The Mutual Settlement Policy establishes policy and procedures for the resolution of a Notice of Violation (NOV) including the preparation of base penalty amounts (based upon the gravity of the violation) and calculation of estimated economic advantage factors.

The Political Reform Act (Government Code §§ 81000, et seq., hereinafter referred to as the Act) requires state and local government agencies to adopt and promulgate conflict of interest codes. The Fair Political Practices Commission (“FPPC”) has adopted a regulation (2 California Code of Regulations § 18730) which contains the terms of a standard conflict of interest code, which can be…