2020 Audit: Not All States Require Officials To Disclose Conflicts of Interest



Excerpt from the full report: Download below

2020 State Financial Disclosure Laws
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by Jack Hemphill and Jake Jacobs


As with the financial disclosure requirements for federal legislators, most states have ethics laws in place to identify their politicians’ potential conflicts of interest. The content of these policies and their quality vary greatly, but every state except Michigan and Idaho has legislated some baseline standard of financial transparency for their politicians.


We’ve ranked each state to see which ones have the best laws preventing financial conflicts of interest for their elected officials. The table below includes links to all of the available state financial disclosure databases as well as resources to find more information about each state’s disclosure requirements and sample financial disclosure forms from major state officials.

What makes a state’s financial disclosure system ‘good’? And why do some states earn higher grades than others? We based our grades on several factors:

  • Breadth of data- how many years of disclosures were available for how many elected officials

  • Depth of data- what data the disclosures contained, how specific the data was in regards to the value of assets, how assets were broken down into investments, real estate, etc

  • Ease of use- how easy it was to navigate the database and download disclosures

  • Accessibility- whether or not the data was publicly accessible without a login requirement, information request, or physical component

The most important factor is, in our view, accessibility. Thorough, back-dated, easy to parse disclosures aren’t useful to the public if they aren’t accessible. We gave out five ‘A’s (10%), fourteen ‘B’s (28%), ten ‘C’s (20%), 19 ‘D’s (38%), and two ‘F’s (4%).


Our ‘A’ rated states all have easily accessible and readable, back-dated, complete disclosures, which makes it trivial to request and analyze the financial behavior of state and local government officials. These five states differed slightly in their approach, but in general they had easily searchable databases, with the ability to search for specific positions over multiple years. The ability to download data into a .csv file was incredibly helpful in the case of Hawai’i. Specific asset value information was also helpful, Washington’s disclosures do a great job of addressing this issue.


‘B’ states are generally good, but they all have at least one flaw that prevents them from reaching ‘A’ range. California’s system is excellent in the data it contains, but navigating their menus can be confusing, and they don’t allow you to link to specific disclosures without downloading a .pdf. Alabama has a comprehensive database in terms of the number of officials available over a period of years, but the disclosures themselves are woefully vague.

The states that earned a ‘C’ generally had more pronounced flaws in our four criteria. New Hampshire’s system was difficult to navigate, with very limited available information. Tennessee doesn’t require any asset value listing as part of their disclosures. Their commitment to having a disclosure system is a positive, but the execution is sorely lacking.


The states that earned a ‘D’ all have barriers preventing easy access to their disclosures: an account requirement, request form, or physical component. We couldn’t accurately judge the quality of their disclosures, as we didn’t have access to them. We’ve included links to their disclosure request portals, but an additional step is required before accessing them.


The two states that earned an ‘F’, Michigan and Idaho, lack any sort of financial disclosure system for elected officials. Michigan has seen several attempts at ethics in government legislation stall; Idaho lawmakers rejected a similar measure in 2018.


Washington D.C. has a financial disclosure system, despite not being a state, and it was generally quite good, earning a ‘B.’ Puerto Rico was not ranked, as they have no disclosure system, bar a section in their territorial ‘Basic Financial Statements,’ a copy of which we have attached.

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