CITY OF GROVER BEACH
CITY COUNCIL STAFF REPORT
Agenda Item No. 4
Placement: Consent
Meeting Date: September 14, 2026
TO: Honorable Mayor and City Council
FROM: Matthew Bronson, City Manager
PREPARED BY: Wendi Sims, City Clerk
Jennifer Thompson, City Attorney
SUBJECT: Biennial Review of Conflict-of-Interest Code
RECOMMENDATION
Adopt the Resolution acknowledging there have been no substantial changes to the City’s organizational structured since 2024 which require the City’s Conflict of Interest Code to be amended.
BACKGROUND
The Political Reform Act of 1974 as amended requires every local government agency to review its Conflict-of-Interest Code by October 1 of even-numbered years and determine whether it is upto-date or in need of revision. The Conflict-of-Interest Code sets out those job classifications within the City that are decision-making positions, but are not among those positions mandated by State law to file Statements of Economic Interests (Form 700) pursuant to Government Code Section 87200.
As of January 1, 2025, Assembly Bill (AB) 1170 requires positions designated in Government Code Section 87200 (members of the City Council and Planning Commission, City Manager, City Attorney, and City Treasurer), to file statements directly with the FPPC through the State’s edisclosure filing system. This has been reflected in the proposed updated COI Code.
The City Council determines, with input from staff, what other job classifications entail the making or participation in the making of governmental decisions which may foreseeably have a material effect on any financial interest (Government Code Section 82019). Such designated positions would then be included in the City's Conflict of Interest Code. Individuals identified as holding those positions would be required to file Statements of Economic Interests directly with the City Clerk. There is no electronic online filing option for these designated positions.
The City’s Conflict of Interest Code was last updated in September 2024. Upon review, there have been no substantial changes to the City’s Conflict of Interest Code.
FISCAL IMPACT
There is no fiscal impact to this report.
Staff Report: Biennial Review of Conflict-of-Interest Code Page 2 September 14, 2026
ALTERNATIVES
The Council has the following alternatives to consider:
1. Adopt the Resolution acknowledging there have been no substantial changes to the City’s organizational structured since 2024 which require the City’s Conflict of Interest Code to be amended.;
2. Provide alternative direction to staff.
PUBLIC NOTIFICATION
The agenda was posted in accordance with the Brown Act.
ATTACHMENTS
1. Draft Resolution regarding Conflict-of-Interest Code for the City of Grover Beach, Exhibit A - designated employees / classifications
Multi-Year Goals
☐ Public Safety and Community Services ☐ Economic Development and Housing ☐ Community Infrastructure ☐ Financial and Organization Sustainability Council Priorities
☐ Water & Wastewater Infrastructure ☐ Community Engagement ☐ Street Improvements and Maintenance
RESOLUTION NO. 26-__
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF GROVER BEACH,
CALIFORNIA, ADOPTING AN AMENDED CONFLICT OF INTEREST CODE
CONTAINING REVISED DESIGNATED FILERS
WHEREAS, the Political Reform Act of 1974, California Government Code Sections 87300 et. seq., requires that governmental entities in the State of California adopt and promulgate Conflict of Interest Codes; and
WHEREAS, said Act requires that local governmental entities include within the provisions of Conflict-of-Interest Codes certain employees, commissioners, and committee members who make or participate in the making of decisions which may foreseeably have a material effect on financial interests; and
WHEREAS, a Conflict of Interest Code adopted pursuant to the Political Reform Act consists of two basic parts, which are: (1) the body of the code which contains the basic provisions including the manner of reporting financial interests and the procedure for filing Statements of Economic Interests, and (2) the Appendix of the Code which lists the positions of designated filers of the agency and the corresponding disclosure categories for each position; and WHEREAS, The Fair Political Practices Commission (“FPPC”) has adopted a standard model Conflict of Interest Code codified in California Code of Regulations, Title 2, Section 18730 (“Section 18730”), containing the provisions for the body of a Conflict-of-Interest Code which may be incorporated by reference by the City as the City’s Conflict of Interest Code; and WHEREAS, incorporating Section 18730 by reference, as the body of the City of Grover Beach's Conflict of Interest Code, will ensure compliance with state law by automatically incorporating any changes to the financial disclosure provisions of the Political Reform Act and Section 18730; and
WHEREAS, the Fair Political Practices Commission gives notice of all changes to Section 18730, and the City would be given an opportunity to comment on the changes before adoption by the Commission; and
WHEREAS, there have been no substantial changes to the City’s organizational structured which require the Conflict of Interest Code to be amended; and WHEREAS, the City Council has determined that the attached Appendix, contained in “Exhibit A" and “Exhibit B", accurately sets forth those classifications which should be designated and categories of financial interest which should be disclosed.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Grover Beach as follows:
1. The terms of California Code of Regulations, Title 2, Section 18730, duly adopted by the Fair Political Practices Commission, are hereby incorporated by reference and with the attached Appendix shall constitute the Conflict-of-Interest Code of the City of Grover Beach.
