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RES-2014-209 RESOLUTION NO. 2014 - 209 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ANAHEIM APPROVING AMENDMENTS TO THE CONFLICT OF INTEREST CODE FOR THE CITY AND VARIOUS CITY AGENCIES. WHEREAS, pursuant to the requirements of the Political Reform Act, Section 81000, et seq. of the Government Code of the State of California ("Act"), the City of Anaheim ("City"), the Anaheim Housing Authority ("Authority"), the Successor Agency to the Anaheim Redevelopment Agency ("Successor"), the Anaheim Public Financing Authority ("APFA"), the Anaheim Public Improvement Corporation ("APIC"), the Industrial Development Authority of Anaheim ("[DA"), and the Anaheim Public Housing and Improvements Authority ("APHIA") have or will file Statement of Economic [nterests under the Conflict of Interest Codes (Authority, Agency, APFA, AP1C and IDA shall hereafter be referred to collectively as the "Agencies"); and WHEREAS, pursuant to Government Code Section 82011 of the Act, the City Council is the Code Reviewing Body for any City agency within its jurisdiction (except the City Council), which includes the Agencies; and WHEREAS, the City Council has previously adopted the terms of 18730, the Conflict of Interest Code terms promulgated by the Fair Political Practices Commission ("FPPC") (2 Calif. Code of Regulations §18730.); and WHEREAS, the City Council, as the Code Reviewing Body under the Act, adopts, affirms and incorporates by reference the Conflict of Interest Code set forth in Regulation 18730, including any amendments to it duly adopted by the FPPC (the "Code"), on behalf of the City and the Agencies; and WHEREAS, the City Council has previously adopted a Code which established disclosure categories and included a list of designated positions required to file a Statement of Economic Interests, which disclosure categories and list of designated positions were heretofore adopted as Appendices A and B of said Code, respectively, and which Appendix B has heretofore been amended by Resolution of the City Council; and WHEREAS, changed circumstances, including the establishment and deletion of certain departmental positions, as well as changes in job titles and responsibilities, necessitate further changes in Appendix B setting forth the designated positions. NOW THEREFORE, be it resolved by the City Council of the City of Anaheim as follows: 1. Appendix B of the City of Anaheim Conflict of Interest Code is superseded and a new Appendix B, attached hereto and incorporated by reference herein, is hereby added to the Code effective on the date the City Council approves and adopts this Resolution. 2. Those employees or officials whose positions are designated in Appendix B for the first time are required to file an initial statement as defined by the Act. BE [T FURTHER RESOLVED that this Resolution shall supersede any prior Resolutions of the City Council to the extent of any inconsistency between the provisions thereof. THE FOREGOING RESOLUTION is approved and adopted by the City Council of the City of Anaheim this 23` day of December, 2014, by the following roll call vote: AYES: Mayor Tait, Council Members Murray, Brandman, Kring and Vanderbilt NOES: None ABSENT: None ABSTAIN: None CITY OF ANAHEIM By: MAYOR OF THE CITY OF ANAHEIM ATTEST• CITY CLERK OF THE CITY OF A AHEIM CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE ADMINISTRATION DEPARTMENT Exhibit A Designated Positions Disclosure Categorv Assistant City Manager 1 Audit Manager 2, 3, 4 Chief Communications Officer 1 Council Aide I, II 1 Council Assistant II 1 Deputy City Manager 1 Management Auditor II 2, 3, 4 Mayor's Assistant 1 Senior Policy Aide I Senior Management Auditor 2, 3, 4 Tax Revenue Auditor 2, 3, 4 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 1 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE CITY ATTORNEY'S DEPARTMENT Exhibit B Desi�nated Positions Disclosure Categorv Assistant City Attorney 1 Civil Liability Claims Adjuster 1 Deputy City Attorney 1 Law Office Administrator 1 Paralegal 1 Senior Assistant City Attorney 1 Consultant* I * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 2 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE CITY CLERK'S DEPARTMENT Exhibit C Desi�nated Positions Disclosure Cate�orv Assistant City Clerk 1 City Clerk 1 Records and Information Manager 3 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 3 of 26 _ __ CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE CITY TREASURER'S DEPARTMENT Exhibit D Desi�nated Positions Disclosure Categorv Administrative Assistant 3 Collections Supervisor 3 Principal