CEO 81-63 -- September 17, 1981

QUARTERLY CLIENT DISCLOSURE

PRESENTATIONS BEFORE LOCAL GOVERNMENT ENTITIES BY DEVELOPMENT AUTHORITY MEMBER

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

SUMMARY:

Under Section 112.3145(4), Florida Statutes, each local or state officer or employee who is required to file financial disclosure also is to file a quarterly report of the names of clients represented for a fee or commission, except for appearances in ministerial matters, before agencies at his level of government. This statute requires a local officer to disclose representations made before agencies of the political subdivision in which he serves, but not representations before agencies of other political subdivisions. CEO 80-63 is referenced.

QUESTION:

Is a member of a City Development Authority required to disclose representations made before governing bodies of cities other than the one which he serves?

Your question is answered in the negative.

In your letter of inquiry you advise that recently you have been appointed a member of the City of Gainesville Development Authority. You also advise that you are a member of a professional, consulting actuarial firm which does a substantial amount of municipal work throughout the State. In most instances, the work is performed for a retirement board of trustees which administers the city's retirement system and fund. Often when the firm has completed a particular assignment, it is requested by the board of trustees to present and explain the results of the firm's work to the city commission or council. In a telephone conversation with our staff, you advised that your firm presently does not perform this type of work for any agency of the City of Gainesville.

The Code of Ethics for Public Officers and Employees provides that each local or state officer or employee who is required to file financial disclosure also shall file "a quarterly report of the names of clients represented for a fee or commission, except for appearances in ministerial matters, before agencies at his level of government." Section 112.3145(4), Florida Statutes. We previously have advised that this statute requires a local officer to disclose representations before agencies of the political subdivision in which he serves, but not representations before agencies of other political subdivisions. See CEO 80-63, a copy of which is enclosed.

Accordingly, we find that you are not required to disclose representations made by your firm before the governing body of municipalities other than the one which you serve as a member of its Development Authority.