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State law requires all public officials to disclose personal financial interests by filing Form 700. A conflict of interests (COI) code is a document that identifies which public officials must disclose personal financial interests and specifies the types of interests that each public official must publicly disclose.

COI codes and the disclosure they govern help City officials monitor their financial interests and avoid participating in government decisions that might affect those interests. They also help to assure the public that the City’s decision makers are acting in the public’s best interest.

Each position that has the authority to make or participate in making City decisions must be identified as a City official in a department’s COI code. All officeholders, commissioners, and department heads are City officials. Other employees and consultants may also be City officials.

The disclosure required for each City official varies, depending on the position. In general, the more decision-making authority a City official has, the greater the detail the City official will have to disclose about personal finances.

Each COI code is reviewed by the department, the Ethics Commission, and the City Attorney’s Office before being sent to the City Council for final approval. Each COI code has three sections:

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    Incorporation and Certification

    This section, formerly known as the Main Code Body, identifies laws regarding financial disclosure and conflicts of interests and is the same for all departments.  A sample of the Incorporation and Certification that applies to each Conflict of Interests Code can be viewed here.

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    Schedule A

    Schedule A lists the positions in each department that are considered City officials, as defined by law.  Each position is listed along with a number, which is its disclosure category (defined in Schedule B).  Persons who occupy positions listed on Schedule A are required to file Form 700.

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    Schedule B

    Each position listed in Schedule A is assigned a number that corresponds with its disclosure category.  Schedule B defines each disclosure category by describing the types of financial interests that must be disclosed (reported) on a Form 700.

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