Departmental Filing Officers:
Thank you for submitting your worksheets confirming your Form 700 designated filers last week. This was a critical step in the transition to electronic filing (“e-filing”) beginning January ’22 for your designated filers who presently file on paper. My office is in the process of reviewing and validating information you’ve provided, and may be in touch with you in the coming days should we have questions or require clarification.
Additionally, we’d like to take this opportunity to answer a few of the questions that some of you have sent in, as well as, provide additional clarification pertaining to positions that are not presently designated in the City’s Conflict of Interest Code (“ COI Code”):
Q: Can departments add filers who occupy positions that are not presently listed in the COI Code?
No. Filers who occupy positions that are not currently identified in your departmental conflict of interest code will not be included in the import to the e-filing system (“NetFile”). Submitted worksheets that include non-code positions/filers, or positions who already e-file with the Ethics Commission (e.g., department heads and board/commissioners) will be excluded prior to import.
Please note: Amending the COI Code – including adding and removing positions, and changes to position titles – is a legislative process that occurs biennially (or every other year). The review period is initiated by the Board of Supervisors Clerk of the Board generally via a notice disseminated to all department heads. The next biennial review period will kick-off in Spring/Summer of 2022. Departments who wish to make changes to their departmental COI Code will do so during the biennial review period. The NetFile system will contain positions currently designated in the COI Code. The system will be updated following the effective date of future COI Code amendments.
Q: Will employees who file Form 700s as a requirement of Prop Q authority begin e-filing in January?
No. Departments should consider adding these positions to the COI Code during the next biennial review period. Until such time, Prop Q filers will continue to file on paper with their respective departments.
Q: What if departments have changes to filers as a result of personnel changes between now and December 31, 2021?
As designated filers will continue to file assuming/leaving office Form 700 statements on paper through December 31, 2021, for now it is recommended that filing officers maintain a log for staff/consultants who assume or leave designated positions after September 15, 2021. Your log should include the name, DSW number and email address of the filer, the designated position occupied (as listed in the COI Code), and their assuming or leaving office date. The log should also include individuals occupying designated positions in an Acting or Interim capacity, as these individuals must file Form 700s while they are serving in the position. We will provide further guidance to filing officers prior to the January launch date.
Q: Will Filing Officers receive training before January ’22?
Yes, training will be mandatory for all designated filing officers. Ethics Commission staff is currently developing eLearning modules that will be available in the City’s learning management system, SF Learning, later this year. All designated filing officers will be auto-enrolled in the required training modules and subsequently notified of their enrollment status via email. All filing officers who were added in response to our July 15th notice, will be enrolled in the training. Departments can make changes to their filing officer designations at any time by submitting the Department Contact Change Form. All current and future filing officers will be required to fulfill the training requirement before acquiring accessing to the NetFile Admin system.
As a reminder, the following roles and general responsibilities will continue to apply in the transition to electronic filing:
IMPACTED
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- Designated Filers – Persons who occupy positions designated in the conflict of interest code sections 3.1-103(d) and 3.1-108. Your department is the official filing officer for persons who occupy these positions. Beginning January 1, 2022, these filers will e-file their Form 700 statements.
- Filing Officer – The Department Head or the Executive Director of the City department/agency is the official filing officer for “designated filers.” Filing officer responsibilities are generally delegated to department staff. Beginning January 1, 2022, designated filing officers will have new and expanded online tools for managing your department’s designated filers and their Form 700 filings in the NetFile e-filing system. See Filing Officer FAQ for more information.
NOT IMPACTED
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- City Officers – Elected Officials, Department Heads, and Members of Boards and Commissions designated in the conflict of interest code section 3.1-103 (a) and (b). The Ethics Commission is the official filing officer for persons who occupy these positions. City officers have e-filed their Form 700s since 2014 and there are no changes as a result of the e-filing expansion.
- Filing Liaison – Filing liaisons play an important central role as the intermediary between “City Officers” (who file Form 700s with the Ethics Commission) and Ethics Commission staff. The Ethics Commission is the official filing officer for City Officers. The filing liaison role will not change as a result of the e-filing expansion.
Thank you for your continued collaboration. Please feel free to contact us with any questions.
Sincerely,
Rachel Gage
Engagement & Compliance Manager
San Francisco Ethics Commission
415-252-3100 | sfethics.org