FROM: Debby Cherney, Chief Executive Officer
SUBJECT: Updated Conflict of Interest Code
RECOMMENDATION:
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Adopt updated Conflict of Interest Code with current position identifications, and submit to the Board of Supervisors for approval.
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BACKGROUND:
The Political Reform Act (Government Code section 81000, et seq.) requires local government agencies, including SBCERA, to adopt and maintain a Conflict of Interest code (Code). SBCERA has determined that the individuals identified in the Code make or participate in decisions that may reasonable have a material effect on their economic interests. Accordingly, designated employees are required to file a Statement of Economic interest (Form 700) with the Secretary of the Board (Chief Executive Officer).
Effective January 1, 2026, Trustees, the Chief Executive Officer, the Chief Investment Officer, and all other employees classified as investment officers are designated as public officials who manage public investments. As such, they are required to file their Statements of Economic Interests directly with the Fair Political Practices Commission (FPPC).
The proposed revised Conflict of Interest Code reflects updated job titles, newly created positions, revisions to disclosure categories, and the removal of obsolete classifications. Staff recommends that the Board adopt the updated Conflict of Interest Code and direct staff to submit for approval to the “code reviewing body”, which for SBCERA is the San Bernardino County Board of Supervisors.
BUDGET IMPACT:
None.
STRATEGIC PLANNING GOAL/OBJECTIVE:
Operational Excellence & Efficiency
STAFF CONTACT:
Debby Cherney
ATTACHMENTS:
Exhibit A: Proposed Conflict of Interest Code with Redlines
Exhibit B: Proposed Conflict of Interest Code without Redlines