SEI 700 > Who files, how, where/with whom?
SEI 700 > Who files, how, where/with whom?
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Summary and Linkable Table of Contents
Summary and Linkable Table of Contents
Who filesElected, Appointed and Key employees at State, county, city governments and multi county agency levels. (NOTE Superior Court Judges are county elected officials but oddly employed by the state) Specifics about who has to file is established in multiple state statutes. That part is not vague.
How they file - Two ways
"paper filing" - Digitally filling in pdfs and printing OR hand completed forms that they hand to a clerk relevant to their position
" e-filing" - login to software and provide information that generates a data record. NOTE: Different e-filing systems for county and state submissions. It seems e-filing was available at county and state prior to 2014, but unclear of exact year implementations at this time. Efiling seems to have been poorly implemented and screwed up the review first stamp second clerical check process.
Where/with whom do they file -
Paper Filing - supposed to be submitted to the lowest clerk relevant to the filer's position. That clerk was supposed o review for completeness, then stamp. Then that clerk would foward to other clerks lateral or above as needed. We can show how this as NOT transpariing however in 2017 with Salinas Valley Groundwater Sustainability agency.
Efiling - This is where a lot of confusion and inversion has been introduced. County filers with a state oversight filing requirement are now left to file separate with each entity. No predocument reviews prior to "acceptance". No comparative reviews. No cross checking of lower clerks by upper clerks. This has bypassed/destroyed chain of control and in Case of County Elected Judges and County supervisors, the state has way overstepped logical bounds for county integrity, independence, and sovereignty in multiple different ways.
Concerns arising with paper filing (evidence of conerns since 2017)
Paper filing is not being done with proper clerks or escalations from there
Paper filings were not being checked for completeness. Clearks were allowing patently incomplete and eerrant information to be submitted and accepted.
Concerns arising with efiling (15+ years in process)
County clerk efiling is bypassing paper document review prior to stamping/submssion.
fppc direct efilingg is now bypassing county and state clerk reviews
fppc direct filing allows fors state and/or efile software company to modify/remove content and/or coach on submission to help hide content
The removal of content could be managed / auditable via an email loop as part of the submission / signature process
the coaching on submission may or may not be manageable and auditable -- given the trust that would have to be extended to a software vendor already shown to be possible source of data flipping for audit obfuscations.
Both county and state efiling is showing signs of data flipping to make visual document audits more challenging and time consuming
Below is information known as of 2/7/2026 and subject to update with details and changes as time permits and a need for more specific information may arise.
Fuller Reporting
Fuller Reporting
Who files SEI 700, in General ?
Who files SEI 700, in General ?
Who files is set by mutliple/numerous statutes. Exact statutes may be referenced later.
Elected State, County, and City officials (inclusive of "county elected" Superior Court Judges)
Candidates running for election must file with each Candidate application packet
Appointed officials serving State, County and city jurisdication, plus a few multi-county entities
Key employees at State, County, city, multi-county entities who can affect their own economic interests must file.
For example, the Assistant Assessor are required,
For exmple of odd omission, the Chief of Staff of Monterey County Supervisors are not.
There are forms other than SEI 700 required for Contractors, but that will be addressed separately. ( IT contractors being a major concern).
How do they file SEI 700, in General?
How do they file SEI 700, in General?
There were/are two ways to file:
"paper" - They filled out forms by hand or via computer and printed copies of forms were submitted with hand signature or proper electronic signature (doc sign style)
"e-file" - They logged into a computer system - filled out information and then selected "submit" to create an e-file submission/record.
Concerns with Efile vs paper:
Efile Content and Signature - There is NO e-file content storage system or efile signature that can be relied on in court the way a hand written signature and paper filed copies can. HUGE problem. There were/are better ways to do e-filing for easiest legal relaibilit-- and all of them include an email loop with submitted content in a pdf and an action required from that email ( returned email or entry of code or confirm button that confrms. )
Details - Upon approval by a reviewer, An email with all provided content is sent to the filers email address with information in the PDF as completed -- and they must respond to that one of several ways. Thus, not only can the content they submitted be said to ahve been reviewed by them and recoverable via their emaisls and those sent, they would also have to claim loss of control of their password if they wanted to avoid responsibility for content.
Completeness/Appropriate Review responsibility lost -
With paper, when a form was presented to a clerk, the clerk would/should have reviewed the form for basic completeness/appropriateness and reject prior to stamping if needed. Thus if a form was stamped and it was not complete, not only is there a problem with the filer but the clerk is a concern too.
