Title
Approving the Sacramento Housing and Redevelopment Agency's (SHRA) Conflict of Interest Code Amendments
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FileID
File ID: 2026-01054
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Location
Location: Citywide
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Recommendation
Recommendation: 1) Adopt a Housing Authority Resolution approving the amended Sacramento Housing and Redevelopment Agency (SHRA) Conflict of Interest Code, including the updated list of designated positions and disclosure categories, and repealing prior Housing Authority resolutions related to the SHRA Conflict of Interest Code and superseding any inconsistent provisions; and 2) adopt a City Council Resolution approving the amended SHRA Conflict of Interest Code, including the updated list of designated positions and disclosure categories.
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Contact
Contact: Brad Nakano, General Counsel, (916) 440-1330, bnakano@shra.org; Amber Alexander, Agency Clerk, (916) 440-8544, aalexander@shra.org; Sacramento Housing and Redevelopment Agency
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Presenter
Presenter: None
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Attachments
Attachments:
1-Description/Analysis
2-Attachment 1 - Red Lined Conflict of Interest Code and Designated Employee List
3-City Council Resolution
4-Housing Authority Resolution
5-Exhibit A - Final Conflict of Interest Code and Designated Employee List
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Description/Analysis
IssueDetail
Issue Detail: The Sacramento Housing and Redevelopment Agency (SHRA) provides staffing for the Housing Authority of the City of Sacramento and administers federal housing and community development programs on behalf of the City of Sacramento. The Political Reform Act (Government Code §81000 et seq.) requires public agencies to adopt and maintain a Conflict of Interest (COI) Code to ensure that governmental decisions are made free from financial conflicts of interest.
SHRA adopted its COI Code in 1983 and most recently amended the code in 2024. Government Code Section 87306.5 requires agencies to review their COI codes at least every two years to determine whether amendments are necessary.
The proposed amendments are part of SHRA’s biennial review process and update the code to reflect current organizational structure and legal requirements. The amendments also clarify filing requirements for officials specified in Government Code §87200, including City Council Members and County Board of Supervisors acting as Housing Authority governing bodies, who file Statements of Economic Interests directly with the Fair Political Practices Commission and are subject to the SHRA Conflict of Interest Code for disqualification purposes only.
In addition, the amendments update the gift reporting threshold to reflect the current Fair Political Practices Commission limit and incorporate current federal conflict of interest requirements applicable to housing and community development programs.
Exhibit A contains the amended COI Code, including designated positions and disclosure categories.
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PolicyConsiderations
Policy Considerations: A COI Code must be amended in the event of changed circumstances, such as the addition of new classifications or the modification of existing classifications (Government code Section 87306). SHRA's updated code includes the addition of positions that have been deemed to have authorities that require filing; modification of positions that have been reclassified; deletion of classifications that no longer exist; deletion of positions that have been deemed to no longer have authorities that require filing; and updated disclosure categories.
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EconomicImpacts
Economic Impacts: None.
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EnvironmentalConsiderations
Environmental Considerations:
California Environmental Quality Act (CEQA): Pursuant to Cal. Code Regs., tit. 14, section 15378 subds. (b)(2) and (5), the recommended actions are not considered a “project,” as they constitute administrative activities and policymaking of government entities that will not result in direct or indirect physical changes in the environment.
National Environmental Policy Act (NEPA): There is no federal funding involved in this action and NEPA does not apply.
Sustainability
Sustainability: Not applicable.
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Commission/Committee Action
Commission/Committee Action: Sacramento Housing and Redevelopment Commission: At its June 6, 2026, meeting it is anticipated that the Sacramento Housing and Redevelopment Commission will adopt a Commission resolution related to the update and recommend that the City Council consider approval of the recommendations in this report. In the event the Commission does not take the anticipated action, staff will advise the City Council at the meeting.
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RationaleforRecommendation
Rationale for Recommendation: Pursuant to Government Code 81000 local agencies are required to update their COI codes to reflect changed circumstances relating to their designated filers and disclosure categories. Updating the code also allows the incorporation of provisions contained in California Code Regulations Section 18730 that have changed since the previous approval of SHRA's code and allows for the inclusion of relevant federal conflict of interest code provisions.
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FinancialConsiderations
Financial Considerations: Not applicable.
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LocalBusinessEnterprise
LBE - M/WBE and Section 3 requirements:
M/WBE & Section 3 Considerations:
The items discussed in this report have no M/WBE or Section 3 impact; therefore, M/WBE and Section 3 considerations do not apply.
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