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HomeMy WebLinkAboutAgenda - Full - Ethics Review Board - 04/07/2025 - Agenda Ethics Review Board April 7, 2025, 3:30 pm to 5:00 pm CIC Conference Room, City Hall, 300 Laporte Ave and via Microsoft Teams Join the meeting now Meeting ID: 298 749 105 116 Passcode: fV9nu9gi Remote Participation Available Upon request, the City of Fort Collins will provide language access services for individuals who have limited English proficiency, or auxiliary aids and services for individuals with disabilities, to access City services, programs and activities. Contact 970.221.6515 (V/TDD: Dial 711 for Relay Colorado) for assistance. Please provide advance notice. Requests for interpretation at a meeting should be made by noon the day before. A solicitud, la Ciudad de Fort Collins proporcionará servicios de acceso a idiomas para personas que no dominan el idioma inglés, o ayudas y servicios auxiliares para personas con discapacidad, para que puedan acceder a los servicios, programas y actividades de la Ciudad. Para asistencia, llame al 970.221.6515 (V/TDD: Marque 711 para Relay Colorado). Por favor proporcione aviso previo cuando sea posible. Las solicitudes de interpretación en una reunión deben realizarse antes del mediodía del día anterior. A. Call to Order B. Roll Call C. Elect Chairperson D. Agenda Review E. Approval of May 17, 2023 Minutes F. Agenda Item 1: Overview – Gift Restrictions G. Agenda Item 2: Overview – Gift Disclosures H. Agenda Item 3: Overview – Financial Disclosures I. Discuss Work Plan and Schedule for Future Meetings J. Other Business K. Adjournment Page 001 DRAFT - ETHICS REVIEW BOARD MEETING MINUTES MAY 17, 2023 MEETING HELD VIA ZOOM Ethics Review Board members in attendance: Councilmember Susan Gutowsky (Chair), Councilmember Julie Pignataro, Mayor Jeni Arndt Staff in attendance: Carrie Daggett, City Attorney; Briana McCarten, Paralegal Other Attendees: none The City Council Ethics Review Board (the “Board”) held and recorded a meeting via Zoom Webinar on Wednesday, May 17, 2023, at 4:00 p.m. Chair Gutowsky called the meeting to order at 4:03 pm. The Board reviewed the Agenda which contained the following items: 1. Call to Order 2. Roll Call 3. Review and Approval of the December 14, 2022, Minutes of the Ethics Review Board. 4. Discuss the definition and examples of “personal interest” within the City’s ethical rules of conduct and with respect to quasi-judicial proceedings. 5. Other Business. 6. Adjournment. Paralegal Briana McCarten took roll call for the Board. All members were in attendance. Councilmember Pignataro moved to approve the December 14, 2022, minutes. Mayor Arndt seconded the motion. The Minutes were approved by unanimous vote. The Board moved on to Agenda Item 4. City Attorney Daggett gave an overview of the Agenda Item Summary and its attachments. The AIS provides: examples of other municipalities’ ethics provisions regarding personal or private interest; Ordinance 145, 2014, which added the definitions to the Code that relate to personal interest in order to interpret the language and terms of the Code in the way a court could interpret them for guidance; a summary of the conclusion reached by past ERBs when asked to make a determination as to whether a personal interest was present in a particular scenario; and an overview of quasi-judicial decision-making proceedings. Daggett noted that she has recently gotten positive feedback from other jurisdictions about the City’s personal interest definitions. Page 002 ERB Meeting Minutes 5/17/2023 Page 2 Daggett provided an example of a scenario in which a Council or board member would have a personal interest as defined in the Code: an architect draws up plans for a building and was previously paid for the work by their employer. Eventually the building or its plans become part of a discussion before Council, centering on the plans. The architect’s professional reputation might be affected by Council’s review or criticism of the plans, and if a Councilmember was the architect that individual may well have a personal interest. Councilmember Gutowsky recalled a scenario brought before a previous ERB: the then Mayor and a Councilmember were employed by or otherwise affiliated with Colorado State University. Even though the topic before Council could not have benefitted either individual financially or personally, the public raised questions about whether there was some favoritism or influence at play in making a decision, and which did lead to multiple ethics complaints. The standard for determining the presence of a personal interest is that a reasonably prudent person would expect a Council or board member to receive a substantial and direct benefit or detriment different in kind than that experienced by the general public. The standard is not intended to be whether a Council or board member will be liked by the public. Councilmember Pignataro discussed that oftentimes the desire or reluctance to recuse oneself from a decision is based on a person’s tolerance level for the appearance of a conflict, which can vary from person to person. Mayor Arndt brought up that one must also consider the power relationship between a Council or board member and an entity requesting a decision. Mayor Arndt has recused herself from a State Board situation in which she was confident that she would have been impartial but didn’t want to invite the public’s perception of a conflict due to her role at the City, which would be impacted by the Board’s decision. City Attorney Daggett asked if the ERB saw any need to add language to the Code around the personal interest definition. Councilmember Pignataro stated that the current language was sufficient in the past few years when the ERB evaluated a spate of complaints. The consensus of the ERB was that there is no need to add language to the Code. City Attorney Daggett informed the ERB that she is almost finished getting several local attorneys on board to be prepared to review potential complaints when they arise, pursuant to recently added Code language. Mayor Arndt stated that the ethics review process should be part of onboarding for new Councilmembers. The ERB discussed their thoughts and experiences around their roles as liaisons to various boards and commissions and their concerns about attending board meetings too regularly. Page 003 ERB Meeting Minutes 5/17/2023 Page 3 The ERB agreed that there is no need to set another meeting at this time. City Attorney Daggett reminded the ERB that we will set another meeting upon request. There being no other business to discuss, the meeting adjourned at 4:54. Page 004 Headline Copy Goes Here Carrie Daggett City Attorney’s Office Review and Recommended Changes of Gift Acceptance, and Gift and Financial Disclosures 04-07-25 Page 005 Headline Copy Goes Here 2 Council Priority to Review and Update Ethics Code At its January 21, 2025, meeting, City Council asked the Ethics Review Board to review the City’s requirements around the acceptance of gifts, gift disclosures, and financial disclosures and consider recommended changes. Page 006 Headline Copy Goes Here 3 Topics for Discussion A.Overview of Current City Gift, Honoraria and Favors Acceptance Restrictions B.Overview of Current City Gift Disclosure Requirements C.Overview of Current City Financial Disclosure Requirements Page 007 Headline Copy Goes Here 7 Clarification Questions What are the dollar amount and in-kind value limitations of allowable gifts per City Code Section 2-576(b)? What are the dollar amount and in-kind value thresholds for reporting gifts per City Code Section 2-656? How specific do reporters need to be when disclosing financial interests per City Code Sections 2-637 and 2-638 Page 008 Headline Copy Goes Here Page 009 City Council ERB Agenda Item Summary – City of Fort Collins Page 1 of 2 Agenda Item 1 April 7, 2025 AGENDA ITEM SUMMARY City Council – Ethics Review Board Carrie Daggett, City Attorney SUBJECT City’s current restrictions on acceptance of gifts, honoraria and favors by City Councilmembers, City EXECUTIVE SUMMARY provide an overview of the City’s current restrictions as a starting point for discussions about potential changes to such restrictions. City Code section 2-576(b) contains the STAFF RECOMMENDATION Not applicable. BACKGROUND / DISCUSSION Under “other business” at its January 21, 2025, City Council meeting, several members of the Council City Council asked the Ethics Review Board (ERB) to review the City’s restrictions on officers’ and employees’ acceptance of gifts, honoraria and favors and consider whether they recommend changes to the restrictions. City Code Section 2-576(b) prohibits officers (and employees) from accepting a gift or favor if it might be construed as compensation for an official decision or would tend to impair independence of judgment in official duties. A copy of Section 2-576(b) is attached for reference. The Code specifically excludes certain types of gifts or favors. Currently, the City’s rules require an officer or employee to use their own judgment about whether they may accept a gift, honoraria or favor. The ERB may discuss whether they recommend change to the requirements that set a more definite or clear standard. For comparison, staff gathered examples of other entities’ restrictions on acceptance of gifts, honoraria and favors, including: 1) Colorado Constitution Article XXIX, Sec. 3, Ethics in Government Gift Ban (also referred to as Amendment 41); and 2) City of Loveland; and 3) City of Commerce City; and 4) City of Colorado Springs; and 5) City of Denver; and 6) City of Aurora. The City’s Council Gifts and Favors FAQ flowchart is attached for reference. Page 010 City Council ERB Agenda Item Summary – City of Fort Collins Page 2 of 2 CITY FINANCIAL IMPACTS Not applicable. BOARD / COMMISSION / COMMITTEE RECOMMENDATION Not applicable. PUBLIC OUTREACH Not applicable. ATTACHMENTS 1. City Code section 2-576(b) 2. Council Gifts and Favors FAQ 3. Other entities’ restrictions on acceptance of gifts, honoraria and favors: Colorado Constitution Article XXIX, Sec. 3, Ethics in Government Gift Ban (also referred to as Amendment 41); City of Loveland; City of Commerce City; City of Colorado Springs; City of Denver; and City of Aurora. Page 011 CHAPTER 2 - ADMINISTRATION ARTICLE VII – OFFICERS AND EMPLOYEES DIVISION 2 Ethical Rules of Conduct: Related Procedures Created: 2025-03-24 09:10:26 [EST] (Supp. No. 149) Page 1 of 1 Division 2 Ethical Rules of Conduct: Related Procedures Sec. 2-576. Ethical rules of conduct—Officers and employees. (b) All officers and employees shall refrain from accepting payment for any speeches, debates or other public events and shall further refrain from accepting any gift or favor which, in the judgment of a reasonably prudent person, would tend to impair the officer's or employee's independence of judgment in the performance of his or her official duties. The following shall not constitute prohibited gifts or favors under this Section: (1) Campaign contributions reported as required by Chapter 7, Article V of this Code; (2) A nonpecuniary award publicly presented by a nonprofit organization in recognition of public service; (3) Payment of or reimbursement for actual and necessary expenditures for travel and subsistence for attendance at a convention or other meeting at which an officer or employee is scheduled to participate; (4) Reimbursement for or acceptance of an opportunity to participate in a social function or meeting which is offered to an officer or employee which is not extraordinary when viewed in light of the position held by such officer or employee; (5) Items of perishable or nonpermanent value that are insignificant in value, including, but not limited