FPPC staff proposes temporary and standing rules to extend Form 700 filing deadlines for officials affected by Southern California wildfires

Fair Political Practices Commission legal staff presented two draft regulatory options on Feb. 4 meant to address difficulties filing annual Statements of Economic Interests (Form 700) for officials affected by recent wildfires in Southern California.

General Counsel Dave Bambridge said legal staff prepared: (1) a narrowly tailored temporary regulation granting a calendar extension for officials with a primary residence, work location, or filing office in Los Angeles or Ventura counties; and (2) a broader regulatory approach that would give the commission chair authority to delay deadlines during statutory emergencies. Bambridge said the commission already has authority under statute to set the annual filing deadline by regulation, and both options are being noticed for public comment and Office of Administrative Law review.

Under the first option, staff proposed extending the April 1 filing deadline to June 1 for affected filers (the text as drafted used a fixed date to avoid ambiguity). Under the second option, the regulation would authorize the chair — within defined emergency parameters — to grant extensions that would become effective upon the chair’s order and then be reported to the full commission.

Commissioners debated which authority was preferable. Several committee members said they preferred having the full commission vote on extensions rather than delegating sole discretion to the chair, noting the commission can meet on short notice but that noticing rules may delay action. Commissioners also asked staff to be mindful of which filers the regulation would cover: most Form 700 filers are due April 1 (Government Code 87200 filers), but a discrete set of high‑level state officials and some agencies file in March (e.g., statewide elected officers, legislators, members of certain boards and commissions). Bambridge said the governor’s office may have authority to modify deadlines for some March filers in declared emergencies and that staff are coordinating with the governor’s office and affected filing offices.

The committee asked staff to: 1) reach out to affected jurisdictions (Los Angeles County, City of Los Angeles, Ventura County and other local filing officers) to document how fires have impaired officials’ and filing officers’ ability to prepare and transmit reports; 2) consider whether to include other counties (several commissioners mentioned monitoring any impacts in San Diego County); and 3) modify draft language to make a fixed effective date clear (e.g., using 06/01/2025 rather than “60 days”). Bambridge said the matter will be on the full commission agenda next week and that the regulation cannot take final effect until after Office of Administrative Law review unless adopted in an emergency manner previously used during the COVID pandemic.

No formal vote was taken at the committee meeting. Committee members agreed staff should solicit input from county and city filing officers and return to the full commission with refined regulatory language and recommended scope (chair authority vs. commission vote, counties covered, exact dates).