State of California law requires disclosure of financial interest in the sponsor of a research project whether as the prime recipient or as a subcontractor; the donor of a research gift; and, under certain circumstances, the provider of materials under a Material Transfer Agreement (MTA) or data under a Data Use Agreement (DUA) when that sponsor, donor, or provider is a non-governmental source.
Who must disclose:
Any person employed by the University of California, i.e., the Principal Investigator (and Co-Investigator where appropriate), who has principal responsibility for a research project if it is to be funded or supported, in whole or in part by a non-governmental entity sponsor or donor must submit a 700-U. Only researchers employed by the University of California may file a Form 700-U.
When to disclose:
Initial conflict of interest disclosures may be solicited through the Sponsored Projects Office (SPA) for projects sponsored by private industry/business and other nongovernmental agencies. For research projects, the Statement of Economic Interests for Principal Investigators (Form 700-U) should accompany the proposal to the Sponsored Projects Office.
If a defined financial relationship is disclosed in the 700-U, an Addendum to Statement of Economic Interests for Principal Investigators must also be submitted to the COI coordinator.
Note: Funding from certain sponsors will not trigger a 700-U disclosure as they have been exempted from the process by the State.
For “interim” disclosures, Investigators must submit a 700-U Form within 30 days after the contract, grant, or gift is renewed that discloses reportable investments, income and business positions that the filer held or received during the period between the date the initial statement was filed and the date the project contract, grant, or gift was renewed.
If there is a change in Principal Investigator (PI), the new Investigator must submit a Form 700-U to the SPO and RCI offices.
What to Disclose:
The principal investigator must disclose 1) paid or unpaid positions, including but not limited to, consultant, trustee, or director positions; 2) investment(s), whether direct, indirect, or beneficial; 3) income of $500 or more within the last 12 months, where income includes but is not limited to salary, interest, royalty payments, proceeds from sale, reimbursement for expenses, per diem; 4) loans within the last 12 months where the balance exceeds $500; 5) gifts within the last 12 months with a value of $50 or more; and 6) certain travel payments.
What is an Investment?
“Investment” means any financial interest in a business entity in which you, your spouse or registered domestic partner, or your dependent children have a direct, indirect, or beneficial interest totaling $2,000 or more. Reportable investments include stocks, bonds, warrants, and options, including those held in margin or brokerage accounts.
What is Income?
“Income” means a payment received, including but not limited to any salary, wage, advance, dividend, interest, rent, proceeds from any sale, gift, including any gift of food or beverage, loan forgiveness or payment of indebtedness received by the filer, reimbursement for expenses, per diem, or contribution to an insurance or pension program paid by any person other than an employer, and any community property interest in income of a spouse or registered domestic partner. Income also includes an outstanding loan. Income of an individual also includes a pro rata share of any income of any business entity or trust in which the individual, spouse, or registered domestic partner owns directly, indirectly, or beneficially, a 10% interest or greater. Income includes your gross income and your community property interest in your spouse’s or registered domestic partner’s gross income totaling $500 or more. Gross income is the total amount of income before deducting expenses, losses, or taxes.
What is a Loan?
Loans received or outstanding are reportable if they total $500 or more from a single lender. Your community property interest in loans received by your spouse or registered domestic partner also must be reported. Loans from commercial lending institutions made in the lender’s regular course of business on terms available to members of the public without regard to your official status are not reportable.
What is a Gift?
A gift is anything of personal value for which you have not provided equal or greater consideration to the donor. A gift is reportable if its fair market value is $50 or more. In addition, multiple gifts totaling $50 or more received from a reportable source must be reported. It is the acceptance of a gift, not the ultimate use to which it is put, that imposes your reporting obligation. Therefore, you must report a gift even if you never used it or if you gave it away to another person. If the exact amount of a gift is not known, you must make a good faith estimate of the item’s fair market value. Listing the value of a gift as “over $50” or “value unknown” is not adequate disclosure.
Gift Funding
For research gift funding, the Form 700-U must be submitted to the RCI Office prior to accepting the gift. The paper 700-U, with original, wet ink signature and date, must be sent or delivered to the RCI Office.
If a defined financial relationship is disclosed in the 700-U, the Gift Addendum to Statement of Economic Interests for Principal Investigators must also be submitted.
Material Transfer Agreements (MTAs)
For MTAs, the Form 700-U should accompany the Material Transfer Agreement Review Form to the appropriate office. In addition, the paper 700-U, with original, ink signature and date, must be sent or delivered to the RCI Office.