to, meals, lodging, travel expenses or tickets to sporting, recreational, educational or cultural events; and (6) Payment of salary from employment, including other employment in addition to that earned from being an officer or employee. (c) No officer or employee shall request on his or her own behalf, or for or through a relative or related entity, from any other officer or employee, or grant to any other officer or employee, or relative or related entity of the same, any consideration, treatment or advantage in the interpretation, administration or enforcement of the Charter, Code, any City regulation, policy or program or in the provision of public services, that is substantially different from that available to other persons in the same circumstances or having the same need. (Ord. No. 112, 1989, § 1, 8-1-89; Ord. No. 162, 2000, § 2, 11-21-00; Ord. No. 109, 2002, §§ 1—4, 8-20-02; Ord. No. 145, 2014, 11-4-14; Ord. No. 159, 2014, §§ 1—3, 11- 18-14; Ord. No. 037, 2017, §§ 2, 3, 3-7-17; Ord. No. 167, 2017, § 2, 12-19-17; Ord. No. 057, 2020, § 2, 4-21-20; Ord. No. 072, 2021, §§ 2, 3, 7-20-21; Ord. No. 120, 2023, § 3, 9-19-23) Page 012 No No No Yes No No No COUNCIL GIFTS AND FAVORS FAQ When someone offers you anything of value (e.g., ticket to event, promotional hat or t-shirt, plant, gift card, etc.), you should evaluate if you are permitted to accept it. Any gifts you accept, you must report regardless of the monetary value. Tickets and items you receive directly from the City generally will not be gifts subject to reporting requirements. Was the item or ticket/admission provided to you by the City (including the various City departments) for you to attend so as to carry out your role as a Councilmember on behalf of the City? It is not a gift to you and you do not have to report.Yes Was the ticket admission given to you because you were invited to speak or be a part of the program?Yes It is not a gift to you and you do not have to report. Was the item a gift received by the City from a third party and provided to you by the City? In practice, this would likely mean the ticket/gift was treated as a gift to the City and coordinated through the City Manager’s Office. Yes It is not a gift to you and you do not have to report. Did a non-profit or external entity offer the gift/ticket to you in express thanks for a City Council vote or action?Yes Please do not accept the gift as this is inappropriate and may be illegal depending on the circumstances. The City Manager’s Office & CityGive can help with a polite decline on your behalf. Did the non-profit or external entity provide a ticket to or for your guest/spouse?Yes Evaluate its value and confirm it does not violate the gift restrictions. If you choose to accept it, you must report it. Did the non-profit or external entity provide you with flowers, food, swag or a clothing item that is not significant in value in appreciation for your service on Council? You may accept the items since they are perishable or insignificant in value. The gift reporting requirement does not state a minimum threshold for reporting, so it may be appropriate to report these items as gifts. Please note that gifts for attending an event or speaking would be considered an honorarium and would be prohibited, so how the entity characterizes the gift is important. Yes Did the non-profit or external entity offer you a monetary gift for speaking at their event?Yes Please do not accept it as this is prohibited as an honorarium. The City Manager’s Office & CityGive can help with a polite return of the money on your behalf. Is the monetary value of the gift significant? City Code does not include a numerical value of significance. As a point of comparison, the current State limit on gifts is $75. No You can accept it. As a gift to you (rather than a covered expense), you do need to report it regardless of the dollar value. • City Code Section 2-576(b) contains the gifts and favors provision and lists types of gifts or favors that you are allowed to accept. The following flowchart can provide you with guidance to evaluate how these requirements apply. • City Code (Section 2-656) requires Councilmembers to report gifts on a quarterly basis (by Jan 15, April 15, July 15, October 15). 24-26691Page 013 STATE OF COLORADO Article XXIX Ethics in government (Amendment 41) Section 3. Gift ban. (1) No public officer, member of the general assembly, local government official, or government employee shall accept or receive any money, forbearance, or forgiveness of indebtedness from any person, without such person receiving lawful consideration of equal or greater value in return from the public officer, member of the general assembly, local government official, or government employee who accepted or received the money, forbearance or forgiveness of indebtedness. (2) No public officer, member of the general assembly, local government official, or government employee, either directly or indirectly as the beneficiary of a gift or thing of value given to such person's spouse or dependent child, shall solicit, accept or receive any gift or other thing of value having either a fair market value or aggregate actual cost greater than fifty dollars ($50) in any calendar year, including but not limited to, gifts, loans, rewards, promises or negotiations of future employment, favors or services, honoraria, travel, entertainment, or special discounts, from a person, without the person receiving lawful consideration of equal or greater value in return from the public officer, member of the general assembly, local government official, or government employee who solicited, accepted or received the gift or other thing of value. (3) The prohibitions in subsections (1) and (2) of this section do not apply if the gift or thing of value is: (a) A campaign contribution as defined by law; (b) An unsolicited item of trivial value less than fifty dollars ($50), such as a pen, calendar, plant, book, note pad or other similar item; (c) An unsolicited token or award of appreciation in the form of a plaque, trophy, desk item, wall memento, or similar item; (d) Unsolicited informational material, publications, or subscriptions related to the recipient's performance of official duties; (e) Admission to, and the cost of food or beverages consumed at, a reception, meal or meeting by an organization before whom the recipient appears to speak or to answer questions as part of a scheduled program; (f) Reasonable expenses paid by a nonprofit organization or other state or local government for attendance at a convention, fact-finding mission or trip, or other meeting if the person is scheduled to deliver a speech, make a presentation, participate on a panel, or represent the state or local government, provided that the Page 014 non-profit organization receives less than five percent (5%) of its funding from for- profit organizations or entities; (g) Given by an individual who is a relative or personal friend of the recipient on a special occasion. (h) A component of the compensation paid or other incentive given to the recipient in the normal course of employment. (4) Notwithstanding any provisions of this section to the contrary, and excepting campaign contributions as defined by law, no professional lobbyist, personally or on behalf of any other person or entity, shall knowingly offer, give, or arrange to give, to any public officer, member of the general assembly, local government official, or government employee, or to a member of such person's immediate family, any gift or thing of value, of any kind or nature, nor knowingly pay for any meal, beverage, or other item to be consumed by such public officer, member of the general assembly, local government official or government employee, whether or not such gift or meal, beverage or other item to be consumed is offered, given or paid for in the course of such lobbyist's business or in connection with a personal or social event; provided, however, that a professional lobbyist shall not be prohibited from offering or giving to a public officer, member of the general assembly, local government official or government employee who is a member of his or her immediate family any such gift, thing of value, meal, beverage or other item. (5) The general assembly shall make any conforming amendments to the reporting and disclosure requirements for public officers, members of the general assembly and professional lobbyists, as provided by law, to comply with the requirements set forth in this section. (6) The fifty-dollar ($50) limit set forth in subsection (2) of this section shall be adjusted by an amount based upon the percentage change over a four-year period in the United States bureau of labor statistics consumer price index for Denver-Boulder-Greeley, all items, all consumers, or its successor index, rounded to the nearest lowest dollar. The first adjustment shall be done in the first quarter of 2011 and then every four years thereafter. Page 015 LOVELAND 2.73.020 Prohibited gifts. Unless permitted under City Code Section 2.73.030, a city official shall not solicit or accept any gift from any person either directly or indirectly through the city official's spouse or dependent child which gift the city official knows or which a reasonable person in the city official's position should know under the circumstances, is either: A. A gift that would tend to improperly influence that city official to depart from the faithful and impartial discharge of his or her public duties; or B. Is a gift being solicited or given for the primary purpose of rewarding the city official for an official action he or she has taken. 2.73.030 Permitted gifts. The gift prohibitions of City Code Section 2.73.020 shall not apply to city officials with respect to the following permitted gifts: A. Campaign contributions as authorized by law; B. A non-monetary award, publicly presented, in recognition of public service; C. Gifts similarly available to the general public; D. Educational scholarships and grants available to members of the general public similarly situated; E. Grants and services provided for medical, respite or hospice care or other social welfare needs available to members of the general public similarly situated; F. An occasional, unsolicited gift having a fair market value of $50.00 or less; G. Unsolicited informational material, publications, or subscriptions related to the city official's performance of his or her official duties; H. An unsolicited token or award of appreciation in the form of a plaque, trophy, desk item, wall memento or similar item; I. Payment of or reimbursement for actual and necessary expenditures for registration, travel, lodging and meals for attendance at a convention, training seminar, or other meeting at which the city official is scheduled to participate as a representative of the city or to attend as part of his or her official duties; J. An occasional, unsolicited opportunity to participate in a business meeting or social function where a meal is served and/or entertainment is provided if the city official's attendance would not be considered extraordinary when viewed in light of the position held by the city official; K. Payment received by a council member for a speech, appearance or publication required to be reported by the council member pursuant to C.R.S. § 24-6-203; Page 016 L. Gifts received by a council member or a board and commission member arising from his or her employment and that is unrelated to his or her official city duties; and M. Gifts received by an employee from the city as authorized in the city's personnel rules and regulations, and any gifts received by an employee arising from his or her non-city employment and that is unrelated to his or her official city