C250166_Email_Form_700_Review_12-31-25.pdf
PDF 1 MB Posted
- Attached to
- Grants Administration Consultant Support
- Solicitation number
- 250166
- Issued by
- Orange County, California
About this file
This file is an email correspondence regarding a Form 700 conflict of interest compliance review for RFP 25-0166 between the Orange County Transportation Authority (OCTA) and its General Counsel. The RFP seeks qualified consultants to provide grants administration consultant support services on an as-needed basis for OCTA. The contract has a budget of $250,000 for a two-year term. The General Counsel's review was conducted to determine whether personnel performing duties under this RFP would be required to file Form 700 conflict of interest statements under OCTA's Conflict of Interest Code.
Based on his review of the Scope of Work, OCTA General Counsel James M. Donich issued a written determination that the agreement awarded as a result of this solicitation will not be subject to Form 700 requirements. The determination was based on the finding that consultant personnel would not authorize or direct any actions, votes, appoint personnel, obligate or commit OCTA to any course of action, or enter into contractual agreements on behalf of OCTA. Additionally, no consultant personnel would provide information, opinions, or recommendations for the purpose of affecting decisions without significant intervening substantive review by OCTA personnel, counsel, and management. This review was conducted as part of Form 700 compliance procedures required by OCTA's Procurement, Contracts Administration and Materials Management (CAMM) department following a recent internal audit.
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Text version
Rhea Aninzo
From: James M. Donich <jdonich@woodruff.law> Sent: Wednesday, December 31, 2025 7:13 AM To: Iris Deneau Cc: Rhea Aninzo Subject: Re: Form 700 Review: RFP 250166 Grants Administration Consultant Support
I have reviewed the SOW for RFP 25-0166 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 Shareholder D: 714-415-1015 jdonich@woodruff.law www.woodruff.law
CONFIDENTIALITY NOTICE – This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify the sender by telephone at 714-415-1015 or return e-mail and delete the original transmission and its attachments without reading or saving in any manner. Thank you.
On Dec 30, 2025, at 7:39 PM, Iris Deneau <ideneau@octa.net> wrote:
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 Grants Administration
Consultant Support. 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: Tuesday, December 30, 2025 9:28 AM To: Iris Deneau <ideneau@octa.net> Subject: Form 700 Review: RFP 250166 Grants Administration Consultant Support
Hi Iris, Please find the attached scope of work for Form 700 review.
Thank you, Rhea
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<SOW.pdf>
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