Electronic Filing Systems for Public Disclosures in California

In today's digital age, the importance of electronic filing in enhancing government transparency cannot be overstated. Electronic filing systems are pivotal in fostering an open government, ensuring that citizens have easy access to vital information regarding public officials, political campaigns, and lobbying activities.

The Political Reform Act of 1974 is a foundational element of California's commitment to transparency in government. This legislation mandates comprehensive disclosure of financial interests, campaign contributions, and lobbying activities, ensuring that public officials operate with integrity and accountability. By requiring these disclosures, the Act helps prevent conflicts of interest and promotes an open government where citizens can easily access information about the financial dealings and influences affecting their elected representatives and government officials. The Political Reform Act thus serves as a crucial mechanism for maintaining public trust and fostering an informed electorate. (See the California Fair Political Practices Commission Website with more details: https://www.fppc.ca.gov/about-fppc/about-the-political-reform-act.html)

In addition to promoting transparency, electronic filing solutions also dramatically reduce the workload of filing officers, who are usually City Clerks and County Supervisory Board Clerks with busy schedules and a wide array of responsibilities. An effective eFile system offers a streamlined and user-friendly experience for the filers while automating simple but time consuming administrative tasks such as assigning filings and sending out filing reminders or late notices.

When looking for an electronic filing provider, filing officials frequently consider a number of criteria:

1. Functionality and Features

Filing officers typically consider the list of supported forms and filing types (campaign, Form 700, lobbyist), the level of workflow automation (e.g., for data validation, filing assignment, reminders, review), and the availability of reporting and analytics features. They also care about the public’s ability to access filings and electronic filing data (e.g., via a public API or bulk data export for data journalists). Another key feature that filing officers often look for is the ability to toggle their view to be that of a specific filer in order to provide them with guidance if they are stuck somewhere in a filing flow.

2. Filer Experience

Filing officers have a keen interest in an excellent and streamlined filer experience. The easier and quicker a filer can complete their filing, the smaller is the potential for time consuming support requests and follow-up. Today, most filers of Form 700 are inclined to complete their filings on their phone or tablet, so a filing system that’s compatible with smartphones or that offers a mobile app, will have a competitive edge. Moreover, an electronic filing system should be designed in such a way that it guides the filer in a Turbo-Tax like fashion step by step through their filing requirement (at least for Form 700 – lobbyist and campaign filings are generally much more complicated). Filers should receive in-context help and should not have to spend time reading lengthy manuals in order to complete their filing tasks.

Another aspect of the filer experience is broad accessibility and ADA compliance. An electronic filing system should follow accessibility standard as laid out by Web Content Accessibility Guidelines (WCAG) and offer various accommodations such as screen reader support, a high contrast mode, automatic multi-lingual translation, and, among other things, responsive design that allows users to increase the font size by multiples while retaining full functionality.

3. Admin/Filing Officer Experience

Filing officers typically look for a simple yet powerful admin interface that lets them accomplish their filing officer tasks easily and efficiently. Above all, they look for automated workflows reducing their workload. These include automated communication with filers (assignment, reminder, and confirmation messages) via customizable message templates, integrated Form 700 review capabilities, bulk filing assignment.

Filing officers also care about a pleasant user experience and a self-explanatory design of the admin interface, which reduces training requirements for new staff. That said, a detailed admin reference manual is an absolute must for any filing system.

4. Custom Support and Training

Filing officers generally place a high value on customer support and comprehensive training programs. Effective customer support is essential because it ensures that any technical issues or user difficulties can be quickly resolved, minimizing downtime and maintaining the efficiency of the filing process. This is most important near quarterly, semi-annual, and annual filing deadlines when filing officers and filing systems are under particular stress.

Clerks prefer vendors that offer responsive, knowledgeable support via email and phone. They also look for extensive training programs for both filers and filing officers to ensure that filers and all staff members are proficient in using the system. This includes initial training sessions, ongoing educational resources, and access to tutorials or webinars that can help users stay updated on new features or changes in the system.

5. Trust and Reputation

Providing public disclosures is a critical public service offered by government agencies, which underscores the necessity for the underlying electronic filing system to be provided by a trusted and reputable entity. Trust and integrity are paramount; the provider must act as an honest broker, ensuring complete impartiality and adhering to the highest standards of ethics and integrity.

Filing officers assess the vendor's history, track record, and reliability. This involves consulting with peers across various agencies in California to gather insights and feedback on potential vendors. Such due diligence helps ensure that the chosen system will uphold the principles of transparency, accountability, and public trust, which are foundational to the effective administration of public disclosures.

The reputation of the vendor thus becomes a cornerstone in maintaining the integrity and reliability of the electronic filing system, ultimately serving the public interest.

6. Customization and Integration with Agency Systems

It’s important for filing officers that an electronic filing system integrates well with their agency website and IT infrastructure. In recent years, single-sign on via SAML/OICD offered by identity providers such as Google, Microsoft, and Okta has become the de-facto standard for user login at public agencies. Naturally, the electronic filing system should offer city filers the ability to log in using their single-sign on credentials.