duties. Page 017 COMMERCE CITY Sec. 9.5. Acceptance of gratuities prohibited. It shall be a violation of this Charter for any city elected or appointed officer or any city employee to accept gratuities, favors, or gifts in connection with or relative to any contract or business of the city. (Ord. No. 1016, § 4(39), 2-16-93, passed 4-6-93) Page 018 COLORADO SPRINGS 1.3.111: GIFTS: A. Hospitality And Gifts: No covered person or immediate family member shall solicit, accept, or give any gift related to the covered person's duties and responsibilities on behalf of the City. B. Exceptions: Providing that the gift could not be reasonably considered a bribe or a means of improper influence on a direct official action, no violation of this Code of Ethics shall be found to apply to the following: 1.A campaign contribution as defined by law. 2. An unsolicited item or items of value less than the dollar amount established and adjusted in Colorado Constitution, article XXIX, section 3, per vendor or third party per year. As of January 1, 2017, that amount is fifty nine dollars ($59.00). a. The cost of the gift is the retail value of the item unless the receiver has knowledge that the giver paid more than the retail value, in which case the cost is the amount actually paid. b. For a charity event, the cost of the event is the amount the event organizer reports to the Internal Revenue Service as the non-deductible portion of the event. c. It is not permissible to pay part of the cost of a gift that is offered with a value exceeding the amount set forth in subsection B2 of this section to reduce the value to less than the amount set forth in subsection B2 of this section and then accept the gift. d. Immediate family members of covered persons, except those of elected officials, may only accept a free or discounted event ticket if they attend the event with a covered person. Event tickets for elected officials are covered under subsection B15 of this section. 3. An unsolicited token or award of appreciation that is reasonable in value and purpose, such as plaques and professional awards. 4. A component of compensation paid or other recognition given in the normal course of employment, appointment, volunteer services, or business. 5. Any scholarship or grant or other financial aid for education given to any covered person or immediate family member for any reason. 6. Any charity event benefiting the City and any of its affiliated organizations. 7. Any gift solicitation for a charitable purpose as determined to be appropriate by the City or its affiliated organization. 8. Any gift, whether solicited or not, to benefit a public safety or community purpose. Page 019 9. Awards or prizes given at competitions or drawings at events open to the public. 10. Reasonable cost (e.g., fees, meals, lodging, and/or transportation) and frequency of conferences, seminars, events, or meetings, so long as the conferences, seminars, events, or meetings are documented and: a. The person is scheduled to deliver a speech, participate in a presentation, participate on a panel, or receive an award; b. The cost of the conference, seminar, event, or meeting is paid pursuant to a vendor agreement or contract; or c. The cost of the conference, seminar, event, or meeting is paid by a governmental entity or an IRC 501(c)(3) organization. 11. Reasonable cost and frequency of City sponsored educational events, so long as the events are documented. 12. Reasonable cost and frequency of business meals for covered persons, so long as the meals are documented. 13. Perishable or consumable gifts given to a City department or group. 14. Gifts accepted in a covered person's official capacity that will become property of the City. 15. For elected officials and their immediate family members, reasonable cost and frequency of meals and event tickets pertaining to their official duties as Mayor or members of City Council so long as the gift is documented and is not intended, and does not affect, a direct official action. 16. A non-pecuniary award of reasonable value and frequency publicly presented by an IRC 501(c)(3) organization in recognition of public service. 17. Discounts that are similarly available to all employees of the City, or discounts that are offered to the public generally or to a large segment of the public (i.e., all uniformed personnel, all government employees, or all first responders). 18. Any exemption granted or exception recognized pursuant to Federal or State law. 19. Any other exceptions as may be approved by the Commission through an inquiry for consideration. C. Inappropriate Hospitality And Gifts: Inappropriate hospitality or gifts involves offering or receiving accommodations, tours, event tickets, recreation, entertainment, meals or other similar personal benefits when a substantial interest exists that could influence or be perceived to influence objectivity when interacting with, representing, or conducting business for or on behalf of the City. (Ord. 11-18; Ord. 16-122) Page 020 DENVER Sec. 2-60. Gifts to officers, officials, and employees. The purpose of this section is to avoid special influence by donors who give gifts to city officers, employees or officials. (a) Except when acceptance is permitted by paragraph (b) below, it shall be a violation of this code of ethics for any officers, officials, or employees, any member of their immediate families to solicit or to accept any of the following items if (1) the officer, official, or employee is in a position to take direct official action with regard to the donor; and (2) the city has an existing, ongoing, or pending contract, business, or regulatory relationship with the donor: (1) Any money, property, service, or thing of value that is given to a person without adequate and lawful compensation; (2) Any honoraria or payment for participation in an event; (3) Any loan of goods, equipment, or other items that is not available to the general public on the same terms and conditions; (4) Any loan of money that is not available to the general public at the same interest rate and the same conditions; (5) Any ticket to a sporting, recreational, or cultural event except as provided for in subsection (b)(4) of this section; (6) Travel expenses and lodging; (7) Any reduction in price or any discount that is not similarly available to all city officers, officials, and employees on the same terms; (8) Parking passes except as provided for in subsection (b)(4) of this section; and (9) Meals except as provided for in subsection (b)(4) of this section. This prohibition shall also apply to gifts from a lobbyist or representative of a client if (1) the officer, official, or employee is in a position to take direct official action with regard to the client and (2) the city has an existing, ongoing, or pending contract, business, or regulatory relationship with the client. (b) Officers, officials, and employees and the members of their immediate family may accept the following even if the officer, official, or employee is in a position to take direct official action with regard to the donor, or, if the donor is a lobbyist or representative, the donor's client: (1) Gifts from other officers, officials, or employees and their family members on appropriate occasions; (2) Campaign contributions as permitted by law; (3) Nonpecuniary awards that are publicly presented by an organization in recognition of public service if the award is not extraordinary when viewed in light of the position held by the recipient; (4) The donation of meals, tickets to events for which admission is charged, or free or reduced price admission to events for which a fee is charged, but only under the following conditions: Page 021 a. The value of any meals, tickets, or free or reduced price admissions accepted from the same donor in any calendar year shall not exceed three hundred dollars ($300.00) and shall be subject to the reporting requirements set forth in article V of this chapter 2; b. A donation from an employee of a business or entity shall be counted as a gift from the business or entity; c. The individual or entity which pays for the meal, ticket, or admission shall be considered the donor for purposes of this subsection regardless of whether that individual or entity is reimbursed for the cost; d. Attendance must be reasonably related to the official or ceremonial duties of the officer, official, or employee; e. The donation of parking for the meal or event shall be allowed on the same terms and conditions; f. Officers, officials and employees may accept the following donations of meals regardless of the annual cap on the value of such meals set forth in paragraph a. of this subsection and without the need to report the donation under article V of this chapter 2: meals provided to all attendees at a public meeting and consumed while the meeting is in progress, including by way of example "working lunches;" and meals provided to all members of any governmental, civic, or non-profit board of which the officer, official or employee is a member and consumed in conjunction with any meeting of the board; g. Officers, officials and employees may accept the following donations of tickets or free admissions to events, regardless of the annual cap on the value of such donations set forth in paragraph a. of this subsection: tickets or free admission to a charitable event, as long as the ticket or free admission is offered directly by and at the expense of the charitable, other non-profit, or governmental entity hosting the event and not directly or indirectly offered by any sponsor of the event or other donor to which the gift restriction set forth in paragraph a. of this section applies. Any ticket or free admission to an event accepted under this paragraph g., shall be subject to reporting requirements set forth in article V of this chapter 2. (5) Unsolicited items of trivial value. "Items of trivial value" means items or services with a value of twenty-five dollars ($25.00) or less, such as inexpensive tee shirts, pens, calendars, books, flowers, or other similar items and does not mean cash or gift cards; (6) Gifts while visiting other cities, counties, states, or countries or hosting visitors from other cities, counties, states, or countries when it would be a breach of protocol to refuse the gift; (7) Reasonable expenses paid by non-profit organizations or other governments for attendance at a convention, fact finding mission or trip, or other meeting if the person is scheduled to deliver a speech, make a presentation, participate on a panel, or represent the city in an official capacity reasonably related to the recipient's employment by the city; (8) Gifts on special and infrequent occasions if the gift is appropriate to the occasion. These occasions include weddings, funerals, and illnesses; Page 022 (9) Gifts to commemorate a public event in which the officer, official, or employee participated in an official capacity, provided that the gift is appropriate to the occasion. Such occasions include ground breaking ceremonies and grand openings; (10) Memberships and passes from the Denver Art Museum, Denver Botanic Gardens, Denver Museum of Nature and Science, and Denver Zoo; (11) Gifts from family members; (12) Items which are similarly available to all employees of the city or the general public on the same terms and conditions. (c) It shall not be a violation of this article for an officer, official, or employee to solicit or accept donations to the city or to solicit, accept, or redirect donations for charitable purposes to a 501(c) or other charitable organization or to provide assistance to individuals affected by illness, crime or disaster or who have educational or other charitable needs, provided, however, that: (1) If