A. Terms of the Code (the "Body")The essential terms of a Conflict of Interest Code are found in the Code's main body, which includes such provisions as the manner of reporting financial interests, disqualification procedures, and other information. The Fair Political Practices Commission (FPPC) recommends that agencies incorporate FPPC Regulation 18730 by reference because the information required to be in a code's main body is complex and may change over time. Regulation 18730 contains all the necessary provisions. The FPPC periodically amends this regulation to include legislative and regulatory changes. By incorporating FPPC Regulation 18730 by reference, the body of the code automatically stays in compliance with Political Reform Act Regulations.
B. Designated Positions
A Conflict of Interest Code must specifically list positions that make or participate in making decisions. Typically, positions that involve voting on matters, negotiating contracts, or making recommendations on purchases without substantive review must be included in the Code. Persons holding positions listed in Government Code Section 87200 are considered "statutory filers." Such persons, include the Mayor, City Councilmembers, the City Manager, the City Attorney, the City Treasurer, Planning Commissioners and persons who manage public investments.
C. Disclosure Categories
The primary purpose of the Conflict of Interest Code is the requirement to disclose types of financial interests, business positions and property that may be affected by the decision-making of persons holding designated positions. Each position designated in the Conflict of Interest Code is assigned a unique disclosure requirement.