BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  SB 439
                                                                  Page  1

          Date of Hearing:   June 22, 2011

            ASSEMBLY COMMITTEE ON PUBLIC EMPLOYEES, RETIREMENT AND SOCIAL 
                                      SECURITY
                              Warren T. Furutani, Chair
                 SB 439 (Negrete McLeod) - As Amended:  June 16, 2011

           SENATE VOTE  :   39-0
           
          SUBJECT  :   Political Reform Act of 1974: PERS: STRS: gift 
          limits.

           SUMMARY  :   Prohibits California Public Employees' Retirement 
          System (CalPERS) and California State Teachers' Retirement 
          System (CalSTRS) board members and specified employees from 
          accepting gifts of more than $50 from a single person who has 
          secured a contract with or submitted a contract proposal to the 
          retirement system within the previous five years.  Specifically, 
           this bill  :  

          1)Prohibits CalPERS and CalSTRS board members and employees who 
            are required to file annual Statements of Economic Interest 
            (also known as Form 700) from accepting gifts in excess of $50 
            from any single person or entity who has secured a contract 
            with, or submitted a contract proposal to, CalPERS or CalSTRS 
            within the previous 5 years in any given calendar year.

          2)Allows a gift recipient to return the gift or its equivalent 
            dollar value to the donor within 30 days of receipt in order 
            to comply with this limit.

          3)Disqualifies any vendor or contractor found to be violating 
            this gift policy twice in a 5-year period from bidding on, and 
            being awarded, any contract for a period of 2 years from the 
            date of the second penalty assessment made by the Fair 
            Political Practices Commission for commission of the 
            violation.

          4)Specifies that violations will be deemed separate if they 
            occur more than 60 days apart.

           EXISTING LAW  :

          1)Requires, pursuant to the Political Reform Act (PRA), 
            specified public officials to annually report the receipt of 








                                                                  SB 439
                                                                  Page  2

            gifts and prohibits the receipt of gifts from any single 
            source in any calendar year exceeding $250 in value, adjusted 
            biannually for inflation since 1993, from any single source, 
            (current inflation adjusted limit is $420).

          2)Establishes the governing boards of CalPERS and CalSTRS and 
            defines their duties and responsibilities, which include 
            oversight of the retirement systems' investment programs and 
            compensation for certain essential employees, including the 
            Chief Executive Officer, the Chief Actuary, the Chief Counsel, 
            the Chief Investment Officer and other managerial-level 
            investment staff.

           FISCAL EFFECT  :   According to the Senate Appropriations 
          Committee, pursuant to Senate Rule 28.8, negligible state costs. 


           COMMENTS  :   In 2010, following charges of unethical conduct 
          against former CalPERS staff and board members relative to the 
          influence of placement agents, CalPERS commissioned a study by 
          the respected Washington, D.C. law firm, Steptoe and Johnson, to 
          review CalPERS' investment decision making practices and to 
          identify ethical vulnerabilities.  The initial findings of that 
          report were released in November 2010 and included a 
          recommendation to prohibit gifts to CalPERS board members and 
          staff. 

          According to the sponsor, State Controller John Chiang, "SB 439 
          is designed to restore public confidence in CalPERS and CalSTRS' 
          decision-making process by limiting opportunities for 
          influence-peddling or to gain an unfair advantage in 
          consideration for investments.  If enacted, this measure will 
          assure CalPERS/CalSTRS members and taxpayers' that investment 
          decisions are being made in the best interest of the funds, and 
          set an enduring ethical precedent for other states, localities, 
          and private investors to follow."

          CalPERS adopted a No Gift Policy for Staff (Policy) in November 
          2009, that prohibits employees that are required to file a Form 
          700 under its Conflict of Interest Code (including, among 
          others, system executives, divisions chiefs and investment 
          professionals) from accepting anything of value including, 
          without limitation, money, gifts, services, loans, 
          entertainment, tickets, transportation, food or beverages from 
          any person or entity doing business with CalPERS; seeking to do 








                                                                  SB 439
                                                                  Page  3

          business with CalPERS; or who is the type of entity that does 
          business with CalPERS.  

          At its October 20, 2010 meeting, the CalPERS board adopted a new 
          Form 700 and Travel Transparency Policy that requires all Form 
          700s and certain Board and staff travel information to be posted 
          on the CalPERS internet web site. 

          In addition to the Gift Policy, the CalPERS Statement of 
          Incompatible Activities prohibits all CalPERS board members and 
          employees from receiving or accepting any gifts from "anyone who 
          is doing or is seeking to do business of any kind with the 
          Public Employees' Retirement System or whose activities are 
          regulated or controlled by CalPERS under circumstances from 
          which it reasonably could be substantiated that the gift was 
          intended to influence the officer or employee in his or her 
          official duties or was intended as a reward for any official 
          actions performed by the officer or employee."

          CalSTRS has developed and complies with its own conflict of 
          interest regulations, which details disclosure categories and 
          what each one is required to report. The conflict of interest 
          code applies to those officials and employees who file statement 
          of economic interests (Form 700) and are required to comply with 
          the limit and to report income and gifts as outlined by the 
          regulations.

          In addition, CalSTRS has adopted a Statement of Incompatible 
          Activities which provides, in pertinent part: All staff members 
          in CalSTRS shall, during hours of duty as State employees, 
          devote full time, attention, and efforts to their State office 
          or employment. No employment, activity, or enterprise shall be 
          engaged in by any officer or employee of CalSTRS that might 
          result in or create the appearance of any of the following:

          Receiving or accepting, directly or indirectly, any gift, 
          including money, any service, gratuity, favor, entertainment, 
          hospitality, loan, or any other thing of value, from anyone who 
          is doing or is seeking to do business of any kind with the State 
          or whose activities are regulated or controlled in any way by 
          the State, under circumstances from which it reasonably could be 
          inferred that the gift was intended to influence him/her in 
          his/her official duties or was intended as a reward for any 
          official action on his/her part.









                                                                  SB 439
                                                                  Page  4

          Furthermore, the Teachers' Retirement Board has a policy related 
          to the disclosure of campaign contributions, charitable 
          contributions, and gifts; recusal requirement; and ban on 
          specified gifts, which prohibits any party who engages in 
          business with CalSTRS for gain from providing gifts to board 
          members, or CalSTRS officers or employees exceeding the gift 
          limit, as outlined by the Political Reform Act. The policy 
          further allows for the disqualification from future business 
          with CalSTRS for a period of two years following a determination 
          by the board that a violation of this policy has occurred. This 
          policy and Form 600H are attached to CalSTRS contracts. CalSTRS 
          requires each contracting entity and each of its authorized/key 
          personnel to complete and file separate Form 600H with CalSTRS.

          The committee recommends the bill be amended to delete "twice" 
          in Section 1 and Section 2 of the bill and replace it with "on 
          two separate occasions" in order to clarify that violations will 
          be deemed separate if they occur more than 60 days apart.

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
          Office of State Controller John Chiang (Sponsor)
          California Public Employees' Retirement System
          California Retired Teacher Association
           
            Opposition 
           
          None on file

           Analysis Prepared by  :    Karon Green / P.E., R. & S.S. / (916) 
          319-3957