an officer or employee soliciting such a donation is in a position to take direct official action with regard to the donor; and the city has an existing, ongoing, or pending contract, business, or regulatory relationship with the donor, any donation that is actually made as a result of the officer or employee's solicitation is reported by the officer or employee as required in article V of this chapter 2; and (2) The soliciting person, or a member of the soliciting person's immediate family does not keep or use the gift or receive any monetary benefit therefrom. (d) It shall not be a violation of this article for a member of an officer's, official's or employee's immediate family to accept a gift which arises from an independent relationship of an adult member, if: (1) The officer, official or employee does not use the gift; and (2) It cannot reasonably be inferred that the gift was intended to influence the officer, official, or employee in the performance of their duties. (Ord. No. 96-01, § 1, 1-29-01; Ord. No. 523-02, § 2, 7-1-02; Ord. No. 931-04, §§ 8, 9, 9- 7-04; Ord. No. 698-09, § 5, 11-30-09; Ord. No. 547-12, § 3, 10-29-12; Ord. No. 1202- 16, § 8, 3-6-17; Ord. No. 614-18, § 2, 7-9-18; Ord. No. 401-21, § 1, 4-26-21) Page 023 AURORA Sec. 1-43. Gifts to elected officials. (a) The purpose of this section is to avoid special influence by those who give gifts to city council members. (b) Except when acceptance is permitted by subparagraph (d) of this section, it shall be a violation of this code of ethics for any elected official, or any member of their immediate family to solicit or to accept any gift from a donor, or from a lobbyist or representative of a client if: (1) The elected official is in a position to take direct official action with regard to the donor or client; or (2) The city has an existing, ongoing, or pending contract, business, or regulatory relationship with the donor or client. (c) The following items shall be considered gifts for purposes of subsection (a) of this section: (1) Any money, property, service, or thing of value that is given to a person without adequate and lawful compensation; (2) Any honoraria or payment for participation in an event; (3) Any loan of goods, equipment, or other items that is not available to the general public on the same terms and conditions; (4) Any loan of money that is not available to the general public at the same interest rate and the same conditions; (5) Any ticket to a sporting, recreational, or cultural event except as provided for in subsection (d)(4) of this section; (6) Travel expenses and lodging; (7) Any reduction in price or any discount that is not similarly available to the general public or everyone similarly situated on the same terms; (8) Parking passes, except as provided for in subsection (d)(4) of this section; and (9) Meals, except as provided for in subsection (d)(4) of this section. (d) An elected official, or any member of their immediate family, may accept the following even if the elected official is in a position to take direct official action with regard to the donor or, if the donor is a lobbyist or representative, the donor's client: Page 024 (1) Gifts from other elected officials and their immediate family members on appropriate, special occasions; (2) Campaign contributions as permitted by law; (3) Non-pecuniary awards that are publicly presented by an organization in recognition of public service if the award is not extraordinary when viewed in light of the position held by the recipient; (4) The donation of meals, tickets to events for which admission is charged, or free or reduced price admission to events for which a fee is charged, but only under the following conditions: a. The value of any meals, tickets, or free or reduced price admissions accepted from the same donor in any calendar year shall not exceed $300.00 and shall be subject to the reporting requirements set forth in article III of this chapter. This amount shall be adjusted by an amount based upon the percentage change over a four-year period in the U.S. Bureau of Labor Statistics Consumer Price Index for Denver-Boulder-Greeley, all items, all consumers, or its successor index, rounded to the nearest lower dollar. The first adjustment shall be done in the first quarter of 2024 and then every four years thereafter; b. A donation from an employee of a business or entity shall be counted as a gift from the business or entity; c. The individual or entity which pays for the meal, ticket, or admission shall be considered the donor for purposes of this subsection regardless of whether that individual or entity is reimbursed for the cost; d. Attendance must be reasonably related to the official or ceremonial duties of the elected official; e. The donation of parking for the meal or event shall be allowed on the same terms and conditions; f. Elected officials may accept the donations of meals regardless of the annual cap on the value of such meals set forth in subparagraph a. of this subsection (d)(4) and without the need to report the donation under article III of this chapter if such meal is provided to all attendees at a public meeting and consumed while the meeting is in progress, including, by way of example, "working lunches," or is provided to all members of any governmental, civic, or non-profit board of which the elected official is a member and consumed in conjunction with any meeting of the board; g. Elected officials may accept donations of tickets or free admissions to events, regardless of the annual cap on the value of such donations set forth in subparagraph a. of this subsection (d)(4) if such ticket or free admission is to a charitable event, as long as the ticket or free admission is offered directly by and at the expense of the charitable or other non-profit entity hosting the event and not Page 025 directly or indirectly offered by any sponsor of the event or other donor to which the gift restriction set forth in this section applies; h. Elected officials shall report the value of the meal or food provided at an event rather than the value of the seat at the table or what the entity paid for the table and/or sponsorship. If the actual cost cannot be ascertained, but it is reasonable to assume that the cost exceeds $300.00, the elected official shall report the circumstances on the required report without an exact monetary value. (5) Unsolicited items of trivial value. For purposes of this subsection, "items of trivial value" means items or services with a value of $300.00 or less, such as inexpensive tee shirts, pens, calendars, books, flowers, or other similar items, not including cash or gift cards; (6) Gifts while visiting other cities, counties, states, or countries or hosting visitors from other cities, counties, states, or countries when it would be a breach of protocol to refuse the gift; (7) Reasonable expenses paid by non-profit organizations or other governments for attendance at a convention, factfinding mission or trip, or other meeting if the person is scheduled to deliver a speech, make a presentation, participate on a panel, or represent the City in an official capacity reasonably related to the recipient's employment by the City; (8) Gifts on special and infrequent occasions if the gift is appropriate to the occasion. These occasions include weddings, funerals, and illnesses; (9) Gifts to commemorate a public event in which the elected official participated in an official capacity, provided that the gift is appropriate to the occasion. Such occasions include groundbreaking ceremonies and grand openings; (10) Memberships and passes from city recreational and cultural facilities; (11) Gifts from family members; (12) Items which are similarly available to the general public on the same terms and conditions. (e) It shall not be a violation of this article for an elected official to solicit or accept donations to the City or to solicit, accept, or redirect donations for charitable purposes to a 501(c)(3) or other charitable organization or to provide assistance to individuals affected by illness, crime or disaster or who have educational or other charitable needs, provided, however, that: (1) The elected official soliciting the donation, or a member of the such elected official's immediate family does not keep or use the donation or receive any monetary benefit therefrom; and Page 026 (2) It cannot reasonably be inferred that the donation was intended to influence the elected official in the performance of his or her duties. (f) It shall not be a violation of this article for a member of an elected official's immediate family to accept a gift which arises from an independent relationship of an adult member, if: (1) The elected official does not use the gift; and (2) It cannot reasonably be inferred that the gift was intended to influence the elected official in the performance of his or her duties. (Ord. No. 2019-51, § 1, 8-19-2019) The Aurora City Code is current through Ordinance 2025-01, passed January 27, 2025. Page 027 City Council ERB Agenda Item Summary – City of Fort Collins Page 1 of 2 Agenda Item 2 April 7, 2025 AGENDA ITEM SUMMARY City Council – Ethics Review Board Carrie Daggett, City Attorney SUBJECT City’s current gift disclosure requirements EXECUTIVE SUMMARY provide background about favors per City Code §2-656. This will provide a starting the Ethics Review Board (ERB) discussion about the requirements and changes to City Code section 2-656. This Code provision requires Councilmembers to report g by the City Clerk based on one used by the Colorado Secretary of State. STAFF RECOMMENDATION Not applicable. BACKGROUND / DISCUSSION Under “other business” at its January 21, 2025, City Council meeting, the Council asked the Ethics Review Board to review the City’s gifts and honoraria disclosure requirements and consider whether they recommend changes to the disclosure requirements. City Code Section 2-656 requires every Councilmember who receives from any other person any gifts, honoraria, or favor in connection with their public service, to file a report of such gift, honoraria and favor on or before January 15, April 15, July 15, and October 15 of each year. A copy of section 2-656 is attached for reference. Discussion about potential recommended changes to the requirements may include consideration of making the reporting obligations more practical. The City Clerk routinely sends reminders to Councilmembers about their obligation to report gifts, favors and honoraria. A copy of such a reminder is attached. A copy of the form used by City Councilmembers, which is the Colorado Secretary of State “Disclosure by Public Officeholder Report of Gifts, Honoraria, and Other Benefits” form is attached. CITY FINANCIAL IMPACTS Not applicable. BOARD / COMMISSION / COMMITTEE RECOMMENDATION Page 028 City Council ERB Agenda Item Summary – City of Fort Collins Page 2 of 2 Not applicable. PUBLIC OUTREACH Not applicable. ATTACHMENTS 1. City Code section 2-656 2. Colorado Secretary of State “Disclosure by Public Officeholder Report of Gifts, Honoraria, and Other Benefits” form 3. C.R.S. § 24-6-202, Disclosure 4. C.R.S. § 24-6-203, Reporting by incumbents and elected candidates Page 029 CHAPTER 2 - ADMINISTRATION ARTICLE VIII. - FINANCIAL DISCLOSURE Division 3 Gifts, Honoraria and Other Benefits Fort Collins, Colorado, Municipal Code Created: 2025-03-24 09:10:27 [EST] (Supp. No. 149) Page 1 of 1 Division 3 Gifts, Honoraria and Other Benefits Sec. 2-656. Report required. Every Councilmember who receives from any other person any gifts, honoraria or other benefits in connection with the Councilmember's public service shall file, on or before January 15, April 15, July 15 and October 15 of each year, a report covering the period since the