Agencies also care about the general integration of the filing system with their web presence and domain. Ideally, the filing system should be accessible under the agency’s website and not under a separate web domain. Transactional email is preferred to come from an official email address rather than an email address owned by the vendor. The former increases trust and email deliverability while the latter risks emails ending up in Spam folders or filers ignoring transactional emails since they are not coming from an official address.

7. Cost and Budget

While last in this list, cost is certainly not the least important factor. Clerks always have to fight for their budgets, so they care about how much they are paying for electronic filing services. Filing officers typically obtain quotes from multiple providers and then weigh all factors, with cost being an important one. In the case of larger agencies, typically counties and larger Cities with a population of 80,000 or more, officers may request formal bids as part of a request for proposals (RFP). This is a more involved process, but has huge benefits for agencies: going the RFP route ensures transparency, competition among vendors, and best use of taxpayer dollars.

Electronic Filing Vendors in California

All current providers of electronic filing systems provide their filing software as Software-as-a-Service offering, this means the software runs on servers in their data centers or the public cloud (such as Google Cloud, Amazon Web Services, or Microsoft Azure). The software is accessed via web browsers or via dedicated desktop applications that talk to remote servers.

We are the makers of eFile, so we have a natural bias toward our own eFile electronic filing system, which we think is the overall best-value option for agencies of all sizes throughout California. That said, we are committed to our core values of integrity, honesty, truth, and transparency. Thus we are happy to fairly summarize our competitor’s offerings and compare them with what eFile offers.

Granicus

Granicus is a large corporate entity offering a big variety of software products and services to government agencies nationwide.

In 2018, Granicus acquired South Tech Systems and has been offering its DisclosureDocs and CampaignDisclosure products since then.

South Tech Systems was a Southern California software development company founded in 1994. They worked closely with agencies to develop various software solutions for public agencies.

About Granicus and their DisclosureDocs and CampaignDisclosure offerings:

• Large nation-wide corporation that provides stability and deep expertise in government technology.
• Extensive experience with very large agencies (Counties, City of Los Angeles, FPPC).
• More than two decades of experience.
• DisclosureDocs and CampaignDisclosure are legacy web software that use technology from the 2000s and 2010s and correspondingly outdated user interfaces.
• Poor support for mobile devices.
• Don’t integrate directly with agency websites and no support for single-sign on.
• Some agencies have expressed concerns about the responsiveness of Granicus’s customer support.
• Limited flexibility for customization.
• On the more expensive side, given the large overhead created by a corporation of Granicus’s scale.
• Might be a good solution for agencies that already use many of Granicus’s products.

Netfile

NetFile was established in 1998 and was the first company to electronically file a disclosure statement in California. Today, NetFile accounts for well over half of all electronic filings of political disclosure documents and lobbyist statements in the State of California.

About Netfile and their offering:

• Market leader with more than two decades of experience.
• Known for providing excellent customer service.
• Offers some unique add-on features, including Lobbyists Disclosures, Ethics Training and a Boards and Commissions Management system.
• Also offers a campaign-treasurer product with cross-functionality to the campaign disclosures system.
• Offers a public API for disclosure data across all agencies they serve.
• Legacy web software largely developed in the 2000s and 2010s and correspondingly outdated user interfaces. Poor support for mobile devices.
• Self-hosted servers with increased risk for downtime due to hardware issues or natural disasters.
• Limited integration with agency websites and slow public access portals. The latter are set up once with agency links and not updated, leading to broken links and a mismatch of design between agency websites and Netfile’s portals. No single sign-on support.
• On the more expensive side.
  

Electronic Filing Systems

Electronic Filings Systems is a venture of Pasadena Consulting Group LLC, based in Southern California. Development of eFile, EFS’s flagship product for Form 700, Campaign, and Lobbyist disclosures started in 2020. eFile was first deployed at the City of San Diego in 2021. Since 2022, eFile is available to agencies across California.

About Electronic Filing Systems and eFile:

• Micro-business with a dedicated Southern California based engineering and support team.
• eFile is built on modern web and cloud technologies and follows the Agile principles of software development. eFile is constantly being updated, improved, and new features are regularly added and made available to agency partners.
• 100% cloud-hosted on Amazon Web Services with industry leading reliability, availability, and security.
• User-friendly design for easy filing on all kinds of devices, including smartphones and tables.
• Direct integrations with agency websites, email, and single-sign on systems.
• Generally 25-30% more cost effective for agencies due to the use of modern software and cloud technology.
• Offers a general compliance tracking module for the tracking of any compliance requirement, e.g., AB 1234 Ethics Training. This module is available at no extra charge to agencies.
• Open, public-access campaign disclosure API and an open API integration with treasurer software.
• Modular design, which makes agency-specific customization easy and cost effective.
• Free Android/iOS eFile Gift Tracker App that exports to Excel, allowing for the tracking of gifts received throughout the year.