*This report was replaced in its entirety by the Virginia Conflict of Interest and Ethics Advisory Council on February 16, 2018.

Under current law in Virginia, all constitutional officers and all state officials and employees who are required to file a disclosure form submit their forms electronically, using the online filing system developed and maintained by the Virginia Conflict of Interest and Ethics Advisory Council (the Council). All local officials and employees who are required to file a disclosure form submit their forms to their local clerks. While it would be possible to have all local filers submit their forms to the Council, using the online filing system, there would be costs to implement this change. The Council’s filing system would require modifications, the local forms would have to be incorporated into the system, and increased server space would be needed to accommodate the additional thousands of forms that would be submitted. The Council would also need additional staff to handle the expected increase in phone calls and emails from filers who have questions or technical difficulties. Both the Virginia Municipal League and the Virginia Association of Counties recommend that local filings remain at the local level, with disclosure forms submitted to local clerks. In consideration of their recommendations and the costs involved in centralizing all local filings with the Council, the Council recommends that at the current time local officials and employees continue to file with their local clerks.