last report as required by Section 24-6-203, C.R.S. (Ord. No. 175, 2000, § 1, 12-19-00; Ord. No. 003, 2007, 2-6-07) Page 030 § 24-6-202. Disclosure--contents--filing--false or incomplete..., CO ST § 24-6-202 © 2025 Thomson Reuters. No claim to original U.S. Government Works.1 West's Colorado Revised Statutes Annotated Title 24. Government--State Administration Article 6. Colorado Sunshine Law (Refs & Annos) Part 2. Public Official Disclosure Law (Refs & Annos) C.R.S.A. § 24-6-202 § 24-6-202. Disclosure--contents--filing--false or incomplete filing--penalty Currentness (1) Not later than January 10 of each calendar year, each of the following individuals shall file an annual disclosure statement with the secretary of state of Colorado in such form as the secretary of state prescribes, stating the information specified in subsection (2) of this section: (a) Each member of the general assembly; (b) The governor, lieutenant governor, secretary of state, attorney general, and state treasurer; (c) Each justice or judge of a court of record; (d) Each district attorney; (e) Each member of the state board of education; (f) Each member of the board of regents of the university of Colorado; (g) Each member of the public utilities commission. (h) Repealed by Laws 1985, S.B.179, § 1. (1.3) If an individual begins serving in one of the positions specified in subsection (1) of this section after January 10 and has not filed a disclosure statement within the previous thirty days, the individual shall file a disclosure statement no later than ten days after assuming the position. (1.5) The provisions of subsection (1) of this section apply to any individual who is serving in any position specified in subsection (1) of this section on or after January 1, 2024. If an individual who is specified in subsection (1) of this section is serving in office in the 2024 calendar year but has not filed an annual disclosure statement in the Page 031 § 24-6-202. Disclosure--contents--filing--false or incomplete..., CO ST § 24-6-202 © 2025 Thomson Reuters. No claim to original U.S. Government Works.2 2024 calendar year, the individual shall file a disclosure statement no later than July 1, 2024, or in accordance with the requirements specified in subsection (1.3) of this section, whichever is sooner. (1.7) Repealed by Laws 2024, Ch. 468 (S.B. 24-210), § 51, eff. June 6, 2024. (2) Disclosure must include the following for the previous calendar year, unless otherwise specified: (a) The names, and amounts, disclosed as a range as provided in the form prescribed by the secretary of state, of any source or sources of any income, including capital gains, whether or not taxable, of the person making disclosure, the person's spouse, and any minor children residing with the person making the disclosure; (b) The name of each business, insurance policy, or trust in which he, his spouse, or minor children residing with him has a financial interest in excess of five thousand dollars; (c) The legal description of any interest in real property, including an option to buy, in the state in which the person making disclosure, his spouse, or minor children residing with him have any interest, direct or indirect, the market value of which is in excess of five thousand dollars; (d) The identity, by name, of all offices, directorships, and fiduciary relationships held by the person making disclosure, the person's spouse, and any minor children residing with the person making the disclosure, including whether the position is compensated or uncompensated; (e) The identity, by name, of any person, firm, or organization for whom compensated lobbying is done by any person associated with the person making disclosure if the benefits of such compensation are or may be shared by the person making disclosure, directly or indirectly; (f) The name of each creditor to whom the person making disclosure, the person's spouse, or the person's minor children owe money in excess of one thousand dollars, including the interest rate and the highest amount owed, disclosed as a range as provided in the form prescribed by the secretary of state, for the calendar year covered in the statement; (g) A list of businesses with which the person making disclosure or his spouse are associated that do business with or are regulated by the state and the nature of such business or regulation; (h) The sources of compensation exceeding five thousand dollars received by the person making the disclosure or the person's business affiliation for services provided directly by the person making the disclosure during the current year and during the prior calendar year, if the source is a person or entity that is regulated by the state or pays for a lobbyist that conducts lobbying at the general assembly or at a state regulatory body. This includes the names of clients and customers of any affiliated corporation, firm, partnership, or other business enterprise and a description of the duties performed or services rendered for each source of compensation if the person making the disclosure directly provided the services generating a fee or payment of more than five thousand dollars. The person making the disclosure may exclude any information considered confidential as a result of a privileged Page 032 § 24-6-202. Disclosure--contents--filing--false or incomplete..., CO ST § 24-6-202 © 2025 Thomson Reuters. No claim to original U.S. Government Works.3 relationship recognized by law. If the person making the disclosure withholds information as a result of a privileged relationship, the person shall still disclose the existence of the source of compensation and an explanation for why information was withheld. (i) Any additional information that the person making the disclosure deems necessary. (3) Any disclosure statement shall be amended no more than thirty days after any termination, acquisition, or substantial change of interests as to which disclosure is required. (4) Repealed by Laws 2024, Ch. 468 (S.B. 24-210), § 51, eff. June 6, 2024. (5) Each disclosure statement is public information and shall be made available on the secretary of state's website. (6) Repealed by Laws 2024, Ch. 468 (S.B. 24-210), § 51, eff. June 6, 2024. (7) Any person who willfully files a false or incomplete disclosure statement, or who willfully fails to make any filing required by this section is guilty of a misdemeanor and, upon conviction thereof, shall be punished by a fine of not less than one thousand dollars nor more than five thousand dollars. (8) In addition to any other process provided in law or rule, including article XXIX of the state constitution, any person who believes an official listed in subsection (1)(a) of this section is not substantially complying with the requirements of this section may file a complaint with the following: (a) The secretary of the senate and the president of the senate for members of the senate; and (b) The chief clerk of the house of representatives and the speaker of the house of representatives for members of the house of representatives. (9) Upon receiving a complaint, the person or persons receiving the complaint shall follow any existing procedures for investigating ethics complaints or violations. (10) If an official specified in subsection (1)(a) of this section does not timely file the required annual disclosure statement, the secretary of state shall forward notification to the appropriate individual specified in subsection (8) of this section. Credits Amended by Laws 1979, S.B.229, §§ 1, 2; Laws 1985, S.B.179, §§ 1, 6; Laws 2010, Ch. 151, § 5, eff. July 1, 2010; Laws 2022, Ch. 108 (H.B. 22-1156), § 3, eff. Aug. 10, 2022; Laws 2023, Ch. 399 (S.B. 23-276), § 53, eff. Jan. 1, 2024; Laws 2024, Ch. 468 (S.B. 24-210), § 51, eff. June 6, 2024. Page 033 § 24-6-202. Disclosure--contents--filing--false or incomplete..., CO ST § 24-6-202 © 2025 Thomson Reuters. No claim to original U.S. Government Works.4 Notes of Decisions (2) C. R. S. A. § 24-6-202, CO ST § 24-6-202 Current through legislation effective March 24, 2025 of the First Regular Session, 75th General Assembly (2025). Some statute sections may be more current. See credits for details. End of Document © 2025 Thomson Reuters. No claim to original U.S. Government Works. Page 034 § 24-6-203. Reporting by incumbents and elected..., CO ST § 24-6-203 © 2025 Thomson Reuters. No claim to original U.S. Government Works.1 West's Colorado Revised Statutes Annotated Title 24. Government--State Administration Article 6. Colorado Sunshine Law (Refs & Annos) Part 2. Public Official Disclosure Law (Refs & Annos) C.R.S.A. § 24-6-203 § 24-6-203. Reporting by incumbents and elected candidates--gifts, honoraria, and other benefits--prohibition on monetary gifts--penalty--definitions Currentness (1)(a) As used in this section, the terms “appropriate officer” and “candidate” shall have the meanings ascribed to them in section 1-45-103, C.R.S., of the “Fair Campaign Practices Act”. (b)(I) As used in this section, the term “public office” means any office voted for in this state at any election. “Public office” includes, without limitation, the governor, lieutenant governor, secretary of state, attorney general, and state treasurer; a member of the general assembly or the state board of education; a regent of the university of Colorado; a judge on the Colorado court of appeals or the Colorado supreme court; a district attorney; or an officer of a county, municipality, city and county, school district, or any elective office within a special district for which the annual compensation exceeds two thousand four hundred dollars. (II) “Public office” does not include: (A) The office of president or vice president of the United States; (B) The office of senator or representative in the congress of the United States; (C) Any office in a political party chosen pursuant to sections 1-3-103, 1-4-403, and 1-4-701, C.R.S.; or (D) Any political party office in an assembly or convention, including delegates thereto. (E) Repealed by Laws 2012, Ch. 167, § 1, eff. Aug. 8, 2012. (III) Repealed by Laws 2012, Ch. 167, § 1, eff. Aug. 8, 2012. (c) As used in this section, “covered state office” means the governor, lieutenant governor, secretary of state, attorney general, state treasurer, a member of the state board of education, a regent of the university of Colorado, a member of the general assembly, or a district attorney. Page 035 § 24-6-203. Reporting by incumbents and elected..., CO ST § 24-6-203 © 2025 Thomson Reuters. No claim to original U.S. Government Works.2 (2) Every incumbent in or candidate elected to public office who receives from any other person any item described in subsection (3) of this section in connection with the incumbent's or elected candidate's public service shall file with the appropriate officer, on or before January 15, April 15, July 15, and October 15 of each year, a report covering the period since the last report. The requirement of this subsection (2) pertaining to the report due January 15 shall extend to an incumbent leaving public office between October 15 and January 15, who shall file with the appropriate officer by January 15 a report that covers any items received during the period since the last report. Such report shall be on forms prescribed by the secretary of state and shall contain, at a minimum, the name of the person from whom the item was received and the amount or value and the date of receipt. The secretary of state shall furnish such forms to municipal clerks, to county clerk and recorders, and to incumbents and elected candidates for state offices and district offices of districts greater than a county free of charge for use by incumbents and elected candidates required to file such forms. If any incumbent in or