Broker-Dealer_Application_(BDA)_2026_(Addendum_#3_Revision).pdf

County of Orange

Broker-Dealer Application (BDA)

BDA No.: DBA 23-000122 for

Broker-Dealer Application (BDA) 2026

Released Wednesday, September 16, 2026

Application Deadline Wednesday, October 21, 2026, 3:00 pm

Request for Broker-Dealer Applications 2 of 19 Broker-Dealer Application (BDA) 2026

TABLE OF CONTENTS

SECTION 1. STATEMENT OF POSITION AND GENERAL REQUIREMENTS

SECTION 2. PROTEST PROCEDURES

SECTION 3. EVALUATION AND SELECTION CRITERIA

SECTION 4. REQUIRED DOCUMENTATION

SECTION 5. APPLICATION FOR AUTHORIZED BROKER-DEALER

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1. STATEMENT OF POSITION AND GENERAL REQUIREMENTS

1.1. Introduction Summary

The County of Orange (County) periodically evaluates and establishes a slate of Broker-Dealers authorized to provide investment-related services to the County. Through this application process, the County will evaluate Broker-Dealers (BDs) submitting applications for potential inclusion on the County’s “Approved Broker-Dealers List.” All applicants will be evaluated based upon the

County’s requirements and other relevant factors; prior inclusion on the County’s “Approved

Broker-Dealers List” does not confer preference or guarantee continued inclusion.

1.2. Non-Binding Disclaimer

Responses and documents submitted as part of this Broker-Dealer Application are informational only and do not constitute an offer. Submission cannot be accepted by the County to form a binding agreement or commit the County to any business relationship.

The County reserves the right, in its sole discretion and subject to applicable law and County policy, to accept or reject any application, request additional information, waive immaterial deficiencies, modify or discontinue this application process, determine the number of Broker-

Dealers to be approved, and add or remove Broker-Dealers from the Approved Broker-Dealers

List as the County determines appropriate.

1.3. Timeline

Timeline dates are approximations only and do not constitute any commitment or guarantee by the County.

Release Project Date: September 16, 2026

Question Submission Deadline: October 14, 2026, 3:00pm

Response Submission Deadline: October 21, 2026, 3:00pm

1.4. Withdrawal of Application(s)

An application may be withdrawn by the applicant or an authorized representative, provided his or her identity is made known and he or she provides a receipt for the application.

1.5. Questions regarding the BDA Process and Requirements

All questions regarding this BDA are to be posted online via The County’s online bidding system

Question and Answer (Q&A) Section and will only be accepted and answered during the Q&A period that lasts until approximately one (1) week prior to the BDA closing date.

All applicants are expected to thoroughly read through the entire BDA package before posting questions. All participating applicants will simultaneously receive a notification via the County’s online bidding system that a question has been posted related to this BDA and will be available for view by all participating applicants. The County’s responses to the questions asked will be

Request for Applications 4 of 19 Broker-Dealer Application (BDA) 2026 posted as promptly as possible to the County’s online bidding system and will be available for view by all participating applicants.

The Q&A Section will close on Wednesday, October 14, 2026 at 3:00 pm Pacific Time. All applicants are encouraged to post any questions regarding the BDA by this deadline. After the close of the Q&A period, bidders may only contact OC Investments at ocinvestments@ceo.oc.gov with questions related to uploading proposals to the County’s online bidding system. No other specific solicitation-related questions will be answered.

It is up to each individual applicant to determine if their firm meets the eligibility criteria stated in the BDA prior to submitting a proposal. The County does not provide any assistance to that effect.

Applicants are to strictly follow the directions above for questions regarding this BDA. During the entire BDA process, no County representative may be contacted for questions or information regarding this BDA with the exception of OC Investments at ocinvestments@ceo.oc.gov as described above. Any violation of this direction may be deemed non-responsive with the BDA process and shall form a basis for the rejection of the application.

1.6. General Instructions for Submittal

A. Use the Application Preparation Checklist to plan and monitor solicitation application preparation as well as to verify completion of all materials before submission.

B. Applicant’s submission must clearly meet all of the requirements of this solicitation.

C. Applicants should review all requirements and instructions to ensure that each requirement is met. County shall not be responsible for any verbal instructions given by any employees of County in regard to the application instructions, specifications, or application documents as described in this solicitation.

D. Applications and requested documents must be electronically uploaded in PDF format, via the County’s online bidding system. Hard copy applications will not be accepted.

