COI: Guidance for Designated Officials

The Political Reform Act requires certain government employees to disclose their personal assets and economic interests. The Conflict of Interest Code lists the job titles of those employees holding positions at the University requiring disclosure of personal financial information. These employees are known as Designated Officials.

Designated Officials are individuals who are in positions, which make decisions or participate in the making of decisions, which may have a material effect on their personal financial interests. Designated Officials are prohibited from participating in University decisions when personal financial interests may be affected by those decisions. Designated Officials must disqualify themselves from participating in a University decision when a financial conflict of interest is present.

Designated Officials must disclose financial interests and assets on Form 700. Disclosure statements are required on an annual basis, or when an individual assumes or leaves a position categorized as a Designated Official. The University assigns disclosure categories to these positions, and indicates the types of economic interests, which must be reported, such as investments, interests in real estate, and sources of income or gifts.

The University of California Conflict of Interest Coordinator located in the Office of the General Counsel sends the annual Form 700 to all Designated Officials through an electronic system. The UCSD Conflict of Interest Coordinator sends Form 700 through an electronic system directly to all UCSD employees who assume or leave a position categorized as a Designated Official. The University of California Conflict of Interest Coordinator is the University official responsible for receiving statements and placing them on file as public records.

The University of California provides detailed filing instructions for the Form 700. Designated Officials should review these instructions prior to filing their disclosure statements.

The UCSD Conflict of Interest Coordinator is available to assist Designated Officials with the filing requirements and with completing the Form 700.

Designated Officials are required to file as follows:

Assuming Office Statements:

• All UCSD employees assuming designated positions must file statements of financial interest within 30 days after assuming the designated positions, or if subject to confirmation by the UC Regents, 30 days after being nominated or appointed.
• Assuming Office Statements must disclose any reportable investments, interests in real property and business positions held on the date of assuming office or, if subject to confirmation or appointment by the UC Regents, on the date of nomination, and income received during the 12 months prior to the date of assuming office or the date of being appointed or nominated, respectively.

Annual Statements:

• All designated employees must file statements no later than April 1st.
• Annual statements must disclose any reportable investments, interests in real property, income and business positions held or received during the previous calendar year.

Leaving Office Statements:

• All persons who leave designated positions must file statements within 30 days after leaving office.
• Leaving Office Statements must disclose reportable investments, interests in real property, income and business positions held or received during the period between the closing date of the last statement filed and the date of leaving office.

Where do Designated Officials submit Form 700?

Effective 2018, Designated Officials will submit and complete their Form 700 through the electronic system. The University of California Office of the President will only accept Paper forms for Disclosers that are leaving the University.

For leaving forms only, the cover page must be signed and dated and sent with the completed Form 700 with original signature to:

UC Conflict of Interest Coordinator
1111 Franklin Street, 8th Floor
Oakland, CA  94607-5200

The sanctions for violations of the disqualification provisions of the Act (the Act) provides that violators are subject to administrative, criminal, and civil sanctions. In addition, persons violating an agency’s conflict of interest code are subject to disciplinary action. (Gov. Code, § 91003.5.) Persons violating the Act: 

• May be subject to monetary penalties imposed by the Fair Political Practices Commission;
• May be enjoined or compelled to comply with the provisions of the Act in an injunctive action brought by any person living in California;
• May be liable in a civil action; or
• May be prosecuted for a misdemeanor and, if convicted, fined.

The University of California has developed a Conflict of Interest Course for Designated Officials designed to help individuals identify and understand conflict of interest situations that may arise during the course of their University employment. This course was developed through UCOP with a UC vendor, Workplace Answers. Designated Officials will receive from UCOP a link via email to the required training when they first assume the position, and then every two years thereafter. The course can be taken on any computer with Internet access.

• California Fair Political Practices Commission
• University of California Conflict of Interest Code
• University of California’s Office of the General Counsel, Conflict of Interest
• University of California Personnel Policy for Staff Members – Conflict of Interest
• Designated Officials Guide to Honoraria (PDF), a flow-chart for honoraria
• Form 700: Common Questions and Errors