candidate elected to public office does not receive any such item, he or she shall not be required to file such report. (3) The reports required by subsection (2) of this section shall include the following: (a) In the case of a candidate elected to public office who is not an incumbent and has not yet been sworn into such office and subject to the requirements of subsection (3.5) of this section, any money, including but not limited to a loan, pledge, or advance of money or a guarantee of a loan of money, or any forbearance or forgiveness of indebtedness from any person, with a value greater than fifty-three dollars; (b) In the case of a candidate elected to public office who is not an incumbent and has not yet been sworn into such office and subject to the requirements of subsection (3.5) of this section, any gift of any item of real or personal property, other than money, with a value greater than fifty-three dollars; (c) In the case of a candidate elected to public office who is not an incumbent and has not yet been sworn into such office, any loan of any item of real or personal property, other than money, if the value of the loan is greater than fifty-three dollars. For such purpose, the “value of the loan” means the cost saved or avoided by the elected candidate by not borrowing, leasing, or purchasing comparable property from a source available to the general public. (d) Any payment for a speech, appearance, or publication; (e) In the case of a candidate elected to public office who is not an incumbent and has not yet been sworn into such office, tickets to sporting, recreational, educational, or cultural events with a value greater than fifty-three dollars for any single event; (f) Payment of or reimbursement for actual and necessary expenditures for travel and lodging for attendance at a convention, fact-finding mission or trip, or other meeting that the incumbent or elected candidate who has been sworn into public office is permitted to accept or receive in accordance with the provisions of section 3 of article XXIX of the state constitution, unless the payment of or reimbursement for such expenditures is made from public funds of a state or local government in the case of an incumbent or elected candidate subject to the provisions of said article or from the funds of any association of public officials or public entities whose membership includes the incumbent's or elected candidate's office or the governmental entity in which such office is held; Page 036 § 24-6-203. Reporting by incumbents and elected..., CO ST § 24-6-203 © 2025 Thomson Reuters. No claim to original U.S. Government Works.3 (g) Subject to the provisions of section 3 of article XXIX of the state constitution, any gift of a meal to a fund- raising event of a political party; (h) Payment of or reimbursement for actual and necessary expenses for travel and lodging for attendance at a convention, fact-finding mission or trip, or other meeting that is from an organization declared to be a joint governmental agency by section 2-3-311, C.R.S. (3.5)(a) Each incumbent in or candidate elected to covered state office is prohibited from knowingly receiving or accepting from any other person, in connection with the public service of the incumbent or elected candidate: (I) A gift of any money, including but not limited to a loan, pledge, or advance of money, a guarantee of a loan of money, or any monetary payment given, directly or indirectly, for the purpose of defraying any expenses related to the official duties undertaken by the incumbent or elected candidate; or (II) An in-kind gift. (b) Nothing in paragraph (a) of this subsection (3.5) shall be construed to prohibit an incumbent or elected candidate from receiving a salary or other compensation paid to the incumbent or elected candidate in connection with the performance of his or her official duties, including, without limitation, payment for a speech, appearance, or publication or payment of or reimbursement for actual and necessary expenditures for travel and lodging to the extent the incumbent or elected candidate who has been sworn into covered state office is permitted to accept or receive such items in accordance with the provisions of section 3 of article XXIX of the state constitution. (c) For purposes of this subsection (3.5), an “in-kind gift” means any gift of equipment, goods, supplies, property, services, or anything else, the value of which exceeds fifty dollars in the aggregate in any one calendar year, given, directly or indirectly, to an incumbent in or candidate elected to covered state office for the purpose of defraying any expenses related to the official duties undertaken by the incumbent or elected candidate. (3.7) Notwithstanding any other provision of this section, no incumbent in or candidate elected to covered state office shall accept a gift of any money from any person who is a professional or volunteer lobbyist or from a corporation or labor organization. (4) The reports required by subsection (2) of this section need not include the following: (a) A contribution or contribution in kind that has already been reported pursuant to section 1-45-108, C.R.S.; (b) Any unsolicited item of trivial value as described in section 3(3)(b) of article XXIX of the state constitution; (c) An unsolicited token or award of appreciation as described in section 3(3)(c) of article XXIX of the state constitution; Page 037 § 24-6-203. Reporting by incumbents and elected..., CO ST § 24-6-203 © 2025 Thomson Reuters. No claim to original U.S. Government Works.4 (d) Payment of or reimbursement for actual and necessary expenditures for travel and lodging for attendance at a convention, fact-finding mission or trip, or other meeting that the incumbent or elected candidate is permitted to accept or receive in accordance with the provisions of section 3 of article XXIX of the state constitution, if the payment of or reimbursement for such expenditures is made from public funds of a state or local government in the case of an incumbent or elected candidate subject to the provisions of said article or from the funds of any association of public officials or public entities whose membership includes the incumbent's or elected candidate's office or the governmental entity in which such office is held; (e) Payment of salary from employment, including other government employment, in addition to that earned from being a member of the general assembly or by reason of service in other public office; (f) Except as otherwise described in this subsection (4), any other gift or thing of value an incumbent or elected candidate who has been sworn into public office is permitted to solicit, accept, or receive in accordance with the provisions of section 3 of article XXIX of the state constitution. (5) Any person who provides an incumbent or elected candidate with any item required to be reported by the incumbent or elected candidate pursuant to this section shall, at the time the item is provided, furnish the recipient with a written statement of the dollar value of the item. (6) Nothing contained in this section shall relieve any person from the disclosure requirements of part 3 of article 6 of this title, relating to the regulation of lobbyists. (7) Any person who willfully files a false or incomplete report pursuant to this section, who willfully fails to file a report required by this section, who willfully fails to provide the statement of value required by subsection (5) of this section, or who violates any provision of subsection (3.5) of this section is guilty of a misdemeanor and, upon conviction thereof, shall be punished by a fine of not less than fifty dollars nor more than one thousand dollars. (8) The amount of the gift limit specified in subsection (3) of this section, set at fifty-three dollars as of August 8, 2012, shall be identical to the amount of the gift limit under section 3 of article XXIX of the state constitution, and shall be adjusted for inflation contemporaneously with any adjustment of the constitutional gift limit pursuant to section 3(6) of article XXIX. Credits Added by Laws 1994, H.B.94-1341, § 3, eff. Jan. 1, 1995. Amended by Laws 1998, Ch. 226, § 34, eff. Aug. 5, 1998; Laws 1998, Ch. 252, §§ 5, 6, eff. May 27, 1998; Laws 2006, Ch. 363, §§ 1, 2, eff. July 1, 2006; Laws 2010, Ch. 184, § 3, eff. Aug. 11, 2010; Laws 2012, Ch. 167, § 1, eff. Aug. 8, 2012; Laws 2017, Ch. 364, § 3, eff. Aug. 9, 2017. Notes of Decisions (1) C. R. S. A. § 24-6-203, CO ST § 24-6-203 Page 038 § 24-6-203. Reporting by incumbents and elected..., CO ST § 24-6-203 © 2025 Thomson Reuters. No claim to original U.S. Government Works.5 Current through legislation effective March 24, 2025 of the First Regular Session, 75th General Assembly (2025). Some statute sections may be more current. See credits for details. End of Document © 2025 Thomson Reuters. No claim to original U.S. Government Works. Page 039 City Council ERB Agenda Item Summary – City of Fort Collins Page 1 of 2 Agenda Item 3 April 7, 2025 AGENDA ITEM SUMMARY City Council – Ethics Review Board Carrie Daggett, City Attorney SUBJECT e City’s financial disclosures requirements EXECUTIVE SUMMARY provide background about the City’s current financial disclosure requirements City Code Article VIII Division 2 also requires City Manager and City Attorney to file a financial disclosure no later than January 10 each year. STAFF RECOMMENDATION Not applicable. BACKGROUND / DISCUSSION Under “other business” at its January 21, 2025, City Council asked the Ethics Review Board to review the City’s financial disclosure requirements. City Code Section 2-636 requires every Council candidate to file with the City Clerk a written financial disclosure statement at the time of filing their acceptance of nomination with the City Clerk. City Code Section 2-636 also requires each Councilmember to file, no later than the January 10th after their election re-election, retention, or appointment, the same written financial disclosure. Similarly, the City Manager and City Attorney are required to file such written financial disclosure within 30 days of their appointment. Councilmembers, the City Manager, and the City Attorney must file financial disclosures yearly after their initial disclosures. City Code Section 2-637 lists the financial interests that must be disclosed. City Code Section 2-638 requires any person required to file a financial disclosure statement to file an amended statement, or a written statement that there has been no change, on or before May 15 of each year after their election, re-election, appointment or retention. City Code Article VIII Division 2 is attached for reference. For comparison, staff gathered examples of other entities’ financial disclosure requirements, including: 1) Colorado; and 2) Denver; and 3) Aurora; and 4) Colorado Springs. CITY FINANCIAL IMPACTS Page 040 City Council ERB Agenda Item Summary – City of Fort Collins Page 2 of 2 Not applicable. BOARD / COMMISSION / COMMITTEE RECOMMENDATION Not applicable. PUBLIC OUTREACH Not applicable. ATTACHMENTS 1. City Code Article VIII Division 2 2. Other entities’ financial disclosure requirements: State of Colorado; Denver; Aurora; Colorado Springs. Page 041 CHAPTER 2 - ADMINISTRATION ARTICLE VIII. - FINANCIAL DISCLOSURE Division 2 Financial Disclosure Fort Collins, Colorado, Municipal Code Created: 2025-03-24 09:10:26 [EST] (Supp. No. 149) Page 1 of 3 Division 2 Financial Disclosure Sec. 2-636. Financial disclosure required. Any candidate for the office of City Councilmember shall, at the time of filing their acceptance of nomination with the City Clerk, file with the City Clerk a written disclosure statement that conforms to the requirements of § 2-637. Such a written disclosure statement