E. Allow sufficient time to upload all required files. After the application deadline, the

County’s online bidding system will not allow any uploads. If all files are not uploaded successfully by the application deadline, your firm’s application will not be accepted.

F. Provide accurate and honest information. Information that is deliberately inaccurate may prompt an investigative review and will affect the evaluation of the application.

G. Provide documentation where necessary, including items such as forms, licenses, etc.

H. If you omit any required information or data, explain why.

I. Do not include home addresses, home phone numbers, and/or personal email addresses for any employee, volunteer, Board member, etc. in your applications.

mailto:OCInvestments@ceo.oc.gov mailto:ocinvestments@ceo.oc.gov

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NOTE: Electronic applications cannot be viewed by County until after the submission deadline.

If you encounter any problems with your registration, system, application submission, or other system issues, please contact OpenGov’s support staff via the live chat option or via email at procurement-support@opengov.com.

1.7. Change of Ownership/Name and Litigation Status

Applicant agrees that if there is a change or transfer in ownership of applicant’s firm, and the

County agrees to continue conducting business with the applicant, the new owners shall be required to assume Broker-Dealer’s duties and obligations and complete them to the satisfaction of the County.

The County reserves the right to immediately terminate conducting business with the firm in the event the County determines that the assignee is not qualified or is otherwise unacceptable to the

County for the provision of services.

1.8. Conflict of Interest

Applicant shall exercise reasonable care and diligence to prevent any actions or conditions that could result in a conflict with County interests. In addition to the applicant, this obligation shall apply to the applicant’s employees, agents, and subcontractors associated with the provision of services provided. The applicant’s efforts shall include, but not be limited to establishing rules and procedures preventing its employees, agents, and subcontractors from providing or offering gifts, entertainment, payments, loans or other considerations which could be deemed to influence or appear to influence County staff or elected officers in the performance of their duties.

The County reserves the right to disqualify any applicant on the basis of any real or apparent conflict of interest that is disclosed in the application submitted or any other information available to the County. This disqualification is at the sole discretion of the County. Any applicant submitting an application herein waives any right to object to the County’s exercise of this right, now or at any future time, before anybody or agency including, but not limited to, the County

Board of Supervisors or any court of competent jurisdiction.

1.9. Confidentiality

California Public Records Act

Pursuant to California law, all information contained in an application may be public record, subject to disclosure to any member of the public who requests it through the California Public

Records Act (CPRA). If it is necessary to include proprietary/trade secret information in a response, the County recommends that the applicant clearly and prominently marks the information believed to fall within such categories.

Applicant will include a written statement as to the basis for considering the marked pages confidential including the specific harm or prejudice if disclosed and the County will review the material, applicant’s concerns and make an independent determination.

mailto:procurement-support@opengov.com

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1.10. Modifications of the BDA

The County reserves the sole right to interpret or change any provision of the solicitation at any time prior to the application submission date. Any and all interpretations or changes will be in the form of a written addendum, which will be furnished to all applicants through the County’s online bidding system. All addendums issued will become part of the solicitation and resultant expected services provided. Applicants hereby acknowledge their receipt of any addendum by being registered in County’s online bidding system and acknowledge it is the applicant’s responsibility to check for, and read all addendums posted in County’s online bidding system.

Should such addendum require information not previously requested, the County, at its sole discretion, may determine if a time extension is required for the submission of applications, in which case the addendum will indicate the new application submission date.

1.11. Broker-Dealer Screening

Broker-Dealers approved through this application process must maintain the qualifications, registrations, licenses, financial requirements, regulatory standing and other representations and certifications upon which their approval was based while on the County's Approved Broker-

Dealers List.

As part of the application process and annual review, the County may verify the firm's continued qualifications. including:

• SEC and FINRA registrations and authorization to conduct Broker-Dealer activities in

California;

• Primary Dealer status with the Federal Reserve Bank of New York, when applicable, or qualification as a regional Broker-Dealer;

• FINRA BrokerCheck registration, licensing and regulatory disclosures;

• Compliance with applicable net capital requirements, including SEC Rule 15c3-1;

• Financial condition, including audited financial statement;

• Applicable MSRB Rule G-37 political contribution disclosures;

• Regulatory, litigation, arbitration, disciplinary, or other disclosures relevant to the firm’s qualifications or suitability to conduct business with the County;

• Receipt and acknowledgment of the County’s Investment Policy.

