The Deadline to File Annual Statements of Economic Interest (“Form 700”) has been Extended from April 1 to June 1, 2020

March 30, 2020

As the ongoing Coronavirus (“COVID-19”) pandemic continues to impact all of us, charter school board members and employees should be aware of changes the Fair Political Practices Commission (“FPPC”) has recently announced regarding the filing of Statements of Economic Interest (“Form 700”) and adopting Conflict of Interest Codes.

Filing Deadline for the Form 700 Extended
Due to the current COVID-19 pandemic, late Friday last the FPPC announced an extension of the filing deadline for those individuals required to file a 2019 annual Form 700 by sixty (60) days. This two-month extension means a Form 700 that would be normally due on April 1 will be accepted by the Commission as timely until June 1, 2020. The extension will apply to all officials required to file in April pursuant to Commission Regulations 18723 and 18739. The FPPC intends to formally ratify this extension at its April 2, 2020, special meeting.  

The FPPC still encourages filers to file when they can, as soon as they are able. Those who have access to an electronic Form 700 filing system are encouraged to take advantage of its use. If electronic filing is not available, filers can submit the Form 700 by mail. Statements postmarked on or before June 1, 2020, will be considered filed on time.

Charter Schools in Los Angeles County May Adopt its Own Conflict of Interest Code
Senate Bill 126 created Education Code Section 47604.1, effective January 1, 2020. Education Code Section 47604.1(b)(4)(B) states that “… a charter school and an entity managing a charter school shall be considered an agency and is the most decentralized level for purposes of adopting a conflict-of-interest code.” In Advice Letter A-19-239 dated Jan. 21, 2020, the FPPC determined that the question of “whether each charter school must adopt a separate code or an entity that manages charter schools may adopt one code for all of its charter schools, shall be resolved by the County of Los Angeles as the code reviewing body.”

This means that charter schools in Los Angeles County, that have previously adopted “bridge” Conflict of Interest Codes required by their authorizing district, may now adopt their own Conflict of Interest Code to be approved by the Los Angeles County Board of Supervisors. Where multiple charter schools are managed by a single entity, the Los Angeles County Board of Supervisors shall determine whether each charter school or the charter management organization is required to adopt a Conflicts of Interest Code.

Charter school board members and staff that need general assistance in filling out the Form 700 can contact Wayne Strumpfer (wstrumpfer@mycharterlaw.com) or (916) 646-1400. Wayne is the former Executive Director at the FPPC and can answer your questions. Charter Schools in Los Angeles County that would like to adopt their own Conflict of Interest Code can also contact Wayne for guidance.

Young, Minney & Corr, LLP’s Legal Alerts provide general information about events of current legal importance; they do not constitute legal advice. As the information contained here is necessarily general, its application to a particular set of facts and circumstances may vary. We do not recommend that you act on this information without consulting legal counsel.