Accountant 7 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 4 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE COMMUNITY DEVELOPMENT DEPARTMENT Exhibit E Designated Positions Disclosure Categorv Acquisition Consultant 5 Administrative Analyst 3 Administrative Assistant 3 Administrative Services Manager 1 Affordable Housing Specialist 5 Community Development Manager 1 Community Investment Manager 5, 8 Deputy Community Development Director 1 Executive Director Community Development 1 Family Self Sufficiency Supervisor 5 Financial Accounting Manager 1 Housing Authority Manager 1 Housing Coordinator 5 Housing Loan Counselor I 5, 8 Housing Loan Counselor II 5, 8 Housing Programs Administrator 3, 5, 8 Housing Programs Manager 1 Housing Services Administrator 3, 5, 8 Housing Specialist I/II 5 Management Assistant 3 Neighborhood Development Coordinator 3, 5, 8 Neighborhood Preservation Coordinator 3, 5, 8 Project Manager UII 5, 8 Senior Accountant 3 Senior Administrative Analyst 3 Senior Project Manager 5, 8 Senior Project Manager, PT 5, 8 Special Project Manager 5, 8 Special Project Manager PT 5, 8 December 23, 2014 Page 5 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE COMMUNITY DEVELOPMENT DEPARTMENT Page 2 Exhibit E Desi�nated Positions Disclosure Categorv Staff Analyst 3 Workforce Center Administrator 3 Workforce Center Supervisor 3 Workforce Development Manager 1 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 6 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE COMMUNITY SERVICES DEPARTMENT Exhibit F Desi�nated Positions Disclosure Categorv Administrative Analyst 3 Administrative Assistant 3 Associate Project Planner 3 City Librarian 1 Communications Specialist [I 3 Community Services Director 1 Community Services Manager 1 Community Services Superintendent 3 Community Services Supervisor 3 Golf Course Superintendent 3 Golf Manager 1 Library Services Manager 1 Library Services Manager 1 Parks Manager 1 Park Services Superintendent 3 Principal Librarian 3 Principal Project Planner 1 Supervising Librarian 3 Consultant * 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 7 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE CONVENTION, SPORTS AND ENTERTAINMENT DEPARTMENT Exhibit G Designated Positions Disclosure Cate�orv Assistant Facility Services/Parking Manager 3 Box Office Manager 3 Convention Center Manager 1 C/S/E Systems/Contracts Administrator 1 Employee Development Specialist II 3 Enterprise Administrative Services Manager 1 Event Manager I/II 1 Event Services Manager 1 Executive Director 1 Facility Services/Parking Manager 3 Financial Accounting Manager 1 Lead Facility and Event Electrician 3 Lead Facility Maintenance Worker 3 Lead HVAC Mechanic 3 Operations Superintendent 3 Operations Supervisor 3 Senior Accountant 3 Senior Booking & Contracts Coordinator 1 Security Manager 3 Senior Storekeeper 3 Stores and Wardrobe Manager 3 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 8 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE FINANCE DEPARTMENT Exhibit H Designated Positions Disclosure Categorv Acquisition Specialist (EDS) 2 Assistant Information Services Manager 3 Assistant Purchasing Agent 2 Buyer I, I] 2 Deputy Finance Director 1 Finance Director 1 Information Systems Manager 1 Purchasing Agent 1 Senior Buyer 2 Consultant * 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 9 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE FIRE DEPARTMENT Exhibit I Designated Positions Disclosure Cate�orv Administrative Analyst 3 Administrative Captain 3 Administrative Services Coordinator 3 Administrative Services Manager 3 Arson Investigator 4, 5 Fire Communications Manager 3 Deputy Chief 1 Deputy Fire Marshal 4 Battalion Chief/Emergency Management 2 Preparedness EMS Coordinator 3 External Affairs Manager 3 Fire Battalion Chief 4 Fire Captain 4 Fire Chief 1 Fire Inspector 4 Fire Marshal 1 Fire Safety Specialist 4 Haz Mat Specialist 4 Investigation Coordinator 4, 5 Public Information Officer 3 Senior Haz Mat Specialist 4 Senior Store Keeper 3 Staff Analyst 4 Training Officer 1 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 10 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE HUMAN RESOURCES DEPARTMENT Exhibit J Desi�nated Positions Disclosure Categorv Administrative Services Manager 3 Assistant Risk Manager 6 Claims Examiner 6 Deputy Human Resources Director 1 Employee Relations Manager 1 Human Resources Analyst I and II 3 Human Resources Director 1 Principal Human Resource Analyst 3 Risk Manager 1 Senior Development Specialist 3 Senior Human Resources Analyst 3 Workers Compensation Manager 6 