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This article was originally published by Atkinson, Andelson, Loya, Ruud & Romo

Beginning in 2026, public officials who manage a local agency’s investment will be required to file Form 700 Statement of Economic Interest with the FPPC through FPPC’s e-filing system.

Senate Bill (SB) 852, signed into law by Governor Newsom on October 3, 2025, amends the Political Reform Act of 1974 (Government Code sections 81000 et seq.).  Specifically, SB 852 amends Government Code section 87500 to now require “a public official who manages public investments” to e-file with the FPPC instead of filing with their local agency.

According to the legislature, the intent behind SB 852 was to “fix a drafting error…that omitted public officials who manage public investments from those who must file their Form 700s electronically.” (Assembly Floor Analysis, 3rd Reading of S.B. 852, 2025–2026 Reg. Sess. (Cal. Aug. 27, 2025)).

The category of “public officials who manage public investment” is not new to the Political Reform Act. Section 87200 of the Government Code made conflicts of interest disclosures applicable to “other public officials who manage public investments.” Originally, however, these officials filed their disclosure forms locally. Now, with SB 852, they will need to file with the FPPC’s e-filing system.

While SB 852 does not define “manage” or “public investment” under Section 87500, the FPPC Regulations fill in the gap by defining these terms in relation to Government Code section 87200. Under 2 C.C.R. section 18700.3(b)(1), “[o]ther public officials who manage public investments” means:

“(A) Members of boards and commissions, including pension and retirement boards or commissions, or of committees thereof, who exercise responsibility for the management of public investments;

(B) High-level officers and employees of public agencies who exercise primary responsibility for the management of public investments, such as chief or principal investment officers or chief financial managers. This category shall not include officers and employees who work under the supervision of the chief or principal investment officers or the chief financial managers; and

(C) Individuals who, pursuant to a contract with a state or local government agency, perform the same or substantially all the same functions that would otherwise be performed by the public officials described in subdivision (b)(1)(B).”

“Public investments” encompasses the “investment of public moneys in real estate, securities, or other economic interests for the production of revenue or other financial return.” (2 C.C.R. section 18700.3(c)).

“Management of public investments” means the non-ministerial functions of “directing the investment of public moneys, formulating or approving investment policies, approving or establishing guidelines for asset allocations, or approving investment transactions.” (2 C.C.R. section 18700.3(e)).

The Draft Form 700 Reference Pamphlet, published as an attachment to the 2025/2026 Form 700 Statement of Economic Interests Interested Persons Meeting, retains and reincorporates these definitions under the Terms & Definitions.

The Notice to the Interested Persons Meeting also indicates that the FPPC’s Statement of Economic Interests Unit will send notices to filing officials in the coming months regarding implementation of SB 852 and information on how to include the new filers to the FPPC system.

In summary, starting in 2026, contracted consultants, pension and retirement board members, chief investment officers, and similar officials or contracted individuals performing non-ministerial functions with respect to public investments must e-file Form 700 with the FPPC, while junior staff will continue to file with their respective local agencies.

If you have any further questions regarding Form 700 filing procedures, please do not hesitate to reach out to one of the authors of this alert, or your AALRR attorney.

Thanks to our FCPPG post-bar law clerk, Benjamin Chen, for his work on this alert.

This is intended for informational purposes only and should not be relied upon in reaching a conclusion in a particular area of law. Applicability of the legal principles discussed may differ substantially in individual situations.