Contractor/Subcontractor
Transparency Ordinance
Study Session September 9, 2025
PRESENTATION BY:
Brian Mohan, City Manager
• The Center for Contract Compliance (“CCC”) works with local, state, and federal agencies to combat the underground
economy. In this collaborative effort, the CCC provides information and resources to ensure law-abiding contractors can bid on a level playing field for public works contracts • The CCC focuses on issues related to prevailing wage, meal and rest periods, travel and subsistence, safety, apprenticeship, contractor licensing, and workers compensation premium fraud • The CCC is committed to outreach and education, and provides information to workers, employers, and public agencies without cost
Background 2
In working with the Inland Empire Labor Council, the City of Moreno Valley can take a more active role in combating the underground economy and upholding State labor standards in Moreno Valley by updating our verification requirements for contractors and subcontractors of large projects in the city and keeping record of all contractors and subcontractors throughout the duration of the project
Background 3
• Currently, applicants must submit a General Contractor’s Statement that requires subcontractors to be validated through the Business License Division § 5.02.320 Duty to certify general contractor's statement. • Every person acting as a general contractor, whether building for their own occupancy or not, shall file with the collector a full, true and complete written statement, signed by such person, under penalty of perjury, listing all subcontractors who have performed or shall perform any service whatsoever for such person within the city. The statement shall include the name, address and telephone number of each subcontractor. Any builder-owner, general engineering contractor, specialty contractor or subcontractor, subcontracting any work shall be deemed a general contractor for the purpose of this section
Background 4
This process can be strengthened to better identify potential bad actors and ensure a transparent process through:
• Creating General Contractor’s Statement template for uniformity of reporting information
• Updating the time of reporting
• Identifying a reporting threshold
• Requiring reporting of past labor violations
• Codifying requirements for incomplete reporting
• Violations for not reporting information
Strengthening the Process 5
• Time of reporting: Must report prior to permit issuance • Reporting Threshold: Exempt smaller projects, only
developments with 20+ units or commercial/industrial of 20,000 square feet or more
• Reporting of labor violations: Add requirement for reporting any past or present/pending labor violations as defined by the California Labor Code
Possible Changes 6
• Incomplete reporting: Currently not clear what happens when someone provides an incomplete report. This ordinance will clarify that applicants will have a reasonable period of time after issuance of each permit, but prior to commencement of any associated work to finish an incomplete report
• Violations/Enforcement: Multiple remedies:
1. Stop work order
2. Revocation of permit
3. Penalty fee equal to cost of original permit fee in order to defray city costs of enforcement of this section prior to the issuance of any new permit
Possible Changes 7
• Continue to work with Inland Empire Labor Council on detailing the possible changes
• Engage the development and business community for awareness and stakeholder buy-in
• Return to Council in November/December for introduction and, if approved, subsequent adoption of the ordinance
Next Steps 8
Questions 9
Questions?