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 11 of 26 _ CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE PLANNING DEPARTMENT Exhibit K Designated Positions Disclosure Category Accounting Technician 3, 4 Administrative Analyst 3 Assistant Building Official 1 Assistant Planner 1 Associate Planner 1 Building Inspection Supervisor 4, 5 Building lnspector I, II, III, FT & PT 4, 5 Building Official 1 Business Information Systems Administrator 4, 5 Community Preservation Manager 1 Community Preservation Officer I, I1, PT & FT 4, 5 Community Preservation Supervisor 1 Licensing Specialist 3, 4 Permit Counter Supervisor 4, 5 Plan Check Supervisor 4, 5 Plan Checker II 4, 5 Planning Aide 8 Planning Director 1 Planning Services Manager 1 Plans Examiner I 5 Plans Examiner II 5 Principal Planner 1 Revenue & Licensing Supervisor 3, 4 Senior Code Enforcement Officer 4, 5 Senior Planner 1 Senior Plans Examiner 4, 5 Technology Development Manager 1 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 12 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE POLICE DEPARTMENT Exhibit L Designated Positions Disclosure Categorv Budget and Financial Manager 1 Captain 1 Chief of Police 1 Communications Manager 1 Correctional Manager 1 Deputy Chief of Police 1 Homeland Security Bureau Sergeant 1 Lieutenant 1 Police Records Manager 1 Staff Analyst 3 Division Commander 1 Consultant* l * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 13 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE PUBLIC UTILITIES DEPARTMENT Exhibit M Designated Positions Disclosure Cate�orv Assistant Business Information Systems Manager 5 Assistant Customer Service Manager 3 Utilities Assistant General Manager 1 Associate Engineer 3 Associate Power Engineer 5 Business Information Systems Analyst I/II/III 7 Business Information Systems Manager 5 Utilities Systems Operator 3 Cross Connection Control Specialist I, II 5 Electrical Capital Projects Manager 3 Electric Crew Supervisor 5 Electric Field Manager 5 Electric Field Superintendent 3 Electric Operations Manager 3 Electric System Planning Manager 1 Electric Systems Designer 5 Electrical Utility Inspection Supervisor 5 Electric Utility Inspector 5 Employee Development Specialist I, II 6 Energy Risk/Transaction Supervisor 7 Energy Risk, Wholesale Settlements and Regulatory 1 Affairs Manager Engineering Manager 1 Enterprise Administrative Services Manager 6 Environmental Services Manager 3 Environmental Services Specialist 4 Utilities Financial Planning Manager 1 Utilities General Manager 1 Generation Plant Manager 3 December 23, 2014 Page 14 oF26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE PUBLIC UTILITIES DEPARTMENT Page 2 Exhibit M Designated Positions Disclosure Categorv Integrated Resource Planner UII 4 Integrated Resources Manager 1 Line Crew Supervisor 5 Line Mechanic 5 Management Assistant 3 Power Resource Scheduler I/II 5 Principal Accountant 7 Principal Civil Engineer 5 Principal Electrical Engineer 3 Principal Integrated Resource Planner 5 Principal Power Systems Planning Engineer 5 Product Development Specialist I, II 3 Real Property Analyst 5 Records & lnformation Manager 3 Resource Efficiency Advisor I/II 5 Resource Programs Specialist 3 Revenue Protection Coordinator 5 Safety Administrator 6 SCADA Systems Analyst I, II, III 5 Senior Accountant 7 Senior Administrative Analyst 3 Senior Electrical Engineer 3 Senior Electric System Designer 5 Senior Electrical Utility Inspector 5 Senior lntegrated Resource Planner 3 Senior Power Systems Planning Engineer 5 Senior Power System Planning Specialist 5 Senior Product Development Specialist 3 Senior Utilities Systems Scheduler 3 Senior Water Utility Inspector 3 December 23, 2014 Page 15 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE PUBLIC UTILITIES DEPARTMENT Page 3 Exhibit M Designated Positions Disclosure Cate�orv Substation/Automation Engineering Manager 3 Substation Electrician Supervisors 5 Substation Test Technician Supervisor 5 Transmission and Distribution Manager 1 Utilities Analyst I/IUIII 7 Contract Administrator 6 Communications Specialist I, Il 3 Utilities Communications Supervisor 3 Utilities Financial Services Manager l Senior Communications Specialist 3 Utilities Strategic Planning Manager l Utilities Inventory/ Facilities Manager 2 Utilities Services Supervisar 5 Water Engineer Manager 1 Water Engineering Representative 5 Water Field Operations Manager 1 Water Field Superintendent 3 Water Inspection Supervisor 3 Water Maintenance Scheduler 5 Water Production Superintendent 3 Water Quality Laboratory Supervisor 3 Water System Operations Superintendent 3 Water Utility Inspector 3 