TO: Mayor and Members of City Council
THRU: Dr. Douglas J. Hewett, DBA, ICMA-CM, City Manager
FROM: Rose Rasmussen, CIA, CFE, Internal Audit Director
DATE: February 6, 2026
RE:Title
City of Fayetteville Conflict of Interest Questionnaire
Title
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COUNCIL DISTRICT(S):
Council District(s)
All Districts
b
Relationship To Strategic Plan:
Goal 6: The City of Fayetteville will continue to have a collaborative citizen and business engagement base.
Executive Summary:
Mayor Colvin input a City Council Agenda Item Request to the November 10, 2025 work session to request City Council approve the disclosure of their annual conflict of interest forms for the years 2024 and 2025. However, the action voted on by the consensus of Mayor and Council was to have staff come back with best practices for a consistent process with a unified form for the annual conflict of interest questionnaire to make them available and easily accessible like the State Ethics Commission forms.
Internal Audit staff conducted peer municipality research and contacted the UNC School of Government. Based on this research, Internal Audit determined disclosures ask similar questions to the current City of Fayetteville’s questionnaire and are most commonly:
• Completed in writing with signature;
• Public record and available for inspection and copying by any person during normal business hours, and
• Submitted to the Clerk.
Internal Audit also reviewed the State Ethics Commission forms and formats in which the forms could be completed. Internal Audit staff determined the main reason the State Ethics Commission 2025 Statement of Economic Interest form cannot be substituted for the City’s conflict of interest questionnaire is because the State form focuses on conflicts related to State service, not service as a City of Fayetteville Mayor or Council Member.
Consistent with the City of Fayetteville conflict of interest questionnaire, the State Ethics Commission allowed an electronic and a manual filing option for their forms.
Background:
The City’s Code of Ethics, Chapter 2, Article IV, section 2-95(j) Conflict of Interest Questionnaire, states “All elected officials, members of the city senior management team, and a random sample of city employees shall be required to complete the conflict of interest questionnaire sent by the city’s internal auditor and certify that they have read the City of Fayetteville Code of Ethics.”
The Internal Audit Office has been requiring completion of the City’s Conflict of Interest Questionnaire since FY2018. Since that time there have been minor changes to the questionnaires.
The FY2018 conflict of interest questionnaire was a PDF that required the form be printed, completed and signed. Starting with FY2019 the PDF was fillable; therefore, the form could be completed electronically to include an electronic signature, or printed and completed manually. For FY2023 and FY2024, the option was given to either complete the fillable PDF form electronically with either an electronic signature or ink signature, or complete the electronic Microsoft Forms questionnaire.
Each year when the PDF forms were completed, Internal Audit staff manually keyed the information needed to complete the annual review into an Excel spreadsheet. However, the Microsoft Forms questionnaire saved the information into Excel; therefore, saving Internal Audit staff time that was previously used to manually key the information into an Excel spreadsheet.
Issues/Analysis:
Peer Municipality Research:
• The most common disclosure format among peer municipalities is a written form with wet signature.
• Disclosures are typically submitted to the Clerk.
• Completed disclosures are available for inspection and copying during normal business hours.
• Among surveyed Internal Audit peers, the City of Fayetteville was the only municipality whose Internal Audit Office obtained questionnaires and conducted an annual conflict of interest review.
The City of Charlotte appears to have modified the State Ethics Commission form to work for their purposes.
State Disclosure Form vs. City Questionnaire
Internal Audit evaluated whether the State Ethics Commission 2025 Statement of Economic Interest (SEI) form could replace the City’s current conflict of interest questionnaire. Audit staff determined it could not for several reasons:
• The State form focuses on conflicts related to State service, not service as a City of Fayetteville Mayor or Council Member.
• The State form requires additional disclosures (e.g., ownership interest in North Carolina real estate) that would exceed Internal Audit’s staffing capacity to monitor for agenda related conflicts.
• The State form does not include home address information in the section available to the public.
• The State form limits family disclosures to household members, whereas the City’s questionnaire asks about immediate family members regardless of place of residence.
The State Ethics Commission allows the SEI forms to be filled out either electronically through the State Ethics Commission public filing portal, or manually.
UNC School of Government Guidance
UNC School of Government (UNC SOG) faculty advised that State law does not mandate a specific format or process for local government conflict of interest disclosures. The disclosure template provided by UNC SOG closely mirrors the City’s existing questionnaire.
Budget Impact:
None
Options:
1. Continue with the current fillable PDF City of Fayetteville Annual Conflict of Interest Questionnaire for Mayor and Council requiring a printed form with a wet signature which meets the City’s Code of Ordinances requirements.
2. Direct staff to implement a conflict of interest disclosure process as specified by City Council and return with any required implementation or ordinance changes.
Recommended Action::Recommended Action
Continue with the current fillable PDF City of Fayetteville Annual Conflict of Interest Questionnaire for Mayor and Council requiring a printed form with a wet signature which meets the City’s Code of Ordinances requirements.
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Attachments:
FY26 Annual Conflict of Interest Questionnaire
State Ethics Commission 2025 Statement of Economic Interest form
UNC SOG Disclosure Template
Charlotte NC Statement of Economic Interest
Conflict of Interest Presentation