shall also be filed with the City Clerk by the City Manager and the City Attorney not later than thirty (30) days after their appointment, and then each subsequent year in office no later than January 10. Each member of the City Council who is elected, re-elected, appointed or retained in office shall also file such a written disclosure statement with the City Clerk not later than January 10 next after their election, re-election or appointment and then each subsequent year in office no later than January 10. However, any City Councilmember who is elected or re-elected and who has, prior to said election or re-election, filed a written disclosure statement within ten (10) days after filing acceptance of nomination, may file an amended statement with the City Clerk or notify the City Clerk in writing that there has been no change in the disclosures made therein, since the date of filing of the same. (Code 1972, § 8-1(A); Ord. No. 146, 2000, § 1, 11-7-00; Ord. No. 115, 2018, § 2, 9-18- 18; Ord. No. 109, 2020, § 2, 9-15-20; Ord. No. 046, 2023, § 2, 4-4-23) Sec. 2-637. Requirements. Financial disclosure shall include: (1) The source or sources of any income, including capital gains whether or not taxable of the person making disclosure and such person's spouse; (2) Any financial interest in excess of ten thousand dollars ($10,000.) in any business entity; (3) The legal description of any interest in real property owned by the person making disclosure or such person's spouse; (4) The identity by name of all offices and directorships held by the person making disclosure and such person's spouse; (5) The name of each creditor to whom the person making disclosure or such person's spouse owes money in excess of ten thousand dollars ($10,000.); (6) A list of businesses with which the person making disclosure or such person's spouse are associated that do business with or are regulated by the City and the nature of such business or regulation; (7) Such additional information as the person making disclosure might desire. Page 042 Created: 2025-03-24 09:10:26 [EST] (Supp. No. 149) Page 2 of 3 (Code 1972, § 8-1(B); Ord. No. 123, 2011, 10-4-11) Sec. 2-638. Amended statement. Any person required to file a disclosure statement after his or her election, re-election, appointment or retention in office, shall on or before May 15 of each calendar year after the year in which his or her election, re-election, appointment or retention in office occurs, file an amended statement with the City Clerk or notify the City Clerk in writing that there has been no change in the information shown on the last previous disclosure statement. (Code 1972, § 8-1(C); Ord. No. 146, 2000, § 2, 11-7-00) Sec. 2-639. Notice. The City Clerk shall give written notice to each person required to make disclosure at least thirty (30) days before such disclosure is required to be filed. (Code 1972, § 8-1(C)) Sec. 2-640. Public record. Each disclosure statement, amended statement or a notification that no amendment is required shall be public information available to any person upon request during normal working hours. (Code 1972, § 8-1(D)) Sec. 2-641. Federal income tax alternative. Any person subject to the provisions of this Division may elect to file with the City Clerk annually a copy of such person's federal income tax return and any separate federal income tax return filed by such person's spouse together with a statement of any investments held by such person or such person's spouse which are not reflected by the income tax returns in lieu of complying with the provisions of §§ 2-636, 2-637 and 2-638 which tax return and any statement filed under the provisions of this Section shall be public information. (Code 1972, § 8-1(E)) Sec. 2-642. Penalty. Any person who willfully files a false or incomplete disclosure statement, amendment or notice that no amendment is required or who willfully files a false or incomplete copy of any federal income tax return or a false or incomplete certified statement of investments or who willfully fails to make any filing required by this Division shall be guilty of a Page 043 Created: 2025-03-24 09:10:26 [EST] (Supp. No. 149) Page 3 of 3 violation of the Code punishable as a misdemeanor, and shall upon conviction be punished by a fine not to exceed the limits established in § 1-15. (Code 1972, § 8-1(F)) Secs. 2-643—2-655. Reserved. Page 044 STATE OF COLORADO § 24-6-202. Disclosure--contents--filing--false or incomplete filing—penalty (1) Not later than January 10 of each calendar year, each of the following individuals shall file an annual disclosure statement with the secretary of state of Colorado in such form as the secretary of state prescribes, stating the information specified in subsection (2) of this section: (a) Each member of the general assembly; (b) The governor, lieutenant governor, secretary of state, attorney general, and state treasurer; (c) Each justice or judge of a court of record; (d) Each district attorney; (e) Each member of the state board of education; (f) Each member of the board of regents of the university of Colorado; (g) Each member of the public utilities commission. (h) Repealed by Laws 1985, S.B.179, § 1. (1.3) If an individual begins serving in one of the positions specified in subsection (1) of this section after January 10 and has not filed a disclosure statement within the previous thirty days, the individual shall file a disclosure statement no later than ten days after assuming the position. (1.5) The provisions of subsection (1) of this section apply to any individual who is serving in any position specified in subsection (1) of this section on or after January 1, 2024. If an individual who is specified in subsection (1) of this section is serving in office in the 2024 calendar year but has not filed an annual disclosure statement in the 2024 calendar year, the individual shall file a disclosure statement no later than July 1, 2024, or in accordance with the requirements specified in subsection (1.3) of this section, whichever is sooner. (1.7) Repealed by Laws 2024, Ch. 468 (S.B. 24-210), § 51, eff. June 6, 2024. (2) Disclosure must include the following for the previous calendar year, unless otherwise specified: (a) The names, and amounts, disclosed as a range as provided in the form prescribed by the secretary of state, of any source or sources of any income, including capital Page 045 gains, whether or not taxable, of the person making disclosure, the person's spouse, and any minor children residing with the person making the disclosure; (b) The name of each business, insurance policy, or trust in which he, his spouse, or minor children residing with him has a financial interest in excess of five thousand dollars; (c) The legal description of any interest in real property, including an option to buy, in the state in which the person making disclosure, his spouse, or minor children residing with him have any interest, direct or indirect, the market value of which is in excess of five thousand dollars; (d) The identity, by name, of all offices, directorships, and fiduciary relationships held by the person making disclosure, the person's spouse, and any minor children residing with the person making the disclosure, including whether the position is compensated or uncompensated; (e) The identity, by name, of any person, firm, or organization for whom compensated lobbying is done by any person associated with the person making disclosure if the benefits of such compensation are or may be shared by the person making disclosure, directly or indirectly; (f) The name of each creditor to whom the person making disclosure, the person's spouse, or the person's minor children owe money in excess of one thousand dollars, including the interest rate and the highest amount owed, disclosed as a range as provided in the form prescribed by the secretary of state, for the calendar year covered in the statement; (g) A list of businesses with which the person making disclosure or his spouse are associated that do business with or are regulated by the state and the nature of such business or regulation; (h) The sources of compensation exceeding five thousand dollars received by the person making the disclosure or the person's business affiliation for services provided directly by the person making the disclosure during the current year and during the prior calendar year, if the source is a person or entity that is regulated by the state or pays for a lobbyist that conducts lobbying at the general assembly or at a state regulatory body. This includes the names of clients and customers of any affiliated corporation, firm, partnership, or other business enterprise and a description of the duties performed or services rendered for each source of compensation if the person making the disclosure directly provided the services generating a fee or payment of more than five thousand dollars. The person making the disclosure may exclude any information considered confidential as a result of a privileged relationship recognized by law. If the person making the disclosure withholds information as a result of a privileged relationship, the person shall still disclose the existence of the source of compensation and an explanation for why information was withheld. Page 046 (i) Any additional information that the person making the disclosure deems necessary. (3) Any disclosure statement shall be amended no more than thirty days after any termination, acquisition, or substantial change of interests as to which disclosure is required. (4) Repealed by Laws 2024, Ch. 468 (S.B. 24-210), § 51, eff. June 6, 2024. (5) Each disclosure statement is public information and shall be made available on the secretary of state's website. (6) Repealed by Laws 2024, Ch. 468 (S.B. 24-210), § 51, eff. June 6, 2024. (7) Any person who willfully files a false or incomplete disclosure statement, or who willfully fails to make any filing required by this section is guilty of a misdemeanor and, upon conviction thereof, shall be punished by a fine of not less than one thousand dollars nor more than five thousand dollars. (8) In addition to any other process provided in law or rule, including article XXIX of the state constitution, any person who believes an official listed in subsection (1)(a) of this section is not substantially complying with the requirements of this section may file a complaint with the following: (a) The secretary of the senate and the president of the senate for members of the senate; and (b) The chief clerk of the house of representatives and the speaker of the house of representatives for members of the house of representatives. (9) Upon receiving a complaint, the person or persons receiving the complaint shall follow any existing procedures for investigating ethics complaints or violations. (10) If an official specified in subsection (1)(a) of this section does not timely file the required annual disclosure statement, the secretary of state shall forward notification to the appropriate individual specified in subsection (8) of this section. Amended by Laws 1979, S.B.229, §§ 1, 2; Laws 1985, S.B.179, §§ 1, 6; Laws 2010, Ch. 151, § 5, eff. July 1, 2010; Laws 2022, Ch. 108 (H.B. 22-1156), § 3, eff. Aug. 10, 2022; Laws 2023, Ch. 399 (S.B. 23-276), § 53, eff. Jan. 1, 2024; Laws 2024, Ch. 468 (S.B. 24- 210), § 51, eff. June 6, 2024. Page 047 DENVER Sec. 2-72. Annual financial disclosure statement and semi-annual gift disclosure statement. (a) Form of statement; duty of clerk. The clerk shall prepare forms for reports required by this article and furnish the forms free of charge for use by officers who are required by this article to make reports. The report forms will not include any requirement to disclose sensitive personally