Attachment 1 - Show Me the Money - Financial Transparency NeededRelease date here Page 0 of 22
SHOW ME THE MONEY:
FINANCIAL TRANSPARENCY NEEDED
2022 Santa Clara County
Civil Grand Jury
December 14, 2022
ATTACHMENT 1
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TABLE OF CONTENTS
GLOSSARY AND ABBREVIATIONS ...................................................................................... 2
SUMMARY ................................................................................................................................... 3
BACKGROUND ........................................................................................................................... 4
METHODOLOGY ....................................................................................................................... 5
INVESTIGATION ........................................................................................................................ 6
CONCLUSION ........................................................................................................................... 11
FINDINGS AND RECOMMENDATIONS ............................................................................. 12
REQUIRED RESPONSES ......................................................................................................... 15
APPENDIX ................................................................................................................................. 16
REFERENCES ............................................................................................................................ 19
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GLOSSARY AND ABBREVIATIONS
Government Code, Section
41004
California Government Code section 41004 states:
“Regularly, at least once each month, the city treasurer
shall submit to the city clerk a written report and
accounting of all receipts, disbursements, and fund
balances. The city treasurer shall file a copy with the
legislative body.”
Treasurer’s Reports
The reports required by Government Code section 41004
may have various styles and titles. For purposes of this
report, the Civil Grand Jury will refer to these reports
throughout as "treasurer's reports."
Charter City
Article XI, section 3(a) of the California Constitution
authorizes the adoption of a city charter and provides that
the charter has the force and effect of state law. Article XI,
section 5(a), the "home rule" provision, grants to charter
cities the ability to govern over "municipal affairs."
There are six charter cities in Santa Clara County: San
José, Palo Alto, Santa Clara, Sunnyvale, Gilroy, and
Mountain View.
General Law City
A general law city may only have a form of government
authorized by state general law. A city that has not
adopted a charter is bound by the state’s general laws even
with respect to municipal affairs.
There are nine general law cities and towns in Santa Clara
County: Los Altos, Los Altos Hills, Los Gatos, Milpitas,
Campbell, Monte Sereno, Cupertino, Saratoga and
Morgan Hill. The scope of this investigation is limited to
general law cities.
GAAP Generally Accepted Accounting Principles: a set of
accounting rules and standards established by the
accounting industry.
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SUMMARY
General law cities in California are required to comply with California Government Code section
41004 (Section 41004), which states, “at least once each month, the city treasurer shall submit to
the city clerk a written report and accounting of all receipts, disbursements, and fund balances.
The city treasurer shall file a copy with the legislative body.” The benefit of the law is to ensure
financial accountability and public transparency as well as to foster better fiscal affairs. Treasurer's
reports provide city councils with timely and accurate financial information necessary to make
reliable and sound decisions.
The 2022 Santa Clara County Civil Grand Jury (Civil Grand Jury) found that there is widespread
noncompliance with this state requirement throughout Santa Clara County (County) by the general
law cities. As of the date of this report, six of the nine general law cities1 in the County are
noncompliant with this state law: Los Altos, Los Altos Hills, Los Gatos, Milpitas, Campbell, and
Monte Sereno. Additionally, the City of Cupertino was initially noncompliant until the city took
corrective action during the Civil Grand Jury’s investigation. The City of Saratoga and City of
Morgan Hill were the only two cities compliant prior to the investigation.
Based on responses from city officials, the Civil Grand Jury determined that there is a widespread
misunderstanding among these general law cities in the County regarding Section 41004 reporting
requirements. The Civil Grand Jury recommends that the noncompliant cities – Los Altos, Los
Altos Hills, Los Gatos, Milpitas, Campbell, and Monte Sereno – comply with Section 41004.
1 The Town of Los Altos Hills and the Town of Los Gatos are general law cities.
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BACKGROUND
The State Legislature established the office of city treasurer by enactment of California
Government Code, Title 4 - Government of Cities, Division 3 - Other Officers, Chapter 3 - City
Treasurer. The statutory duties for city treasurers may generally be found in the following sections:
Section 41001: The city treasurer shall receive and safely keep all money the treasurer
receives.
Section 41002: (a) The city treasurer shall comply with all laws governing the deposit and
securing of public funds and the handling of trust funds in their possession; and (b) if the
city has issued bonds, the city treasurer shall use a system of accounting and auditing that
adheres to generally accepted accounting principles.
Section 41003: The city treasurer shall pay out money only on warrants signed by legally
designated persons.
