On February 4, in response to the Los Angeles wildfires, Governor Newsom signed Executive Order N-17-25 to extend a panoply of deadlines and put several state law requirements on hold, including extending the filing deadlines by 60 days for public officials in Los Angeles County to file:
- Behested Payments Reports;
- Assuming Office Statements of Economic Interests; and
- Leaving Office Statements of Economic Interests.
This 60-day relief applies to any report which would otherwise be due on or before April 1, 2025.
Behested Payments Reports
Under California law, a public official who fundraises or solicits payments for a civic or charitable organization may be required to publicly disclose the payment by filing the Form 803 with the public official’s agency. Generally speaking, a payment is considered “behested” and must be reported if:
- the payment was made “at the request, suggestion, or solicitation of, or made in cooperation, coordination or concert with the public official”;
- is made for a legislative, governmental or charitable purpose; and
- the payment equals or exceeds $5,000 per calendar year from a single source.
Once the $5,000 threshold is met, state law requires the public official to file a report within 30 days disclosing the source and recipient of the payment, the amount of the payment, and a brief description of the payment. However, with the adoption of Executive Order N-17-25, city, county and state public officials located in Los Angeles County now have an additional 60 days to file this report. This 60-day extension for Behested Payment Reports should be very impactful given the number of civic and charitable fundraising drives currently being conducting for residents impacted by the fires.
Statements of Economic Interest
Upon assuming or leaving office, elected public officials and government employees are required to file a Statement of Economic Interests (Form 700) disclosing their financial interests in the jurisdiction. Under California law, public officials have 30 days from the date they assumed or left office to file this report. However, with the adoption of Executive Order N-17-25, city, county and state officials located in Los Angeles County now have an additional 60 days to file this report.
In addition, the FPPC is proposing to adopt a new regulation to temporarily extend the filing deadline for public officials required to file their annual Statement of Economic Interests. The deadline to file is either March 1 or April 1 depending on the office held. However, if this regulation is adopted, public officials in Los Angeles County whose primary residence or work location is located in Los Angeles or Ventura County will have until June 1 to file. The FPPC will consider this proposed regulation at its upcoming February 13 meeting.
Extension of City and County Lobbyist Registration Deadlines
We confirmed that the Los Angeles City Ethics Commission (CEC) and Los Angeles County will extend the annual lobbyist registration deadline for persons affected by the Los Angeles wildfires on a case-by-case basis. Annual registration forms for City lobbyists are normally due on February 10 and County registrations are due within 10 days of qualifying or January 10. If you or your family has been affected by the recent wildfires and you need to file City or County lobbying reports, please let us know and we will contact the CEC or the County on your behalf to arrange an extension.
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We appreciate how challenging the upcoming weeks and months will be for those impacted by the wildfires. If you are a public official, government employee or lobbying entity in Los Angeles County and would like an extension to file one of these above-referenced reports, please contact an Election Law Practice Group attorney or Political Compliance Specialist so that we can assist you.