identifying information, such as social security numbers or bank account numbers. (b) Annual financial disclosure statement required. Officers shall file their annual financial report for calendar year 2016 no later than January 31, 2017, under the reporting requirements in effect during 2016. Beginning in 2018, every officer as defined in section 2-71(4) shall file a financial disclosure statement with the clerk no later than January 31 of each year. The report shall cover the period from January 1 to December 31 of the prior year. (c) Semi-annual gift disclosure statement required. Beginning on July 31, 2017, every officer as defined in section 2-71(4) shall file a gift disclosure with the clerk on or before January 31 and July 31 of each year. The January 31 report shall cover the period from July 1 to December 31 and the July 31 report shall cover the period from January 1 to June 30. The report shall include the identification, estimated value, and the source of any gifts which were accepted under sections 2-60(b)(4), (7), (9) and (10) received by the officer during the reporting period. Officers are required to report gifts from persons pursuing business with the city or with whom the city has an existing, ongoing, or pending contract, business, or regulatory relationship and over whom the officer may take direct official action as defined in section 2-52(b). (d) Information required in financial disclosure statement. The financial disclosure statement required of officers shall contain the following information for the reporting year (excluding the actual dollar amounts): (1) The name of each business in which the officer and/or that officer's spouse owned any securities or other financial interest in excess of one (1) percent or five thousand dollars ($5,000.00), and the name of the person holding the financial interest; (2) The names of any sources of income received by the officer, including capital gains, whether or not taxable, which exceeded two thousand dollars ($2,000.00); provided, that the amounts of such incomes need not be disclosed; (3) The names of all persons or employers, other than the city, for whom the officer performed compensated lobbying; (4) The names of the creator, beneficiaries or ownership of any private trust for the benefit of the officer and a description of the assets held by the trust when the value exceeds five thousand dollars ($5,000.00); Page 048 (5) A listing of all real property or interest therein owned by the officer at any time during the reporting year, including options to purchase, located in the state, together with the location and name, if any, by which such property is commonly known, whether the real property was owned outright or held in whole or in part under a corporation or partnership; except that, home addresses of the officer or family immediate members need not be listed; (6) The transfer by the officer of any assets with a value in excess of five thousand dollars ($5,000.00) to an immediate family member during the reporting year or during the previous two (2) years; (7) The name of each creditor owed an amount in excess of five thousand dollars ($5,000.00); and (8) The names of any current employer and any employer for whom the officer worked during the period from July 1 of the year prior to the calendar year through December 31 of the reporting year. (e) Disclosure with respect to immediate family members. The officer shall also disclose the information described in subsection (d) for any financial interest of an immediate family member which is held jointly, derived from the income or assets of the officer, or may be materially affected by a direct official action of the officer as defined in section 2-52(b) DRMC; and shall list the name of the person holding the financial interest. (f) Public records. Financial disclosure statements filed pursuant to section 2-72(b) and gift disclosure statements filed pursuant to section 2-72(c) shall be public records. The city clerk will make the completed statements available to the public on line within a reasonable time, not to exceed seven (7) business days after the date of receipt of the completed statements. (Code 1950, § 115.3; Ord. No. 846-94, § 1, 10-24-94; Ord. No. 456-95, § 1, 6-26-95; Ord. No. 1098-02, § 1, 12-30-02; Ord. No. 113-09, § 3, 2-23-09; Ord. No. 919-16, § 1, 1-9-17; Ord. No. 1202-16, § 12, 3-6-17; Ord. No. 794-17, § 1, 8-21-17; Ord. No. 614-18, § 3, 7-9-18) Sec. 15-33. Candidate affidavit, financial disclosure, and committee designation. (a) Candidate affidavit. Within ten (10) days after becoming a candidate for the applicable election cycle each candidate shall affirm to the clerk and recorder that the person is familiar with the provisions of this article. (b) Financial disclosure. All candidates shall file a financial disclosure statement containing the information required by section 2-72 with the clerk and recorder within ten (10) days after becoming a candidate for the applicable election cycle. (c) Committee designation. A candidate shall designate a candidate committee for the applicable election cycle no later than ten (10) days after becoming a candidate and shall file, or cause the committee to file, a statement of organization as provided in this division. Page 049 (1) Except as provided in subsection (2), a candidate may only designate one (1) candidate committee during the election cycle. (2) A candidate may designate one (1) other candidate committee for a separate city office before closing the original committee solely in order to transfer funds to the new committee if the candidate transfers money from the original committee to the new committee, then closes the original committee no later than ten (10) days after such transfer. (Ord. No. 1676-24, § 1, 2-18-25) Page 050 AURORA Sec. 1-63. Annual financial disclosure statement. (a) On or before the second Monday in January of each year, financial disclosure statements, on forms to be supplied by the city clerk, shall be made to and filed with the city clerk by the following people: (1) Mayor and each member of the city council. (2) City manager. (3) City attorney. (4) All appointed members of the planning and zoning commission and the board of adjustments and appeals. (b) Each financial disclosure statement shall contain the following information: (1) The source of any income or losses, including sources of income, losses and capital gains held by the spouse of the person making the disclosure or held jointly with the spouse of the person making the disclosure and also including the source of any other income, losses or capital gains sustained by the person making the disclosure held or owned jointly with any other third party, not the spouse of the person making the disclosure, over which the person making such disclosure has the right to the majority control of such source of income, losses or capital gains when: a. The appointed or elected official is in a position to take direct official action with the entity that is the source of income, losses or capital gains; or b. The city has an existing, ongoing, or pending contract, business, or regulatory relationship with the entity that is the source of income, loss or capital gains. (2) Any insurance policy or trust owned by or created and endowed by a third person, other than the person making the disclosure and such person's spouse, the value of which is in excess of $5,000, which the person making the disclosure or the person making the disclosure and such person's spouse are joint beneficiaries. (3) Indicate whether and how many real properties and mineral rights leases are located in the city in which the person making the disclosure, solely or jointly with such person's spouse, has an interest if the value exceeds$5,000. This subsection shall not apply to the appointed or elected official's personal residence or appurtenances thereto. (4) The identity, by name, of all offices, directorships and fiduciary positions held by the person making the disclosure and such person's spouse, if such positions are with groups or organizations organized for profit. Page 051 (5) The identity, by name, of any person for whom lobbying is done, other than a municipal corporation or organization sponsored by a municipal corporation, and the identity of each lobbyist associated with the person making the disclosure. (6) Businesses for profit located in or doing business in the city in which the person making the disclosure engages in a transaction for mutual gain. (c) All financial disclosure statements filed pursuant to this section shall be public records. (Ord. No. 2020-06, § 1, 4-6-2020; Ord. No. 2019-51, § 2, 8-19-2019; Ord. No. 2016-35, § 16, 8-8-2016) Page 052 COLORADO SPRINGS 5.2.103: CANDIDATE AND ELECTED OFFICIAL DISCLOSURE REQUIRED: A. In addition to any other disclosure required by part 2 of this article, every candidate shall file a Disclosure of Substantial Private Business Interests form disclosing his or her substantial private business interests, and the substantial private business interests of his or her spouse, within ten (10) days after filing an Affidavit of Independent Candidacy, except that the candidate shall not be required to disclose information about real property used as the primary residence of the candidate or the candidate's spouse. B. In addition to any other disclosure required by part 2 of this article, every elected official shall file a Disclosure of Substantial Private Business Interests form disclosing his or her substantial private business interests, and the substantial private business interests of his or her spouse, by April 30 each year if the elected official is in office on that date, except that the elected official shall not be required to disclose information about real property used as the primary residence of the elected official or the elected official's spouse. C. Every Disclosure of Substantial Private Business Interests form shall be signed under penalty of perjury, filed with the City Clerk, and in the following form: DISCLOSURE OF SUBSTANTIAL PRIVATE BUSINESS INTERESTS Name of Elected Official or Candidate Residence Address SECTION 1 INTERESTS IN ENTITIES List each investment or any other interest, whether direct or indirect, in every business entity, commercial venture, or real property, or a beneficial interest in a trust or any asset if the investment, interest, business entity, commercial venture, real property, trust, or other asset is one that does business in or is located in El Paso County, Colorado. Name of Entity, Address, Nature of Busines s (Includin g Commer Is Intere st Held Directl y or Indirec tly Busine ss conduc ted in El Paso County, CO Financia l Interest (Stock, Investm ent, Other) Fair Market Value of Financi al Interes ts (as of Reporti Percent Owners hip of 5 Percent or Greater Positio ns Held in Entity (Office r, Direct or) Intere st is Held by: (Self, Spou se, Both) Comme nts Page 053 Venture Trusts and Interests Held By Another Person on Your Availab le or Dec. 31 if Not Availab le) SECTION 2 REAL ESTATE Real Property Address (El Paso County Only, Exclude Personal Residence) Is Interest Held Directly or Indirectly Fair Market Value (as of Reporting Date if Available or Dec. 31 if Not Available) Owned by (Self, Spouse, Both) Comments Use additional pages as necessary Page 1 of Under penalty of perjury I certify that to the best of my knowledge and belief the information contained on this form is true and correct. Printed Name: Signature: Date: D. The form required by this section may be filed and signed electronically under a system maintained by the City Clerk. E. The computation of time for filings under this part shall be controlled by section 1.1.105 of this Code. (Ord. 12-91) Page 054