Section 41004: Regularly, at least once each month, the city treasurer shall submit to the
city clerk a written report and accounting of all receipts, disbursements, and fund balances.
The city treasurer shall file a copy with the legislative body.
Pursuant to California Government Code section 36502, the city treasurer is an elective office.
California Government Code section 36508 and California Elections Code section 9222 permit
cities to submit to the electors the question of whether the city treasurer position should be an
appointive office. In that instance, the financial duties assigned by the state statutes to the city
treasurer are transferred from an elected treasurer to an appointed officer if approved by the
electorate. Only one general law city in the County, Morgan Hill, continues to have an elected city
treasurer, who serves for four years. All other cities in the County have opted to assign city
treasurer duties to senior administrative staff.
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METHODOLOGY
Upon receiving a complaint regarding Government Code section 41004 noncompliance in
Cupertino, the Civil Grand Jury decided to expand the investigation to review all nine general law
cities in the County: Los Altos, Los Altos Hills, Los Gatos, Milpitas, Campbell, Monte Sereno,
Cupertino, Saratoga, and Morgan Hill. From March to August 2022, the Civil Grand Jury began
the process by polling these Cities to determine if they produced treasurer’s reports.
The Civil Grand Jury took the following steps:
• Contacted a total of 22 officials across nine cities who were responsible for tasks relevant
to the topic of this report.
• Reviewed relevant sections of the California Government Code, California Elections Code,
and examined the ordinances, policies, and memos of each city relevant to their city
treasurer duties.
• Reviewed published city council and city committee agendas relevant to Section 41004.
• Reviewed other relevant city documents, including but not limited to financial audits, city
organizational charts, and relevant job descriptions.
• Verified the six most recent treasurer’s reports of each city, if submitted.
The Civil Grand Jury inspected the contents of each report to verify the inclusion of the required
elements: monthly disbursements, receipts, and fund balances. The Civil Grand Jury also
determined whether the reports were published at least once each month to be compliant with
Section 41004.
It should be noted that most cities do not call their report “Treasurer’s Report.” Appendix A
provides links to examples of compliant Section 41004 reports, showcasing variations in terms of
report name, style, layout, and appearance.
The Civil Grand Jury used the 2011-2012 Solano County Civil Grand Jury report entitled “City
Treasurer Functional Review” as a reference for this report.
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INVESTIGATION
All interviews and email correspondence were designed to determine if general law cities complied
with Section 41004. To be deemed compliant, a city must produce a financial document at least
once each month that details all of the following: monthly disbursements, receipts, and fund
balances – and must be filed with the legislative body. Six months of reports were requested to
verify an existing track record. Data collection and verification took place from March to July
2022.
The results of this investigation are depicted in Table 1 below.
Table 1. Section 41004 Compliance Among Nine General Law Cities
City/Town Compliant Noncompliant
Los Altos X
Los Altos Hills X
Los Gatos X
Milpitas X
Campbell X
Monte Sereno X Cupertino X*
Saratoga X
Morgan Hill X *During the investigation, Cupertino started complying with Section 41004.
There are a number of reasons for cities’ noncompliance:
• Some cities were under the impression that the Section 41004 mandate was a discretionary
guideline.
• Others adopted the practice of other cities that did not produce the requisite monthly
reports.
However, the primary error among the cities was that they produced abbreviated reports that
omitted required information such as receipts, disbursements, and fund balances. Some of the
deficient reports lacked substance, with abbreviated information presented without context or
details.
The Civil Grand Jury believes there is no fiscal impact involved in complying with Section 41004.
Outside resources should not be required since existing staff already make some financial reports,
collect this type of data, and should be able to produce treasurer’s reports. Therefore, each of the
deficient cities can be compliant with minimal effort or burden.
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Noncompliant Cities and Towns
Los Altos
The City of Los Altos does not have an elected city treasurer. Further, the Los Altos Municipal
Code does not specifically state which official performs the duties of a city treasurer. Los Altos
Municipal Code Section 2.01.060, however, provides that the city manager is the administrative
head of the city and is specifically empowered “keep the council at all times fully advised as to the
financial condition and needs of the city.” In the City of Los Altos, monthly treasurer’s reports are
not prepared and submitted to the city clerk in accordance with Section 41004.
