December 7, 2022 Notice: Important Form 700 Year End Reminders & Updates

Departmental Filing Officer:

cc: Department Head

Subject:  Important Form 700 Year End Reminders & Updates

This communication contains important information for departmental filing officers and serves as a reminder of year end filing officer responsibilities. It also provides updates regarding upcoming tasks associated with the Conflict of Interest Code amendment and activities leading up to the annual Form 700 filing deadline.

YEAR END FILING OFFICER RESPONSIBILITIES
  • Ensure that all designated employees/consultants (“designated filers”) that occupy positions in your department’s section of the Conflict of Interest Code have an active NetFile user account and that their information is correct in the NetFile system (i.e., contact information, position, and status) by December 30, 2022.
  • Designated filers who left City employment in 2022 should have electronically filed a leaving office statement using the NetFile system within 30-days of leaving their position. If the filer transferred to another designated position within the City and County of San Francisco within 30-days, an interdepartmental transfer should have been completed in the NetFile system. See ‘Offboarding a Form 700 Filer’ and ‘Late Filer Procedures’ sections in the Filing Officer Manual for step-by-step instructions.
  • For a complete list of year end responsibilities, see ‘Year End/Ongoing Filing Officer Responsibilities’ section on the Filing Officers web page.
UPDATE REGARDING BIENNIAL CONFLICT OF INTEREST CODE AMENDMENT

The legislative process for Conflict of Interest Code (“code”) amendments submitted by departments in August is currently underway at the Board of Supervisors (BOS). We anticipate the amended code will be approved and adopted by the BOS in mid- to late- January, and become effective 30-days thereafter. Following its adoption Ethics Commission staff will spend several weeks modifying positions and disclosure categories in the NetFile system to reflect the newly amended code.

After changes have been added to the NetFile system, the following tasks will need to be completed within approximately 2 weeks:

  • Create NetFile User accounts for newly designated filers who’s positions have been added to the code, and notify those filers of their assuming office filing requirements. (Note that the assuming office date for these filers is the effective date of the amended code. Filers will have 30-days from the effective date to file their assuming office statements).
  • Perform intradepartmental transfers for any current filers transferring to new positions within the same department. See Filing Officer Manual, page 15.
  • For positions that are removed from the code, Ethics Commission staff will terminate the NetFile user accounts of existing designated filers who’s positions were removed, and will directly notify those filers of their leaving office filing requirements. (Note that the leaving office date for filers who’s positions are removed from the code is the effective date of the amended code. Filers will have 30-days form the effective date to file their leaving office statements).
  • More information to follow upon adoption of the amended code.
2023 ANNUAL FORM 700 FILING EVENTS TIMELINE
  • Information Sessions for Filing Officers and Form 700 Filers will be conducted in February and March 2023. Dates to be announced and published online in January ‘23.
  • Ethics Commission staff will disseminate Annual Filing Notices to all designated filers with an active NetFile user account during the first week in February ’23.
  • Annual Filing Deadline: Monday, April 3, 2023
OTHER IMPORTANT REMINDERS
  • Ensure your departmental filer list stays accurate and up-to-date by updating filer information in the NetFile Admin System on a regular basis, especially when filers assume office and assume office.
  • Coordinate closely with your hiring managers and/or HR team to be informed timely of personnel changes such as promotions, transfers, acting and interim assignments, and resignations, that may also affect your list of designated filers.
  • Notify filers promptly of their filing requirements and deadlines. For your convenience, sample filer notices are available on the Filing Officers web page under
  • Remember to execute late filer procedures for all filing events: annual, assuming office, leaving office. For more info see our Filing Officer Manual, page 32.
  • After two written attempts to obtain compliance, refer non-filers to the Ethics Commission’s Enforcement Division. See Filing Officer Manual, page 32.
  • Several short “how-to” video tutorials have been produced by our staff to demonstrate how to perform various specific tasks in the NetFile Admin System. These “NetFile How-to Video Tutorials” can be linked directly here and can also be accessed through the Filing Officers web page under the section entitled ‘Resources for Filing Officers.’
  • Sample Form 700 Filer Notices modified to include disqualification language applicable to members of boards, commissions, and other committees that hold meetings and are comprised of uncompensated Form 700 filers. See Campaign and Governmental Conduct Section 3.1-102.5(c) for additional information.

More information and resources for filing officers are available at the Ethics Commission’s website. As always, we encourage you to submit Form 700-related questions to the Ethics Commission’s Form 700 Portal for the most timely assistance.

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