CEO 78-53 -- September 8, 1978

DEAN OF STUDENT DEVELOPMENT FOR JUNIOR COLLEGE

APPLICABILITY OF FINANCIAL DISCLOSURE REQUIREMENTS

To: (Name withheld at the person's request.)

Prepared by: Phil Claypool

SUMMARY:

The Code of Ethics for Public Officers and Employees provides that each "local officer" shall file a statement of financial interests annually. Section 112.3145(2)(b), F. S. 1977. The term "local officer" is defined in s. 112.3145(1)(a)2. to include members of a community college district board of trustees, community college presidents, and purchasing agents having the authority to make any purchase exceeding $100 for any political subdivision of the state or any entity thereof. Accordingly, one holding the position of dean of student development for a junior college, whose purchasing authority is limited to a maximum direct purchase of $24.99 from petty cash, is not deemed to constitute a "local officer" subject to disclosure.

QUESTION:

Am I, a dean of student development for a junior college, a "local officer" subject to the requirement of filing financial disclosure annually?

Your question is answered in the negative.

In your letter of inquiry you advise that presently you are employed as dean of student development for the south campus of Florida junior college at ____. You also advise that in your position the maximum direct purchase you can make on behalf of the college is $24.99 from petty cash. In addition, you advise that while you can recommend sources for other purchases by requisition, the actual purchases must be made by a college purchasing officer who actually issues the purchase order.

Under these circumstances, it is clear that you do not have the authority to make a purchase exceeding $100 on behalf of the junior college. Accordingly, we find that you are not a "local officer," and therefore that you are not subject to the requirement of filing financial disclosure annually.