At the time of the Civil Grand Jury inquiry in June 2022, the City of Los Altos did not submit any
treasurer’s reports. According to the City of Los Altos, Government Code section 37208
indemnified them from the Section 41004 mandate. However, the language of Government Code
Section 37208 refers to payroll warrants or checks and makes no mention of the reporting required
by Section 41004, which requires a report of “receipts, disbursements and general fund balances.”
Moreover, the language of Government Code Section 37208 neither excuses a city from complying
with Section 41004 nor makes any reference to Section 41004.
Further, the city erroneously noted that its Generally Accepted Accounting Principles (GAAP)
policy on financial reporting excused noncompliance with Section 41004 reporting requirements.
In 2015, the city adopted a “Financial Policy” that reads in part, “The city’s accounting and
financial reports are to be maintained in accordance with GAAP.” GAAP accounting does not
address the Section 41004 mandated requirements.
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The Civil Grand Jury determined that the City of Los Altos does not produce treasurer’s reports
and thus is noncompliant.
Los Altos Hills
The Town of Los Altos Hills does not have an elected city treasurer. The town’s Municipal Code
is silent on who performs the duties of the treasurer; however, the Civil Grand Jury learned that
the treasurer responsibilities fall to the director of administrative services.
The Civil Grand Jury received monthly treasurer’s reports in June 2022. Upon inspection,
however, they contained only disbursements and lacked receipts as well as fund balances; thus the
reports are incomplete and noncompliant.
Los Gatos
The Town of Los Gatos does not have an elected city treasurer. The town’s Municipal Code
Section 2.30.035 delegates the responsibility of the treasurer and the ability to assign those duties
to the town manager. The director of finance is responsible for the town’s financial matters. The
Town of Los Gatos produces quarterly reports, not monthly reports as required by Section 41004.
While the disbursements, receipts, and fund balances are in the reports, they must be published at
least once each month to comply with Section 41004. Because the production intervals are
quarterly, the Town of Los Gatos is not in compliance.
Milpitas
The City of Milpitas does not have an elected city treasurer. Milpitas Municipal Code section VI-
1-3.02 vests the duties of a city treasurer with the city manager, who is empowered to appoint a
city treasurer pursuant to Section VI-1-3.04. In the City of Milpitas, the finance director produces
weekly disbursement reports, quarterly receipt and investment reports for the general and special
districts’ funds, and annual reports for all other reporting.
At the time of inquiry in June 2022, the Civil Grand Jury noted well-prepared reports. However,
the frequency of report submission does not meet Section 41004 criteria, which requires monthly
reports. Reports showing all receipts, disbursements, and fund balances must be filed with the city
clerk at least once each month. Due to submission infrequency, the City of Milpitas is not in
compliance.
Campbell
In November of 2010, voters in the City of Campbell approved Measure O, which changed the
office of the city treasurer (and city clerk) from an elected to an appointed office. The City of
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Campbell’s Municipal Code is silent on who has officially assumed those duties.2 The Civil Grand
Jury learned that the city’s finance director has the responsibilities of a treasurer and oversees the
preparation of financial reports. The reports are prepared by the accounting clerk, reviewed by the
finance manager and the finance director, and approved by the city manager for inclusion in the
council packet.
At the time of inquiry in June 2022, 21 reports were submitted. The submitted documents had no
payroll records and accounts payable balances with paid or disbursed funds. Additionally, the
required information was not published at least once each month.
The City of Campbell’s submitted reports do not comply with Section 41004 because
disbursements, receipts, and balances are not filed at least once each month.
Monte Sereno
The City of Monte Sereno does not have an elected city treasurer. The Monte Sereno Municipal
Code section 2.04.010 designates the city manager as the director of finance and tasks the city
manager with “performing all duties of City treasurer as set forth in Government Code sections
41000 et seq.” At the time of inquiry in June 2022, six treasurer’s reports were received by the
Civil Grand Jury. While the reports did contain the required fund balances, the receipts and
disbursements were not compliant with the Section 41004 requirement.
Compliant Cities
Cupertino
The City of Cupertino does not have an elected city treasurer. The City of Cupertino’s Municipal
Code section 2.24.030 states:
The treasurer shall make monthly reports which conform to the requirements of
Government Code Section 41004. Said reports shall be delivered to the City Council, city
manager and made available for review by such other persons who may so request.
Until 2022, no staff member for the City of Cupertino had been preparing and delivering a monthly
treasurer’s report to the Cupertino City council. However, during the Civil Grand Jury's
2 The City of Campbell’s Municipal Code does not appear to have been updated. The City of Campbell’s Municipal Code section 2.08.010 still states that the elected officers shall be those designated by general laws, which includes a city treasurer. Further, the code has other references to an elected city treasurer. (See Sections 2.16.040 [city treasurer compensation] and 2.16.010 [establishment of salaries].)
