Multi-County Agencies - Adopting and Amending Conflict of Interest Codes

A multi-county 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 700). One of the FPPC’s primary goals is to streamline the process for adopting and amending conflict of interest codes so it is more efficient for the agency and the FPPC.

The information below provides an overview of the process. For a more detailed description of the process, please refer to the FPPC’s guide How to Amend a Multi-County Agency’s Conflict of Interest Code Fact Sheet.

Biennial Review of Conflict of Interest Codes

Over time, the structure of an agency will change because employees’ duties shift, positions are renamed or eliminated, and the organizational structure is modified. When an agency makes these types of changes, the conflict of interest code must be amended accordingly. To ensure the codes remain current and accurate, a multi-county agency must review its code biennially during even-numbered years. The FPPC will send a Multi-County Agency Biennial Notice as a reminder of this obligation.

The Six-Step Process to Amend a Multi-County Agency's Conflict of Interest Code

If a multi-county agency determines it must amend its code, there are six steps to complete: 

1. Collect all necessary documentation, including the current code.
2. Review and update the code to reflect the current agency structure.
3. Submit the updated code and other required documents to the FPPC for review.
4. Consult with the FPPC and amend the code as necessary.
5. Conduct a 45-day public notice and comment period.
6. Submit the amended code to the FPPC for final approval.

For detailed information on each step in the process, please refer to the FPPC’s Multi-County Agency Conflict of Interest Code Amendment Checklist.

Resources for Multi-County Agencies

• How to Amend a Multi-County Agency’s Conflict of Interest Code Fact Sheet
• Multi-County Agency Biennial Notice
• Multi-County Agency Conflict of Interest Code Amendment Internal Checklist
• Multi-County Agency Sample Disclosure Categories
• Samples of Explanation of Changes

Tutorials on Conflict of Interest Codes

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. For more information on how to amend a local agency's code, please view our Recorded Video Tutorials provided by the FPPC. 

If you have questions, please contact the FPPC for Advice.

Statutory and Regulatory Authority

For more information on the Government Code Sections, please view The Political Reform Act.

• 87302, 87302.6, 87303, 87306, 87307, 87309, 87310, 87311, and 87314.

For more information on the regulations, please view the Regulations Index.

• 18750.