Broker-Dealers must promptly notify the County of any material change that may affect their continued qualification, including changes in registration, licensing, regulatory standing, financial condition, ownership or key personnel.

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The County may request additional information, including explanations and corrective or remediation actions. Based on its review, the County may determine whether the Broker-Dealer remains eligible for inclusion on the Approved Broker-Dealer List.

1.12. Rejection of Application(s)

The County reserves the right to reject any application at any time during the BDA process on the basis of any substantiated actual and/or apparent conflict of interest regarding the performance of the proposed services solicited under this BDA. All applicants must self-disclose any potential and/or actual conflict of interest(s). Any applicant submitting an application herein waives any right to object to County’s exercise of this right, now or at any future time, before anybody or agency including, but not limited to, the County Board of Supervisors or any court of competent jurisdiction.

As soon as the County has determined that an applicant has a conflict of interest as stated herein, County will provide written notification of such conflict and rejection of the application.

The County also reserves the right to reject any application at any time during the BDA process on the basis of any one or more of the following substantiated grounds:

1. Evidence of collusion amongst applicants;

2. Lack of such business skills and/or financial resources necessary and appropriate to successfully operate the services solicited in this BDA, as revealed by either the financial statement or experience statement;

3. Default on, or unpaid, County debt;

4. Default on any obligation to County;

5. Current or past failure to perform to County standards, as determined by the County.

All applications that are materially incomplete, conditional, ambiguous, obscure, or otherwise fail to meet the BDA requirements may be rejected. The County will provide a written notification of the grounds upon which an application is rejected.

1.13. Minor Irregularities and Deficiencies in Application(s)

The County reserves the right at its sole discretion, to accept an application containing a minor irregularity or when a defect or variation is immaterial or inconsequential.

The County reserves the right to waive any and all minor irregularities in lieu of seeking corrections thereof. All requests for correction of minor irregularities or notification of waiver thereof will be given to applicants in writing.

1.14. Non-Responsive Application(s)

An application which fails to meet the material requirements of this BDA may be rejected as non-responsive.

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The County will provide a written notification of rejecting non-responsive applications, which will state the specific grounds for the rejection. Therefore, it is the sole responsibility of the applicants to ensure their applications are conforming and responsive to all requirements of this BDA.

1.15. Rights Reserved to County

A. Modify this BDA prior to the time applications are due, provided applicants are granted such extensions as necessary to allow sufficient time for submission of applications in response to the modified BDA.

B. Cancel this BDA at any time, in whole or in part, when it is determined that cancellation is in the best interest of the County.

C. Reject any or all applications.

D. Reject an application at any time during the BDA process for reasons stated in this BDA or for false information submitted in response to the BDA.

E. Utilize all or some of the stated services.

F. Approve multiple Applicants.

G. Ask Applicants for additional information or documentation.

1.16. Levine Act Requirement

Effective January 1, 2023, all contractors entering into a contract with the County, will be required to submit the Campaign Contribution Disclosure Form for any contributions made on or after January 1, 2023. In order to comply with this requirement, applicant agrees to furnish the required Campaign Contribution Disclosure Information form as a required submittal with its application response. Failure to include the form as required will render the application response nonresponsive.

2. PROTEST PROCEDURES

Any Broker-Dealer that participated in the application process may submit a written protest regarding the County’s selection decision. The protests must be submitted on the Broker-Dealer’s letterhead and must include the Broker-Dealer’s contact information, the specific grounds for the protest, the relief requested, and the signature of the Broker-Dealer’s authorized representative.

Protests must be received within five (5) business days following the Broker-Dealer’s receipt of notice of the County’s selection decision. The County reviews the protest and issues a written decision within ten (10) business days of receipt of the protest.

All protests must be submitted electronically to ocinvestments@ceo.oc.gov.

3. EVALUATION AND SELECTION CRITERIA

mailto:ocinvestments@ceo.oc.gov

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The County will evaluate all eligible applicants using a standardized scoring matrix. Applicants will be ranked based on the following criteria and weights.

Each applicant will be scored based on the information provided in its application packet and any additional information requested or obtained by the County as part of the evaluation process. The applicable scores will be weighed in accordance with the percentages above to determine each applicant’s overall ranking.

Applicants must also satisfy all mandatory eligibility, regulatory, and compliance requirements established by the County. Failure to meet a mandatory requirement may result in disqualification from further consideration.