Consultant * 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 16 of 26 __ _ CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE DEPARTMENT OF PUBLIC WORKS Exhibit N Designated Positions Disclosure Categorv Administrative Services Manager 1 Assistant Engineer A 4 Associate Engineer 4 Associate Engineer-A 4 Associate Transportation Planner 1 Auto Parts Specialist 3 Auto Parts Supervisor 1 City Engineer 1 City Surveyor 1 Civil Engineer-Development Services 1 CMMS/Auto CAD 1 Construction Inspector II 1 Construction Services Manager 1 Contracts Administrator 3, 5, 6 Contracts Specialist 3, 5, 6 Engineering Manager 1 Fleet Acquisition Administrator 1 Fleet and Facility Manager 1 Management Assistant I 1 Operations Contract Administrator 3, 5, 6 Operations Contract Specialist 1 Operations Superintendent I Operations Supervisor 1 Principal Civil Engineer 1 Principal Traffic Engineer 2,3, 4, 6 Principal Transportation Planner 4, 6 Public Works Director 1 Public Works Operations Manager 1 Real Property Analyst 5 Real Property Specialist [I 5 December 23, 2014 Page 17 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE DEPARTMENT OF PUBLIC WORKS Page 2 Exhibit N Designated Positions Disclosure Categorv Senior Civil Engineer 1 Senior Construction Inspector 1 Solid Waste Program Administrator 1 Staff Analyst 1 Street Maintenance & Sanitation Administrator 1 Supervisor of Records Management 3 Engineering Manager 1 Transit Planning Manager 1 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page l 8 of 26 CITY OF ANAHEIM CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR BOARDS AND COMMISSIONS Exhibit O Designated Positions Disclosure Categorv Housing and Community Development Commission 1 Public Utilities Board 1 Community Center Authority 1 December 23, 2014 Page 19 of 26 _ SUCCESSOR AGENCY TO THE ANAHEIM REDEVELOPMENT AGENCY CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE CITY OF ANAHEIM, AS SUCCESSOR AGENCY TO THE ANAHEIM REDEVELOPMENT AGENCY Exhibit P Designated Positions Disclosure Cate�orv Directors 1 Executive Director 1 Treasurer 1 Secretary 1 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 20 of 26 __ _ ANAHEIM HOUSING AUTHORITY CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE ANAHEIM HOUSING AUTHORITY Exhibit Q Desi�nated Positions Disclosure Category Housing Authority Directors 1 Housing Authority Executive Director 1 Housing Authority Treasurer 1 Housing Autharity Secretary 1 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 21 of 26 ANAHEIM PUBLIC FINANCING AUTHORITY CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE PUBLIC FINANCING AUTHORITY Exhibit R Designated Positions Disclosure Categorv Authority Directors 1 Authority Executive Director 1 Authority Treasurer 1 Authority Secretary 1 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 22 of 26 ANAHEIM INDUSTRIAL DEVELOPMENTAUTHORITY CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE INDUSTRIAL DEVELOPMENT AUTHORITY Exhibit S Designated Positions Disclosure Categorv Authority Directors l Authority Executive Directar 1 Authority Treasurer 1 Authority Secretary 1 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 20 ] 4 Page 23 of 26 ANAHEIM PRIVATE INDUSTRY COUNCIL CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE PRIVATE INDUSTRY COUNCIL Exhibit T Designated Positions Disclosure Categorv Authority Directors 1 Authority Executive Director 1 Authority Treasurer 1 Authority Secretary 1 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a}(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 24 of 26 OVERSIGHT BOARD OF THE SUCCESSOR AGENCY TO THE ANAHEIM REDEVELOPMENT AGENCY CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE OVERSIGHT BOARD OF THE SUCCESSOR AGENCY TO THE ANAHEIM REDEVELOPMENT AGENCY Exhibit U Designated Positions Disclosure Categorv Authority Directors 1 Authority Executive Director 1 Authority Treasurer 1 Authority Secretary 1 Consultant* 1 * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(l)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 25 of 26 ANAHEIM PUBLIC HOUSING AND IMPROVEMENTS AUTHORITY CONFLICT OF INTEREST CODE DESIGNATED POSITIONS FOR THE PUBLIC HOUSING AND IMPROVEMENTS AUTHORITY Exhibit V Designated Positions Disclosure Cate�orv Authority Directors 1 Authority Executive Director 1 Authority Treasurer 1 Authority Secretary 1 Consultant* l * As used in this Code, the term Consultant means those individuals who meet the definition of a Consultant under 2 California Code of Regulations Section 18701(1)(a)(2). Consultants shall disclose pursuant to the broadest category in this Code. December 23, 2014 Page 26 of 26 _ _.