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BEST BEST & KRIEGER � <br />ATTORNEYS AT LAW <br />Regulation 18704.6 — Consultants and Public Officials Who Manage Public Investments <br />In addition to the mergers and clarifications mentioned above, the FPPC has <br />renumbered Regulation 18704.6 to 18700.3. The purpose of this renumbering was to <br />place the definitions of "consultant" and "public official' in the same area as other <br />definitions that apply to conflict of interest provisions in Regulations 18700 through <br />18700.2. <br />It should be noted that these Regulations are very specific in the process and protocols <br />for officials to follow for recusing themselves and identifying their interests creating a <br />conflict;. These apply to officials listed in Section 87200, including officials who manage <br />public investments. In our experience most, but not all, agency board members fall <br />under the definition of officials who manage public investments. As to those that do not, <br />the agency should adopt its own rules for addressing disqualifications, otherwise there <br />may be no process established for publicly disclosing conflicts for board members and <br />other public officials who are not filers under Section 87200. <br />CONCLUSION <br />Substantively, the only revision made is the addition of an exception for additional <br />services from a consultant in Regulation 18704(d)(7). The other changes have been <br />made to clarify the Regulations and create a more organized and streamlined code. <br />If you have any questions regarding the information in this memo or need guidance in <br />applying these Regulations, please do not hesitate to contact the Public Policy & Ethics <br />Group or your Best Best & Krieger attorney. Thank you. <br />Gary W. Schons <br />Krysten Steele, Paralegal <br />-3- <br />93939.00020V9740215.2 <br />