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investigation, the belated monthly treasurer’s reports for January and February 2022 were
published and placed on the Cupertino Audit Committee agenda.
The Civil Grand Jury recognizes the action taken by the City of Cupertino as soon as it was brought
to their attention. The City of Cupertino is now compliant with Section 41004 as of March 2022,
despite the stated history of not submitting the required reports.
Saratoga
The City of Saratoga does not have an elected city treasurer. The City of Saratoga Municipal Code
section 2-20.035 states that the city manager shall serve as the city treasurer and be responsible for
“other duties and responsibilities as required by law to be performed by the City Treasurer.” Thus,
the city manager is responsible for the preparation and submission of monthly treasurer’s reports.
The Civil Grand Jury verified in June 2022 that regular monthly treasurer’s reports are filed with
the City of Saratoga and are fully compliant with Section 41004. These reports can also be found
by the public on the city’s website. An example is shown in Appendix A.
Morgan Hill
The City of Morgan Hill has an elected city treasurer. The treasurer, in conjunction with the finance
director, prepares the treasurer’s reports.
The Civil Grand Jury verified in June 2022 that regular monthly treasurer’s reports are produced.
The reports contain all the required components of disbursements, receipts, and fund balances.
Thus, the City of Morgan Hill is compliant with Section 41004. A compliant Morgan Hill
treasurer’s report is shown in Appendix A.
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CONCLUSION
Within the County, there is widespread noncompliance with California Government Code section
41004 by the general law cities. The Civil Grand Jury commends the cities of Saratoga and Morgan
Hill for being in full compliance and notes the City of Cupertino’s quick action to become
compliant. The Civil Grand Jury recommends that the noncompliant cities of Los Altos, Los Altos
Hills, Los Gatos, Milpitas, Campbell, and Monte Sereno comply with Section 41004. This is to be
done by producing treasurer’s reports at least once each month containing the required
disbursements, receipts, and fund balance information. The benefit of implementing this
recommendation overshadows any limited cost impact since existing staff could compile the
report. In short, there is great benefit in producing these reports, as they improve financial
transparency to the residents of the cities.
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FINDINGS AND RECOMMENDATIONS
It is recommended that noncompliant cities start producing treasurer’s reports as required by law.
Some cities produce abbreviated information that does not include requisite financial information
as defined in state Government Code section 41004. Some cities produce requisite reports, but not
on a monthly basis.
Finding 1
The City of Los Altos is not submitting monthly treasurer’s reports in compliance with California
Government Code section 41004.
Recommendation 1
The City of Los Altos should comply with Government Code section 41004 by submitting monthly
treasurer’s reports that include monthly disbursements, receipts, and fund balances and by filing
those reports with the city. This recommendation should be implemented by March 15, 2023.
Finding 2
The City of Los Altos does not produce treasurer’s reports in compliance with California
Government Code section 41004. The reason provided for non-compliance was that the City of
Los Altos’ financial policy does not require the preparation and submission of treasurer’s reports.
It is an erroneous belief that internal policies excuse compliance with Government Code section
41004.
Recommendation 2
The City of Los Altos should amend its financial policy to require that monthly treasurer’s reports
be prepared and submitted in accordance with California Government Code section 41004 by
March 15, 2023.
Finding 3
The Town of Los Altos Hills produces monthly treasurer’s reports but the content of those reports
lacks monthly disbursements, receipts, and fund balances required by California Government Code
section 41004.
Recommendation 3
The Town of Los Altos Hills should update their existing monthly reports to include monthly
disbursements, receipts, and fund balances by March 15, 2023.
Finding 4
The Town of Los Gatos produced reports that contain the required content but does not produce
the treasurer’s reports on a monthly basis as required by California Government Code section
41004.
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Recommendation 4
The Town of Los Gatos should produce its reports on a monthly basis to comply with California
Government Code section 41004 by March 15, 2023.
Finding 5
The City of Milpitas does not produce monthly treasurer’s reports as required by California
Government Code section 41004.
Recommendation 5
The Civil Grand Jury recommends that the City of Milpitas comply with California Government
Code section 41004 by producing monthly treasurer’s reports that include monthly disbursements,
receipts, and fund balances by March 15, 2023.