With efile, the data should have gone into a queue for completeness, reviewed and then returned for modification or accepted. If accepted, an email confirmation loop with pdf of document attached for review and action. At this time documents appear to be getting stamped with a submissions date/time not an accepted date/time (after a review) -- and the efile signatures are useless for declaring definitively who filed the document AND what was filed.
Loss of The Implement lementation of e-filing at state and county levels , which seems to have happened prior to 2014, seems to have transpired with no concern for clerk level document controls and it seems to have destroyed the concept of chain of custody of documents and processes for documents that needed to go to more than one cleark.
Where/With who do the file SEI 700, in General?
Where/With who do the file SEI 700, in General?
Candidates for Elected Positions
State level candidates during g elections - should be filing with a state level election authority -- unclear if that is transpiring. They may have defaulted to FPPC for submission and may or may not be demanding proof of submission . (See superior court judges separate below)
County level candidates during elections - should be filing with a county level election authority -- the dialogue with Monterey County Elections initially stated that the forms were submitted directly to the Clerk (oddly). When challenged a different answer was given. When asked to put in writing the written response was clear, but the suggestion of when/how the County Clerk was to have then gotten them for posting and the absence from county available records was unanswered. Waiting on response now. (2/7/2026) . (See superior court judges separate below)
City level candidates during elections - should be filing with a city clerk. (little more is known at this time)
Superior Court Judges - They are "county elected" Judges who became state employees as of court consolidation in 2000. The county election office gathers a candidate packet , where a paper form with hand signature is supposedly included. They then supposedly scan the packets and sent originals to FPPC. However, FPPC is only showing candidate forms for Monterey County Superior Judges in 2022.
Elected , Appointed, Key Positions
State - seems to file directly with FPPC . For people that would have filed with clerks prior (Clerk of Assembly, Clerk of Senate) it's unclear if / how they get copies or review anything. (major concerns)
County - This is murkier. . They file with the Clerk of the County OR an agency they report to -- and the communcation then between those two is murky. Furthermore, some fo these are to be overseen by the State as well and others are not -- and the clerk of the county is NOT forwarding county submitted documents to state -- the county filer is using another e-efiling system to submit new data. (no forwarding a previously submiitted e-file to the county) (major major concerns)
County Agenencies - This is murkier. There should be an agency admint/clerk who would get a copy and forward to county clerk. We have a document from 2017 showing an agency person took posession of a document , improperly added content himself and then sent that to the Clerk of the Board of Supervisors, not the County clerk -- and it was sent with no agency stamp on it. That disclosure docyment was missing 12M in commercial real estate and had other defects -- and was not even vsibile or known to exist from public facing county systems. (major major major concerns)
City - no information on their protocals at this time.
Multi- County agency - no information at this time and very concerning -- as these are the groups that can plan and do without oversight -- AND they are being manned by County Supervisors who can pool improper interests. (majorest concerns x 10)
Concerns in More Detail
Concerns in More Detail
Where/with who/how did/do filers file? - Paper filing
Where/with who/how did/do filers file? - Paper filing
County filing example.
Elected County officials OTHER THAN board of supervsiors would have filed with the Clerk of the County. NOTE the Clerk is an elected person too and as of 1995 - the "Assessor - Recorder - County Clerk" roles were all condensed.
Board of Supervisors would have filed with the Clerk of the Board and he/she would have conveyed to the County Clerk for publishing.
Then if anything needed to go to the state, as it the case for Board of Supervisors (but oddly, not other county elected officials) the Clerk of County would mail/email those to the state.
That may or may not have been happening properly. The DA for example, seems to just have ignored filing for a few years. Members of the Board of Supervisors seem to have been filing paper copies directly wth the Clerk of County not their own clerk first. etc.
NOTE: each clerk or office that accepted SEI 700 documents would have had a stamp and stamped them with date (time and initials of person who took in the documents). If that office/agency was not the ultimate destination for the filing, they would forwarded those to the next clerk up the chain at the County or the State , with each subsequent clerk adding their own stamp with date (and time and initials) as well.
We can still see this with some examples that were not efiled and filed with the lower agencies.
Where/with who do filers file? In General - efiling
Where/with who do filers file? In General - efiling
When efinling was implemented (year uknown but seems it was prior to 2014) , there seems to have been a total loss of attention on document / information chain of command AND the process that would have transpired prior where a form should have been checked for general completeness prior to getting a stamp. The efile stamps now seem to represent a "submitted" date and time NOT an "accepted" date and time and it's unclear if any review for an appropriate level of completeness and data integrity is happening after submission. County filiers are using a system submtting directly to county clerk -- seemingly bypassing their own agency clerks. State Filers are filing directly with FPPC, skipping their own clerks when they exist.
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