C250105_Form_700_Review_09-26-25.pdf
PDF 1 MB Posted
- Attached to
- OC Bus Marketing Program
- Solicitation number
- 250105
- Issued by
- Orange County, California
About this file
This file consists of internal correspondence from the Orange County Transportation Authority (OCTA) regarding a Form 700 conflict of interest determination for RFP 250048, the OC Bus Marketing Program. On September 26, 2025, OCTA General Counsel James M. Donich provided a written determination that personnel performing work under this solicitation would not be required to file Form 700 declarations. The RFP seeks qualified consultants to provide marketing services for the OC Bus Marketing Program with a budget of $175,000 for a sixteen-month initial term. The determination was requested as part of Form 700 procedures that OCTA's Contracts Administration and Materials Management (CAMM) division is required to follow following a recent internal audit.
General Counsel Donich's determination concluded that Form 700 filings would not be required because consultant personnel would not authorize or direct actions, votes, appoint persons, obligate OCTA to any course of action, or enter into contractual agreements on behalf of OCTA. Additionally, any information, opinions, or recommendations provided by consultant personnel would not directly affect decisions without significant intervening substantive review by OCTA personnel, counsel, and management. This assessment provides clarity for procurement execution of the OC Bus Marketing Services solicitation without conflict of interest filing obligations for contractor staff.
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Rhea Aninzo
From: James M. Donich <jdonich@woodruff.law> Sent: Friday, September 26, 2025 1:24 PM To: Iris Deneau Cc: Rhea Aninzo Subject: Re: Form 700 Review: RFP 250048 OC Bus Marketing Services
I have reviewed the SOW for RFP 5-0048 as to whether the personnel performing these duties would be required to file Form 700's under OCTA's Conflict of Interest Code. Based upon my review, it is the opinion of General Counsel that this RFP and the SOW would not require the filing of Form 700's. The consultant personnel anticipated by this RFP would not authorize or direct any actions, votes, appoint any person, obligate or commit OCTA to any course of action or enter into any contractual agreement on behalf of OCTA. Moreover, no personnel provided for by this RFP would provide information, an opinion or a recommendation for the purpose of affecting a decision without significant intervening substantive review by OCTA personnel, counsel and management.
James Donich OCTA General Counsel
555 Anton Blvd Suite 1200 Costa Mesa CA 92626
James M. Donich Director & Shareholder D: 714-415-1015 jdonich@woodruff.law www.woodruff.law
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From: Iris Deneau <ideneau@octa.net> Date: Friday, September 26, 2025 at 11:34 AM To: James M. Donich <jdonich@woodruff.law> Cc: Rhea Aninzo <raninzo@octa.net> Subject: FW: Form 700 Review: RFP 250048 OC Bus Marketing Services
Hi James, As part of the Form 700 procedures that CAMM is required to follow as a result of the recent Internal Audit, attached please find the scope of work for OC Bus Marketing Services. Upon your review, please provide your written determination if the agreement awarded as a result of this solicitation will be subject to the Form 700 requirements. If you require additional information, please let me know.
Thank you, Iris Deneau | Section Manager, Procurement Contracts Administration and Materials Management Orange County Transportation Authority
714.560.5786 | 714.560.5792 550 South Main Street | PO Box 14184 | Orange, CA 92863-1584 CAMM - Procurement with Integrity Please consider the environment before printing this e-mail.
From: Rhea Aninzo <raninzo@octa.net> Sent: Friday, September 26, 2025 10:19 AM To: Iris Deneau <ideneau@octa.net> Subject: Form 700 Review: RFP 250048 OC Bus Marketing Services
Hi Iris, Please find the attached scope of work for Form 700 review.
Thank you, Rhea Aninzo | Associate Contract Administrator
Contracts Administration and Materials Management Orange County Transportation Authority raninzo@octa.net | (714) 560-5650 600 South Main Street | P.O. Box 14184 | Orange, CA 92863-1584
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