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FPPC considers clarifying who must file expanded SEI forms for officials with multiple positions
Summary
The commission reviewed proposed amendments to Reg. 18723.1 that clarify when officials may file a single expanded Statement of Economic Interests and which agencies receive filings, and proposed that elected state officers need only file for their state elected position.
At its June 18 meeting the Fair Political Practices Commission held a pre-notice discussion of proposed amendments to Regulation 18723.1, which governs expanded Statements of Economic Interests (SEIs) for public officials who hold multiple positions.
Senior Commission Counsel Joanna Gin explained that an "expanded statement" allows a public official with multiple reportable positions to file a single consolidated Form 700 listing all positions and reportable interests rather than separate statements for each office. The proposed amendments would clarify which positions must appear on the expanded statement, how to determine the "primary position," and which filing officer should receive the document.
One substantive change in the draft would explicitly allow elected state officers to file only for their state elected position and omit listing additional positions in the expanded statement when the elected position triggers the broadest level of disclosure. Gin explained that the rule already applied in practice for "statewide elected officers" and the proposal would extend that clarity to include legislators.
Commissioners asked for the rationale and implementation details. Commissioner Wilson pressed whether a one-stop expanded filing for the broadest jurisdiction could be extended to reduce the administrative burden on clerks and filers when officials serve on multiple local boards. Gin and staff said the draft follows model regulations and that the agency would consult the SEI and IT units and local filing officers about implementation options before adoption.
Staff signaled they would return at adoption (planned for August) with additional examples and coordination with filing officials and the IT unit to ensure notice, access, and appropriate filing workflows.
If adopted, the amendments would clarify how officials with overlapping jurisdictions report economic interests and could reduce duplicate filings for some multi-position officials while preserving the public record of required disclosures.
