To comply with the Political Reform Act (reform act), the city should ensure that the city administrator and city clerk are appropriately trained to administer its conflict-of-interest code (conflict code).
Vernon's current Interim City Clerk is a principal of Reed & Davidson, the firm retained by the City in May 2011 to review the City's conflict of interest codes and assist in the preparation of necessary amendments and new codes, as well as provide all compliance-related training. Among other governmental ethics and election compliance-related matters, Reed & Davidson specializes in conflicts of interest compliance, including the preparation and filing of statements of economic interests (Form 700s). On November 20, 2012, upon the recommendation of the Interim City Clerk, the City Council adopted an amended Conflict of Interest Code for the City of Vernon (Resolution No. 2012-225), establishing the "designated positions" required to file Form 700s along with the respective disclosure categories for each, requiring the City Administrator to determine which City consultants (beyond those filling a designated position), if any, are required to file Form 700s, and delegating the City Clerk as the Filing Officer responsible for receiving, retaining, and making available for public inspection all required Form 700s. As of April 2013, all City employees and consultants filling designated positions, and all ten other consultants determined by the City Administrator to perform a range of duties requiring disclosure under the City's Conflict of Interest Code have filed their required Form 700s for calendar year 2012. Additionally, of the 35 individuals who retired in January and June 2013 under the City's Early Retirement Incentive Program, eight (8) were required to file Form 700s, and all timely filed their respective Leaving Office Forms, or have been reminded of their filing obligations in the case of more recent retirees.
The city council approved the appointment of a consultant as the acting city clerk. The consultant—previously hired to review the city's conflict of interest codes and assist in necessary amendments and new codes and training—is experienced in this area and will continue with the administration and enforcement of the city's conflict of interest codes.
The city did not address this recommendation in its August 2012 response. (See 2013-406, p. 194)
Agency responses received after June 2013 are posted verbatim.