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Ms. Phan's duties as an attorney within the "Builders and Land Developers Team" of the Firm includes advocating on behalf of the Firm's real estate client base, which includes developers of projects in Santa Ana. Upon information and belief, the Firm represents real estate developer Centennial in the re - entitlement of the 49-acre Main Place Mall as well as the developer(s) of the One Broadway Plaza project, which is being re -entitled to include 14 floors of residential apartments. Both are major redevelopment projects in Santa Ana. Centennial's Santa Ana Main Place Mall and the One Broadway Plaza project developer(s) could be two of the "vested" projects specifically carved out of the HOO legislation approved by Ms. Phan. Because Centennial, the One Broadway Plaza developer(s), and likely other developers of Santa Ana residential projects are clients of the Firm, and Ms. Phan's duties as an associate attorney within the "Builders and Developers Team" includes representing developer clients and promoting the financial interests of the Firm, Ms. Phan's votes on the HOO created a nexus between her duties owed to the Firm and her duties owed to the public via the City Council. (Regulation 18702.3(b).) It takes little imagination to foresee a situation where a Firm client might directly, and significantly, benefit from certain changes to the HOO. Any Reasonably Foreseeable Financial Effect on the Firm met the Materiality Standard. Because there existed a nexus between Ms. Phan's duties to the Firm and its clients and to the City Council, any reasonably foreseeable financial effect on the Firm is deemed material. (Regulation 18702.3(b).) It was Substantially that Ms. Phan's Decisions would have a Financial Effect on the Firm. Upon information and belief, it was substantially likely that Ms. Phan's decisions would result in benefits to Centennial, the developer(s) of One Broadway Plaza, and potentially other Firm clients who have projects within the City. It is also substantially likely Ms. Phan's decisions could increase or enhance those clients' ties to and business with the Firm, or attract new clients to the Firm. As such, it was reasonably foreseeable at the time of the decision that the decision would have a financial effect on the Firm. III. Conclusion Based on the above, by making governmental decisions in which she had a financial interest, Ms. Phan violated Government Code Section 87100. As stated above, the only acceptable remedy is for the City Council to formally rescind its November 16, 2021 approval of the Housing Opportunity Ordinance and convene a new vote among eligible, non -conflicted members of the City Council.