2. Persons holding designated job classifications as set forth in “Exhibit A” and disclosure categories as set forth in “Exhibit B” shall file Statements of Economic Interests (Form 700) with Attachment 1
Resolution No. 26-__ Page 2
the City Clerk of the City of Grover Beach pursuant to California Code of Regulations, Title 2, Section 18730.
Upon motion of Council Member, seconded by Council Member, and on the following rollcall vote, to wit:
AYES: Council Members –
NOES: Council Members –
ABSENT: Council Members –
ABSTAIN: Council Members –
the foregoing Resolution was PASSED, APPROVED, and ADOPTED this 14th day of September 2026.
_______
KASSI DEE, MAYOR
ATTEST:
WENDI B. SIMS, CITY CLERK
Resolution No. 26-__ Page 3
City of Grover Beach
CONFLICT OF INTEREST CODE
The Political Reform Act (Government Code Section 81000 et. seq.) requires state and local government agencies to adopt and promulgate conflict of interest codes.
The Fair Political Practices Commission has adopted a regulation, 2 California Code of Regulations Section 18730, that contains the terms of a standard conflict of interest code, which can be incorporated by reference in an agency's code. After public notice and hearing, the standard code may be amended by the Fair Political Practices Commission to conform to amendments in the Political Reform Act.
Therefore, the terms of Title 2 of the California Code of Regulations, Section 18730 and any amendments to it duly adopted by the Fair Political Practices Commission are hereby incorporated by reference. This regulation and the attached Appendix, designating positions and establishing disclosure categories, shall constitute the conflict-of-interest code of the City of Grover Beach.
Designated employees, committees, commissions and consultants shall file statements of economic interests with the City Clerk of the City of Grover Beach who will make the statements available for public inspection and reproduction (Gov. Code Section 81008).
Positions designated in Government Code Section 87200 (member of the City Council, Planning Commission, City Manager, City Attorney, and City Treasurer/Finance Director) shall file their statements directly with the Fair Political Practices Commission through the State’s edisclosure filing system. Statements of all other designated positions will be retained by the City Clerk in accordance with State Law.
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154 S. 8th Street ❖Grover Beach, CA 93433 ❖(805) 473-4567 ❖ [email protected] Visit our website at www.groverbeach.org
Resolution No. 26-__ Page 4
APPENDIX - EXHIBIT A
LIST OF DESIGNATED EMPLOYEES PER POSITION
Designated Employee / Board or Committee Member of the City Disclosure Category
1. Financing Authority Board Members A, B, C
2. Police Chief A, B, C
3. Administrative Services Director A, B, C
4. Community Development Director A, B, C
5. Public Works Director/City Engineer A, B, C
6. Assistant City Manager A, B, C
7. Senior Engineer A, B, C
8. Capital Improvement Project Manager A, B, C
9. Police Commander A, B, C
10. Senior Planner A, B, C
11. City Clerk A and C
12. Finance Manager A and C
13. Information Technology Specialist A and C
14. Building Official (contract services) A, B, C
15. Associate Planner A, B, C
16. Parks, Recreation & Beautification Commission A, B, C
17. Citizen Oversight Committee Members A, B, C
18. City Engineer A, B, C
19. Assistant City Attorney (contract services) A, B, C
20. Consultants1
Determined on case-by-case basis
1Consultants shall be included in the list of designated employees and shall disclose pursuant to the broadest disclosure category in the code subject to the following limitation: The City Manager may determine that a particular consultant, although a "designated position," is hired to perform a range of duties that is limited in scope and thus is not required to fully comply with the disclosure requirements described in this section. Such written determination shall include a description of the consultant's duties and, based upon that description, a statement of the extent of disclosure requirements. The City Manager's determination is a public record and shall be retained for public inspection in the same manner and location as this conflict-of-interest code.
Resolution No. 22-__ Page 5
EXHIBIT B
CATEGORIES OF DISCLOSURE FOR
DESIGNATED EMPLOYEES
The following shall be the categories of disclosure covered by this Policy; A. Investments
Schedules A-1 and A-2
B. Interests in Real Property
Schedule B
C. Income & Business Positions
Schedule C, D, and E
The officials and employees covered by this policy shall each disclose the categories A, B, and C as designated herein above set forth.