C250382_Form_700_Legal_Counsel_Response_06-12-26.pdf
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- Solicitation number
- 250382
- Issued by
- Orange County, California
About this file
This is a legal counsel response from the Orange County Transportation Authority (OCTA) General Counsel regarding Form 700 filing requirements for RFP 25-0382, which seeks qualified consultants to provide investment advisory and consulting services for the Authority's Deferred Compensation Plan. The solicitation pertains to non-ERISA Governmental 457(b) and 401(a) plans and is issued as a firm-fixed contract with a budget of $225,000 for a five-year term. The response was issued on June 12, 2026, following an internal audit that prompted OCTA's Contracts Administration and Materials Management division to request a legal determination regarding conflict of interest filing requirements.
General Counsel James M. Donich determined that personnel providing services under this RFP would not be required to file Form 700s under OCTA's Conflict of Interest Code. The determination was based on the finding that consultant personnel would not authorize or direct actions, votes, appoint persons, obligate OCTA to courses of action, or enter into contractual agreements on behalf of the Authority. Additionally, any information, opinions, or recommendations provided by RFP personnel would be subject to significant intervening substantive review by OCTA personnel, counsel, and management before affecting any decisions. This legal opinion establishes that the scope of work falls outside the categories of positions requiring conflict of interest disclosures.
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Gina Torres
From: James M. Donich <jdonich@woodruff.law> Sent: Friday, June 12, 2026 5:01 PM To: Rebecca Abeyta Cc: Gina Torres Subject: Re: RFP 250382 Deferred Compensation Plan Investment Advisory and Consulting Services (Non-
ERISA Governmental 457(b) and 401(a) Plans)
I have reviewed the SOW for RFP 25-0382 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
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On Jun 12, 2026, at 2:55 PM, Rebecca Abeyta <rabeyta@octa.net> wrote:
Hello James, As part of the Form 700 procedures that CAMM is required to follow as a result of an Internal Audit, attached please find the scope of work for the “Deferred Compensation Plan Investment Advisory and Consulting Services (Non-ERISA Governmental 457(b) and 401(a) Plans)” for your review. This is a professional services procurement and will be issued as a firm-fixed contract for Deferred Compensation Plan Investment Advisory and Consulting Services (Non-ERISA Governmental 457(b) and 401(a) Plans).
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.
Rebecca Abeyta Section Manager, III Contracts Administration and Materials Management Orange County Transportation Authority
714.560.5478 | 714.560.5792 550 South Main Street | PO Box 14184 | Orange, CA 92863-1584
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<C250382_Exhibit_B_Scope_of_Work.docx>
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