. County Counsel is now reviewing all non-executive employees and consultants.
After County Counsel completes this first-ever review and presents the findings to the Board, the reviews will be done both biennially and when positions are added, modified, or deleted by agencies/departments. Additionally, going forward, whenever a County agency/department submits amendments to their Form 700 filing requirements, County Counsel will now review proposed amendments before they reach the Board agenda.
Recognizing that the Form 700 should not be a punitive device, the Board of Supervisors approved the development and enhancement of informational and training materials to give guidance to County agencies and departments for developing and amending their Form 700 filing codes.
Additionally, the Board of Supervisors approved providing resources on the Clerk of the Board’s web site to assist outside agencies in the creation and amendment of their Form 700 filing codes.