Finding 6
The City of Campbell does not produce monthly treasurer’s reports as required by California
Government Code section 41004.
Recommendation 6
The City of Campbell should comply with California Government Code section 41004 by
producing monthly treasurer’s reports that include monthly disbursements, receipts, and fund
balances by March 15, 2023.
Finding 7
The City of Monte Sereno does not produce monthly treasurer’s reports as required by California
Government Code section 41004.
Recommendation 7
The City of Monte Sereno should comply with California Government Code section 41004 by
producing monthly treasurer’s reports that include monthly disbursements, receipts, and fund
balances by March 15, 2023.
Finding 8
When the Civil Grand Jury began this investigation, the City of Cupertino was not in compliance
with California Government Code section 41004. However, starting in March 2022, the City of
Cupertino began producing treasurer’s reports compliant with Section 41004.
Recommendation 8
The City of Cupertino should maintain compliance with California Government Code section
41004. Continued compliance is recommended.
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Finding 9
The Civil Grand Jury commends the City of Saratoga for producing monthly treasurer’s reports
that include disbursements, receipts, and fund balances. The City of Saratoga is in full compliance
with California Government Code section 41004.
Recommendation 9
No recommendation.
Finding 10
The Civil Grand Jury commends the elected city treasurer for producing monthly treasurer’s
reports that include monthly disbursements, receipts, and fund balances. The City of Morgan Hill
is in full compliance with California Government Code section 41004.
Recommendation 10
No recommendation.
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REQUIRED RESPONSES
Pursuant to California Penal Code section 933(b) et seq. and California Penal Code section
933.05, the Civil Grand Jury requests responses from the following governing bodies:
Responding Agency Findings Recommendations
City of Los Altos 1, 2 1, 2
Responding Agency Findings Recommendations
Town of Los Altos Hills 3 3
Responding Agency Findings Recommendations
Town of Los Gatos 4 4
Responding Agency Findings Recommendations
City of Milpitas 5 5
Responding Agency Findings Recommendations
City of Campbell 6 6
Responding Agency Findings Recommendations
City of Monte Sereno 7 7
Responding Agency Findings Recommendations
City of Cupertino 8 8
Responding Agency Findings Recommendations
City of Saratoga 9
Responding Agency Findings Recommendations
City Treasurer of Morgan Hill 10
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APPENDIX A: EXAMPLES OF COMPLIANT TREASURER’S
REPORTS
On the following pages are two examples of monthly treasurer’s reports that contain the required disbursements, receipts, and starting and ending fund balances and are therefore compliant with California Government Code section 41004. They are included to show that there are various
names and formats that the reports may take. Following the examples are links to the full reports
for ease of access.
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Example 1. Page 3 of 7 from Saratoga August 2022 Treasurer’s Report
https://legistarweb-
production.s3.amazonaws.com/uploads/attachment/pdf/1578630/Treasurer_Report_for_August_
2022.pdf
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Example 2. Page 12 of 21 from Morgan Hill March 2022 Financial and Investment Report
https://www.morgan-hill.ca.gov/DocumentCenter/View/40944/March-2022-Financial-and-Investment-Report-PDF
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REFERENCES
Bibliography
Campbell City Council meetings: December 7, 2021-June 7, 2022. Regular agenda item from the Finance Department, titled Approving Bills and Claims. https://campbellca.gov/AgendaCenter/
(Accessed November 28, 2022).
Campbell City Council meeting: February 1, 2022. Regular agenda item from the Finance Department, titled Investment Report – Quarter Ending December 2021. https://campbellca.gov/AgendaCenter/ (Accessed November 28, 2022).
Campbell City Council meeting: May 3, 2022. Regular agenda item from the Finance Department,
titled Investment Report – Quarter Ending March 2022. https://campbellca.gov/AgendaCenter/ (Accessed November 28, 2022).
Campbell City Council meetings: December 7, 2021 – June 7, 2022. Regular agenda item from the Finance Department, titled Monthly Investment Transactions Report. https://campbellca.gov/AgendaCenter/ (Accessed November 28, 2022).
Campbell City Council meeting: April 25, 2022, Study Session Meeting of the Campbell City
Council. https://campbellca.gov/AgendaCenter/ (Accessed November 28, 2022).
City of Cupertino, A- Payments to Chamber Jan 2015- Mar 2022. Report, 2022. https://cupertino.legistar.com/ (Accessed November 28, 2022).
