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Conflict of Interest

The California Political Reform Act of 1974 requires CSU, as an agency, to adopt and communicate Conflict of Interest (COI) codes. The Act contains a general prohibition against conflicts of interest. Conflict of Interest law seeks to minimize the extent to which public employees pursue their own financial interests at the expense of the public interest.

Under the Act, no CSU employee shall make, participate in making, or attempt to use his or her official position to influence a CSU decision in which he or she has a financial interest. University employees shall not vote, make recommendations, or in any way participate in personnel or financial decisions if such participation constitutes a conflict of interest.

The Division of Business and Administrative Services administers this Conflict of Interest process on behalf of CSU, Bakersfield.

 

Form 700 Introduction

The Political Reform Act requires certain state employees and officials who serve in positions designated in an agency's conflict-of-interest code to file a Statement of Economic Interest (Form 700). Most "designated positions" at CSUB have some fiscal responsibility (for example, the ability to purchase items using state funds).

CSUB Designated Positions

When to File

NEWLY APPOINTED

Employees appointed into a designated position or COI Interim position must file a Statement of Economic Interests Form 700 within 30 days of the appointment date, as well as take an online CSU COI Training course within 6 months of their appointment date and every two years thereafter. This is web-based training and may be taken through CSU Learn. The Training System will automatically remind you to complete this training every two years.

ANNUAL FILING

Employees in a designated position or COI Interim position must file an annual Statement of Economic Interests Form 700 by approximately April 1st of each year.

Exception:

If you assumed office between October 1, 2024 and December 31, 2024 and filed an assuming office statement, you are not required to file an annual statement until April 2026.

LEAVING OFFICE

When an employee leaves their designated position or COI Interim position they must file a Statement of Economic Interests Form 700 within 30 days of leaving office.

Form 700 Filing Instructions

STEP 1

Watch Form 700 Tutorial - understanding what to report by the CSU Chancellor's Office (10 min).

STEP 2

Watch eDisclosure's Form 700 overview for filers by SouthTech to understand how filers will use the electronic Form 700 filing system (5 min).

STEP 3

Look for an email from Form700.CSU@southtechhosting.com providing information about your filing requirements and a link to file your Form 700 electronically.

Resources

  • 2024-2025 Statement of Economic Interests Form 700 (Statement of Economic Interests Fillable Form and Schedules begin on page 5)
  • Form 700 Tutorial - understanding what to report by the CSU Chancellor's Office (10 min)
  • Form 700 Amendment 2024-2025
  • CSU Disclosure Categories
  • CSUB Designated Positions
  • 2024-2025 Form 700 Statement of Economic Interests Reference Pamphlet
  • Frequently Asked Questions: Form 700 Disclosure (Rev. 10/2024)
  • Limitations and Restrictions on Gifts, Honoraria, Travel and Loans
  • Late Fine Guidelines

 

Possible Late Fee Enforcement

Employees are subject to a $10 per day, per position fine up to a maximum of $100 for the late filing of a Statement of Economic Interests Form 700 (Government Code Section 91013). In addition, the President/Chancellor may be notified of the late filers. Employees who fail to file a Form 700, or fail to disclose material interests may be subject to a personal penalty. Penalties include disciplinary action against the employee, as well as potential civil and criminal penalties. Violations of the Conflict of Interest Code are addressed in the Conflict of Interest Handbook, prepared by the Office of General Counsel.

Late Statements

There is no provision for filing deadline extensions unless the filer is serving in active military duty. (See page 20 for information on penalties and fines.) Amendments Statements may be amended at any time. You are only required to amend the schedule that needs to be revised. It is not necessary to amend the entire filed form. The amended schedule(s) is attached to your original filed statement. Obtain amendment schedules at www.fppc.ca.gov. Filers authorized to file electronically amend their statements using their agency’s electronic filing system. 

 

Gifts to Agency Reporting /Ceremonial Role Events and Ticket/Pass Distributions (HR 2014-14)

In addition to the administration of the annual filing of Statement of Economic Interests forms by designated positions, the University is required to report Gifts and Tickets/Admissions to Events given to the agency. The gift limit has increased to $630 for calendar years 2025 and 2026.

GIFTS TO AGENCY REPORTING

This form is for use by all state and local government agencies to disclose payments made to the agency when the payments provide a personal benefit to an official of the agency. Examples may include travel, meals or other benefits. Under certain circumstances, these payments will not result in a gift to the official, but will be considered a gift to the agency. The payments must be used for official agency business and must meet other requirements that are set out in FPPC Regulation 18944.2.

