C250213_Form_700_Legal_Counsel_Response_02-05-26.pdf
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- Solicitation number
- 250213
- Issued by
- Orange County, California
About this file
This file is a legal counsel response from the Orange County Transportation Authority (OCTA) General Counsel regarding Form 700 filing requirements for RFP 25-0213 Actuarial Valuation Services. The RFP solicits proposals from qualified firms to provide actuarial valuation services for OCTA's retiree healthcare program and additional retiree benefit account. The contract is structured as a firm-fixed agreement with a budget of $49,500 for a five-year term. The procurement was initiated following internal audit procedures that required OCTA's Contracts Administration and Materials Management (CAMM) section to conduct Form 700 compliance reviews for new solicitations.
OCTA's General Counsel determined that personnel performing work under this contract would not be required to file Form 700 conflict of interest disclosures. The legal determination was based on the finding that 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, no personnel would provide information, opinions, or recommendations affecting decisions without significant intervening substantive review by OCTA personnel, counsel, and management. The contract includes certification requirements that offerors are not subject to Ukraine/Russia-related economic sanctions imposed by the State of California or the United States Government.
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Gina Torres
From: James M. Donich <jdonich@woodruff.law> Sent: Thursday, February 5, 2026 1:38 PM To: Iris Deneau Cc: Gina Torres Subject: Re: 700 Form - RFP 250213 Actuarial Valuations Services
I have reviewed the SOW for RFP 25-0213 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
James M. Donich Shareholder D: 714-415-1015 jdonich@woodruff.law 555 Anton Boulevard, Suite 1200 Costa Mesa, California 92626 Celebrating 50 years of excellence www.woodruff.law
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From: Iris Deneau <ideneau@octa.net> Sent: Thursday, February 5, 2026 11:20 AM To: James M. Donich <jdonich@woodruff.law> Cc: Gina Torres <gtorres@octa.net> Subject: FW: 700 Form - RFP 250213 Actuarial Valuations 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 Actuarial Valuations 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: Gina Torres <gtorres@octa.net> Sent: Thursday, February 5, 2026 9:58 AM To: Iris Deneau <ideneau@octa.net> Subject: 700 Form - RFP 250213 Actuarial Valuations Services
Hi Iris, Please see attached SOW for RFP 250213 Actuarial Valuations Services. This will be procured as a firm-fixed contract.
Thank you, Gina Torres | Senior Contract Administrator Contracts Administration and Materials Management Orange County Transportation Authority
714.560.5566 | 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.
The information in this e-mail and any attachments are for the sole use of the intended recipient and may contain privileged and confidential information. If you are not the intended recipient, any use, disclosure, copying or distribution of this message or attachment is strictly prohibited. If you believe that you have received this e-mail in error, please contact the sender immediately and delete the e-mail and all of its attachments.
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