Following completion of the evaluation process, the County will select the highest-ranked firms for inclusion on the County’s Approved Broker-Dealers List, based on the number of firms determined appropriate to meet the County’s investment and operational needs.

Submission of an application does not guarantee selection or approval. Current authorization or an existing business relationship with the County does not guarantee continued inclusion on the

Approved Broker-Dealers List.

No. Evaluation Criteria Scoring Method Weight (Points)

1. Client Services

Evaluation is based on service level agreement language and compliance & regulatory profile.

Points Based 20 (20% of Total)

2. References

Considers the relevance and quality of references provided and reputation.

Points Based 20 (20% of Total)

3. Investment Types

Assesses the BD’s ability to transact across multiple asset classes.

Points Based 15 (15% of Total)

4. Trade ID Confirms

Evaluates the efficiency and timeliness of trade confirmations provided to the County’s custodian.

Points Based 15 (15% of Total)

5. Net Capital Requirement (SEC Rule 15c3-1)

Measures the BD’s financial strength.

Points Based 10 (10% of Total)

6. Primary Dealer Status

Recognizes BDs that meet federal qualification standards and provide greater liquidity.

Points Based 5 (5% of Total)

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7. Electronic Trading Platform

Reviews the BD’s use of industry-standard electronic trading platforms (such as

Bloomberg, Tradeweb, MarketAxess) and the range of execution channels available.

Points Based 5 (5% of Total)

8. Research Portal

Evaluates BD’s ability to provide a dedicated website or research portal that offers timely and reliable market data, research reports, etc.

Points Based 5 (5% of Total)

9. Firm/Personnel Experience

Evaluates the experience and expertise of the

BD’s team, including coverage depth, execution capabilities, and specialized knowledge of certain asset classes.

Points Based 5 (5% of Total)

4. REQUIRED DOCUMENTATION

The County must receive the following documents from each existing and prospective Broker-

Dealer:

A. A completed Broker-Dealer Application

B. A copy of the firm’s most recent audited Annual Report

C. A copy of the firm’s current Form BD Status Report

D. A copy of the firm’s most recent SEC Form X-17 A-5 “Focus Report” or most recent

Consolidated Reports of Condition and Income for A Bank with Domestic and Foreign

Offices – FFIEC 031 (in the case of a bank)

E. A copy of the firm’s service level agreement or scope of service agreement that outlines trade execution, settlement, coverage/support staff and escalation paths.

F. MSRB Rule G-37 filing for the past 12 months (if not applicable, please provide reason)

G. Levine Act Campaign Contribution Disclosure Form (Government Code § 84308), completed and signed by the applicant, including disclosure of any reportable contributions, as applicable.

All currently authorized Broker-Dealers that wish to continue conducting business with the

County must submit a complete application packet by the specified deadline for consideration. Submission of a complete application is required to be eligible for inclusion on the County’s new slate of authorized Broker-Dealers, which will be established through

Request for Applications 11 of 19 Broker-Dealer Application (BDA) 2026 this application and evaluation process. Current authorization does not guarantee continued approval or inclusion on the new slate of Broker-Dealers.

5. APPLICATION FOR AUTHORIZED BROKER-DEALER

1. Name of Firm*

*Response required

2. CRD #*

*Response required

3. Firm Address*

*Response required

4. Has your firm operated under a different business name in the last 12 months?*

☐ Yes

☐ No

*Response required

When equals "Yes"

4.1. Identify the name, date of the name change, and the reason for the name change.*

*Response required

5. Is your firm currently registered as a Broker-Dealer with the Securities & Exchange

Commission (SEC), a member in good standing of the Financial Industry Regulatory

Authority (FINRA), registered or otherwise authorized to conduct broker-dealer activities in California, and in compliance with all applicable net capital requirements, including

Rule15c3-1 (net capital requirement)?*

☐ Yes

☐ No

*Response required

When equals "No"

5.1. Please explain.*

*Response required

6. Is your firm licensed to operate in California? *

☐ Yes

☐ No

*Response required

7. Primary Representative - Name*

*Response required

8. Primary Representative - Title*

*Response required

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9. Primary Representative - Phone Number*