Form 801 is used to report certain payments received by state and local government agencies that are used for agency purposes and paid by a third party. FPPC Regulations 18944 and 18950.1 provide a procedure that agencies may use to disclose these payments, which may include a payment for an official’s travel expenses for the purpose of facilitating the public’s business in lieu of using agency funds; and a payment that would otherwise be considered a gift or income to the benefiting official, but is instead accepted on behalf of the agency.

Form 801 - Payment to Agency Report

CEREMONIAL ROLE EVENTS AND TICKET/PASS DISTRIBUTIONS

This form is for use by all state and local government agencies to disclose the distribution of tickets or passes that allow admission to facilities, events, shows, or performances for entertainment, amusement, recreational, or similar purposes. The agency must complete Form 802 identifying agency officials who receive tickets or passes from the agency as well as other individuals and organizations that receive tickets or passes at the behest of agency officials. Further information regarding this reporting requirement are set in FPPC Regulation 18944.1.

FPPC Regulation 18944.1 sets out the circumstances under which an agency’s distribution of tickets to entertainment events, sporting events, and like occasions would not result in a gift to individuals that attend the function. In general, the agency must adopt a policy which identifies the public purpose served in distributing the admissions. The Form 802 serves to detail each event and the public purpose of each ticket distribution.

Form 802 - Reporting Ceremonial Role Events and Ticket/Admission Distribution

Additional Designated Positions

PROCARD HOLDERS APPROVING OFFICIALS

All ProCard Holders Approving Officials (PCHAO) will be considered the authority to make discretionary purchasing decisions. Therefore, these administrators will be identified as a designated employee required to file a COI form 700 within 30 days of the appointment date, as well as take an online CSU COI Training course within 6 months of their appointment date and every two years thereafter.

CONSULTANTS

Consultants who meet the following criteria must file Form 700:

  • A consultant authorized and hired to make a CSU decision on behalf of the institution.
  • A consultant hired to influence a CSU decision, whose input is not independently reviewed.
  • A consultant hired to work on an ongoing basis for a year or more, in a position that otherwise would be designated and require a CSU employee to file a Form 700.
  • A consultant who provides investment advice. The above consultants are retained through the procurement process on each campus.
     

The above consultants are retained through the procurement process on each campus.

FORM 700-U REQUIREMENTS FOR PRINCIPAL INVESTIGATORS

Employees with principal responsibility for a research project funded or supported, in whole or in part, by a contract, grant or gift (or other funds earmarked by the donor for a specific research project or for a specific researcher) from a nongovernmental entity, shall be designated employees subject to the disclosure and disqualification requirements of the CSU Conflict of Interest Code. Principal Investigators are designated under Disclosure Category 4 and have distinct requirements for disclosure of financial interests. Disqualification shall not be required in connection with any decision if the decision is substantively reviewed by an independent committee established within CSU. (Refer to Sponsored Programs Administration: Conflict of Interest for Principal Investigators for further definitions.)

Principal Investigators (PIs) required to file a Form 700-U are employees with principal responsibility for a research project funded or supported, in whole or in part, by a contract, grant or gift (or other funds earmarked by the donor for a specific research project or for a specific researcher) from a nongovernmental entity. 

The 700-U disclosure process for PIs differs from the Conflict of Interest filing requirements of other Form 700 filers.  As a result, responsibility for the oversight and administration of the Conflict of Interest policy for PIs is shared between Human Resources and Sponsored Programs Administration.  As such, the Conflict of Interest policy for PIs is set forth both here and the Sponsored Programs Administration: Conflict of Interest for Principal Investigators. 

There is no “annual” filing requirement for PIs; however, Title 2 of the California Code of Regulations requires PIs to file a Form 700-U (Statement of Economic Interests for Principal Investigators) before the final acceptance of a contract, grant or gift for a research project from a non-governmental entity, and within 30 days of renewal of the contract, grant or gift. 

PIs must complete the ethics training within six (6) months of receiving the grant.  Subsequent training is required at least once within each two-calendar year period that the contract, grant or gift is in place.

For additional information regarding PIs and their filing requirements, please see the Sponsored Programs Administration: Conflict of Interest for Principal Investigators

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Need Help?

Ivonna Edkins
COI Filing Coordinator
(661) 654-2265
ddiaz@csub.edu

Kristen Watson
COI Filing Officer
(661) 654-3206
lblodorn@csub.edu

Fair Political Practices Commission (FPPC)
FPPC Website
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1-866-ASK-FPPC (1-866-275-3772)

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Office Location:
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9001 Stockdale Highway
Bakersfield, CA 93311-1099

Email: hr@csub.edu
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