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Disclosing Financial Interests: Gifts

See financial interest reporting requirements for gifts.

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Overview

A Gift is the giving of research support to UCSD on the part of an entity donor with charitable intent and without consideration, in the form of cash, equipment, software or other similar support. Gifts are used to support a UCSD investigator's independent or collaborative research in general. Examples can include:

  • A company provides a gift of $50,000 to a UCSD investigator to support research in the general area of structural engineering.
  • A company provides a gift of software to a UCSD investigator for use in the research laboratory.
The University of California has issued a policy on Disclosure of Financial Interests and Management of Conflicts of Interest in Private Sponsors of Research as mandated by Fair Political Practices Commission.

Disclosure forms

700-U Form:

The State of California's Fair Political Practices Commission requires disclosure of financial interests by using the State of California's Statement of Economic Interest for Principal Investigators (PI), or the 700-U form. Keep in mind that all financial disclosures must also be updated during the entire period of the award, as new reportable significant financial interests occur.

The 700-U form must be filled out in its entirety by the PI who must disclose their financial interests as well as the financial interests of their spouse or registered domestic partner, and/or their dependent children.

Addendum:

If a positive financial interest is disclosed, meaning a conflict of interest may exist due to the information that was disclosed on the 700-U form, a conflict of interest Addendum form must also be completed by the PI. The Addendum provides the opportunity for the PI to more fully describe their financial interest and indicate whether that financial interest could directly and significantly affect the sponsored project.

Financial interests

Financial interests are the most important component or components of a conflict of interest for researchers. In broad terms, financial interests can be defined as anything of economic value; including a fiduciary relationship with the donor. Some examples include, but are not limited to:
  • Salaried or unsalaried positions with the donor
  • Scientific advisory board memberships
  • Vested or non-vested stock or stock options
  • Gifts
  • Loans
  • Travel reimbursements
  • Income received through honoraria or consulting

A financial interest refers to the direct financial relationship between the Principal Investigator (PI) and the gift donor or indirectly through their spouse, their registered domestic partner, or their dependent children. Some examples of this include:

  • Equity holdings in the donor
  • Management positions with the donor
  • Consulting income received from the donor
  • Honoraria received from the donor
  • Principal investigator's spouse or registered domestic partner being an employee of or having a financial interest in the donor

Types of financial interests

The Principal Investigator (PI) at UCSD must disclose their financial interests as well as the financial interests of their spouse or registered domestic partner, and/or their dependent children. In general terms, financial interests that must be disclosed for gift sponsored research can be separated into 6 main categories, and are only for activities that took place 12 months prior to the time of financial disclosure. These categories include, but are certainly not limited to:

Positions with the donor:

These can include positions as founder, partner, director, manager, officer, trustee, employee or any other position of management with the donor within the past 12 months.

Investments in the donor:

Investments in the donor, within the past 12 months, can include stocks, bonds, warrants, and stock options, including margin or brokerage accounts that have a value totaling $2000 or more.

Income from the donor:

Income received from the donor within the past 12 months, which can include salaries, consulting income, honoraria from speeches or other services that were performed, royalty payments, and stock dividends and/or interest earned, or the proceeds from any stock sales. In addition, income also includes compensation received by the University of California Health Sciences Compensation Plans.

Gifts from the donor:

Gifts from the donor, which includes the gift or the promise of a gift received from the donor of $50 or more, or multiple gifts from a single donor totaling $50 or more, within the past 12 months. Keep in mind that it is the acceptance of the gift, not the ultimate use of the gift, that imposes your obligation to disclose. Therefore, you must disclose the personal gift even if you never use it or even if you give it away to another person. If the exact amount of the gift is not known, you must make a good faith estimate of the item's fair market value. Some common examples of disclosable gifts include; tickets or passes to sporting or entertainment events, or amusement parks, parking passes, transportation and lodging, and forgiveness of a loan received by you from the donor.

Loans from the donor:

Loans from the donor require disclosure if the outstanding balance has exceeded $500 within the past 12 months. This also includes community property interest in loans received by the spouse or registered domestic partner.

Travel Reimbursements from the donor:

Travel reimbursement from the donor for travel expenses within the past 12 months, which includes per diem, payments for transportation, travel advances, lodging, and meals that were received from the donor.

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