10. Primary Representative - Email*

*Response required

11. Primary Representative - Number of years in institutional sales*

*Response required

12. Primary Representative - Number of years with firm*

*Response required

13. Primary Representative - CRD Number*

*Response required

14. Manager/Partner-in-Charge - Name*

*Response required

15. Manager/Partner-in-Charge - Title*

*Response required

16. Manager/Partner-in-Charge - Phone Number*

*Response required

17. Manager/Partner-in-Charge - Email*

*Response required

18. Manager/Partner-in-Charge - Number of years in institutional sales*

*Response required

19. Manager/Partner-in-Charge - Number of years with firm*

*Response required

20. Manager/Partner-in-Charge - CRD Number*

*Response required

21. Are you a Primary Dealer in U.S. Government Securities?*

☐ Yes

☐ No

*Response required

When equals "No"

21.1. Has your firm consistently complied with the Federal Reserve Bank’s capital adequacy guidelines over the last 12 months?*

If yes - respond with "Yes"

If no - respond with "No" and provide an explanation

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22. Are you a Regional Dealer in U.S. Government Securities?*

☐ Yes

☐ No

*Response required

23. Are you a Broker instead of a Dealer, i.e. you DO NOT own positions in Securities?*

☐ Yes

☐ No

*Response required

24. Did your firm meet the minimum net capital requirement set by the SEC’s Uniform

Net Capital Rule (Rule 15c3-1) in the latest annual report? *

☐ Yes

☐ No

*Response required

When equals "Yes"

24.1. Provide the net capital amount and the amount by which it exceeded the minimum requirement.*

For example: Net capital was $xx million, which exceeded the minimum net capital requirement of $xx million by $xx million.

*Response required

25. How many years has your firm operated as a Broker, Dealer, or Broker-Dealer?*

The County requires a minimum of five (5) years of operating in the capacity for which the firm is applying.

*Response required

26. Is your firm owned by a holding company?*

☐ Yes

☐ No

*Response required

When equals "Yes"

26.1. Provide the following information regarding the holding company.*

• Name

• Years of operation

• Indicate whether it met the minimum net capital requirement referenced in Question 25.

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27. Do you participate in the SIPC insurance program? *

☐ Yes

☐ No

*Response required

When equals "No"

27.1. Please explain.*

*Response required

28. Which of the following trading platforms does your firm utilize?*

Select all that apply

☐ Bloomberg (BOOM/FIT)

☐ Tradeweb

☐ MarketAxess

☐ Other (OC Investments will follow-up)

*Response required

29. Which of the following investments does your local desk offer regularly?*

Select all that apply

☐ Banker's Acceptances

☐ Corporate Notes

☐ Supranational

☐ Asset Backed Securities

☐ Certificates of Deposits

☐ Municipal

☐ U.S. Treasury

☐ Commercial Paper

☐ Repurchase Agreements

☐ U.S. Government Agency

☐ Other (OC Investments will follow-up)

*Response required

30. Do you expect a minimum trade volume from your clients?*

☐ Yes

☐ No

*Response required

When equals "Yes"

30.1. Minimum trade volume is:*

Enter US Dollar amount - $

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31. After executing a trade, are you able to provide our custodian, within 2 hours, the trade confirmation that includes the Trade ID or Control ID (a unique 9-digit identifier) as proof of the completed trade?*

☐ Yes

☐ No

*Response required

When equals "No"

31.1. Please explain.*

*Response required

32. During the most recent 12-month period, how many and what percentage of your firm's institutional fixed-income transactions failed to settle on the contractual settlement date? *

Please identify the primary causes of such fails and describe your firm's procedures for identifying, escalating, and resolving failed trades.

A. Number of Failed Trades

B. Percentage of Total Transactions

C. Explanation (if applicable)

*Response required

33. Has your firm, or any representatives of your firm, been involved in any material historical disclosures, litigation, arbitration, or regulatory proceedings, whether pending, adjudicated, or settled within the past 24 months, related to fraud, manipulation, deceptive conduct, securities violations, or any other matters that the County should be aware of?*

☐ Yes

☐ No

*Response required

When equals "Yes"

33.1. Describe each matter briefly.*

*Response required

34. Have any of your firm’s public sector clients ever sustained a loss on a securities transaction or loss of principal arising from a misunderstanding or misrepresentation of the risk characteristics of a financial instrument that was recommended by and purchased through your firm?*

☐ Yes

☐ No

When equals "Yes"

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34.1. Describe each matter briefly.*

35. Have any of your firm’s public sector clients claimed, in writing, within the last five years, that your firm was responsible for any investment losses?*

☐ Yes

☐ No

*Response required

When equals "Yes"

35.1. Describe each matter briefly.*

*Response required

36. What policies, procedures, and internal controls has your firm established to ensure that all dealings with local government entities/agencies are conducted with the highest standards of integrity and in full compliance with applicable laws and regulations?*

Please provide written response.