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Comprehensive Annual Financial Report. https://cupertino.legistar.com/ (Accessed November 28, 2022).
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AAEB-7E5FF0F1EF8C&Search= (Accessed November 28, 2022).
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Disbursements, and Cash Balances Cash Investments. http://cupertino.legistar.com/ (Accessed November 28, 2022).
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Cupertino City Council meeting, April 25, 2022. Administrative Services Department, Audit
Committee Staff Report for March, 2022. https://cupertino.legistar.com/ (Accessed November 28,
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Cupertino City Council meeting, May 19, 2022. Amended Agenda of the Cupertino City Council.
https://cupertino.legistar.com/ (Accessed November 28, 2022).
Cupertino Office of the City Clerk, Notice of Adjournment of the May 17, 2022. Notice, May 17, 2022. https://cupertino.legistar.com/ (Accessed November 28, 2022).
Cupertino, Payment Register. Report, December 21, 2021. http://cupertino.legistar.com/ (Accessed November 28, 2022).
Cupertino, Resolution NO. 22-015. Resolution, 2022. http://cupertino.legistar.com/ (Accessed
November 28, 2022).
City of Lancaster, Excerpt from A Quick Summary for the Press and Researchers, https://www.cityoflancasterca.org/home/showpublisheddocument/10103/635775792210230000 (Accessed November 28, 2022).
Los Altos City Council meetings, January, 2022 – May, 2022. Monthly Disbursement Listing. https://www.losaltosca.gov/calendar/month?field_microsite_tid=2131&field_microsite_tid_1=All (Accessed November 28, 2022).
Los Altos City Council meeting, May 24, 2022. Quarterly Investment Portfolio Report – Quarter
Ended March 31, 2022. https://www.losaltosca.gov/citycouncil/page/city-council-meeting-155
(Accessed November 28, 2022).
Los Altos City Council meeting, March 8, 2022. Quarterly Investment Portfolio Report – Quarter Ended December 31, 2021. https://mccmeetingspublic.blob.core.usgovcloudapi.net/losaltosca-meet-419c5823741c494d9706451908d3061f/ITEM-Attachment-001-
0979a9a16c5c4dc898b8e8d7d4d4a6e1.pdf (Accessed November 28, 2022).
Los Gatos Town Council meeting, February 15, 2022. Second Quarter Investment Report (October
through December 2021) for Fiscal Year 2021/22. https://mccmeetings.blob.core.usgovcloudapi.net/losgatos-pubu/MEET-Packet-94e86df454424b8b95ccc3f6eff96e41.pdf (Accessed November 28, 2022).
Los Gatos Town Council meeting, May 17, 2022. Third Quarter Investment Report (January
through March 2022) for Fiscal Year 2021/22 https://mccmeetings.blob.core.usgovcloudapi.net/losgatos-pubu/MEET-Packet-997ea555609c4af9b94eeb28b34fc7e3.pdf (Accessed November 28, 2022).
Monte Sereno City Council meetings: December 28, 2021 – June 3, 2022. Regular agenda item
from the Finance Department submitting the monthly Treasurer’s Report.
https://montesereno.civicweb.net (Accessed November 28, 2022).
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City of Morgan Hill Finance Division, Monthly Financial and Investment Reports. March 31,
2022. https://www.morgan-hill.ca.gov/DocumentCenter/View/40944/March-2022-Financial-and-
Investment-Report-PDF (Accessed November 28, 2022).
City of Saratoga Administrative Services, Treasurer’s Report for the Month Ended August 31, 2022. Final Report, October 5, 2022. https://legistarweb-production.s3.amazonaws.com/uploads/attachment/pdf/1578630/Treasurer_Report_for_August_
2022.pdf (Accessed November 28, 2022).
Solano County 2011-2012 Grand Jury, City Treasurer Functional Review. Final Report, January 12, 2012. https://solano.courts.ca.gov/wp-content/uploads/2020/01/111227-City-Treasurer-Final.pdf (Accessed November 28, 2022).
California Government Code Sections 34000 – 45345.
Los Gatos Municipal Code 2.30.035.
Milpitas Municipal Code VI-1-3.04.
Interviews
Interviews were conducted with 16 individuals between April 25, 2022, and June 16, 2022.
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SHOW ME THE MONEY: FINANCIAL TRANSPARENCY NEEDED
This report was ADOPTED by the 2022 Santa Clara County Civil Grand Jury on this 14th day of
December, 2022.
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Karen Enzensperger
Foreperson