*Response required

37. Local Government Entity/Agency References*

Identify five of your most comparable clients within California, preferably within the surrounding regions of County of Orange, or with a similar portfolio size.

If comparable California references are not available, references from clients outside California with similar sized portfolios are acceptable.

If County of Orange is your current or previous coverage, please list it as a reference.

Include:

• Entity

• Client Since

• Contact Person

• Email

*Response required

38. The County requires monthly statements to be provided electronically via email.

The County does not require printed trade confirmations, as we use Bloomberg as the

County’s approved trade ticket.*

Please identify all reports, statements, trade confirmations, transaction notices or other communications your firm would routinely provide, including the method and frequency of delivery.

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Please also indicate whether these communications can be customized to allow the County to opt-out if so desired.

*Response required

39. Do you have a research web portal for clients to access market commentaries, public company research, and other information?*

☐ Yes

☐ No

*Response required

When equals "No"

39.1. Provide reason.*

*Response required

40. What training does your firm have available that can be provided to the County?*

*Response required

41. What other services do you offer that might be of interest to the County (i.e. access to your economist, strategist, credit rating reports, etc.)?*

*Response required

42. Is there anything that makes your firm unique from other firms, such as minority owned, specialized knowledge in certain areas, etc.?

43. I certify I have reviewed the County’s IP and understand the objectives.*

By selecting Confirm, you are certifying that the applicant has reviewed the County's current

Investment Policy (IP) (available here) and understands the investment objectives, permitted investments, limitations, and other requirements applicable to transactions with the County. If approved, the firm agrees to review subsequent updates provided by the County and distribute the applicable Investment Policy to personnel responsible for the County's account.

☐ Please confirm

*Response required

44. If approved, I agree to review subsequent updates, submit written acknowledgements of receipt and ensure distribution to any employees who handle the

County’s account. *

☐ Please confirm

*Response required

45. Broker-Dealer Attestation*

Once you "Click here to go to the form" you will be asked to complete the Broker-Dealer

Attestation Docusign form.

Click here to go to the form https://ceo.oc.gov/finance-office/county-investment-fund#docaccess-6f65496d3de6038374749e0df497f41f https://na2.docusign.net/Member/PowerFormSigning.aspx?PowerFormId=5ddae049-e6d2-4e2d-87d4-b36726e67f83&env=na2&acct=bbc5da53-55a6-406d-b244-b9ee56f12f4c&v=2

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46. County of Orange Campaign Contribution Disclosure*

The Levine Act compliance is a minimum submittal requirement of this solicitation.

Please complete and sign the County of Orange Campaign Contribution Disclosure Form attached hereto. An applicant’s failure to provide a completed and signed copy will render its application as incomplete and nonresponsive.

It is the Broker-Dealer's responsibility to update the County should any new reportable activity occur after initial disclosure throughout the final Approved Broker-Dealers List.

• Levine_Act_-_Campaign_Contr...

• Levine_Act_-_Campaign_Contr...

*Response required

47. Required Documentation*

Upload the following required documentation:

1. A copy of the firm’s most recent audited Annual Report

2. A copy of the firm’s current Form BD Status Report

3. A copy of the firm’s most recent SEC Form X-17 A-5 “Focus Report” or most recent

Consolidated Reports of Condition and Income for A Bank with Domestic and Foreign

Offices – FFIEC 031 (in the case of a bank)

4. A copy of the firm’s service level agreement or scope of service agreement that outlines trade execution, settlement, coverage/support staff and escalation paths.

5. MSRB Rule G-37 filing for the past 12 months (if not applicable, please provide reason) https://government-project.s3.us-west-2.amazonaws.com/303602/fffc6695-8b6a-49a8-9126-d49045239ba8_Levine_Act_-_Campaign_Contribution_Disclosure_Form.docx https://government-project.s3.us-west-2.amazonaws.com/303602/27a8ac59-782c-4930-8717-1a8617fa9e01_Levine_Act_-_Campaign_Contribution_Disclosure_Form.pdf

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