Form CIQ Conflict of Interest Questionnaire: Filing and Penalties

Form CIQ, the Conflict of Interest Questionnaire, is a one-page disclosure that vendors file with a Texas local government entity when they have a qualifying business relationship, family tie, or gift history involving one of that entity’s officers. The form comes from the Texas Ethics Commission under Chapter 176 of the Texas Local Government Code. You file it with the records administrator of the local government you want to do business with, not with the state, and you have seven business days from the start of contract discussions or the submission of a bid to get it in.¹

Do You Have to File

Chapter 176 defines a vendor as any person who enters or seeks to enter into a contract with a local governmental entity, including an agent acting on the vendor’s behalf. If that is you, a filing is required when any one of three things is true:

You have an employment or other business relationship with a local government officer of that entity, or with a family member of that officer.
You have given the officer or a family member one or more gifts with a combined value of more than $100 in the twelve months before the officer became aware the entity executed or is considering a contract with you.
You are related to a local government officer of that entity by blood or marriage within the degrees Chapter 573 of the Texas Government Code covers.

A “local government officer” here means a member of the entity’s governing body (a city council member, county commissioner, or school board trustee, for example) or a person designated as the entity’s executive officer, such as a superintendent, city manager, or executive director.² Rank-and-file employees are not officers for this purpose.

Two boundaries worth flagging. A “business relationship” under Section 176.001(1-a) excludes transactions subject to government rate regulation, purchases made at prices and terms available to the general public, and purchases from entities like chartered banks that are already subject to regular examination.² And the $100 gift threshold is cumulative across twelve months, so a series of smaller items — meals, tickets, travel accepted as a guest — can add up to a filing obligation.³

How to Fill Out Each Section

Download the current version from the Texas Ethics Commission at ethics.state.tx.us.⁴ The form has seven numbered sections. Most take a sentence or two. Here is what each one is asking for.

Section 1 — Vendor name. Enter your full legal name or the name of the business entity. If you are filing as an agent, use the entity’s name, not your personal name.

Section 2 — Update checkbox. Leave this blank on an initial filing. Check it only when you are refiling to correct or supplement a prior questionnaire.

Section 3 — Officer name. Provide the full name of the local government officer you are disclosing about. If more than one officer is involved, you may need a separate form for each.

Section 4 — Taxable income. Answer both sub-questions. Sub-question A asks whether the officer or a family member receives, or is likely to receive, taxable income (other than investment income) from you. Sub-question B reverses the direction: whether you receive or are likely to receive taxable income from the officer or a family member, not counting income that comes from the governmental entity itself. Mark Yes or No for each.

Section 5 — Describe the relationship. Write out the nature of each employment, business, or family relationship with the officer or the officer’s family member. Be specific. “Officer’s spouse is employed as a project manager at my firm” is more useful than “business relationship exists.” Attach additional pages if you need the room.

Section 6 — Corporate connections. Describe any employment or business relationship you have with a corporation or other entity in which the officer serves as an officer or director, or holds an ownership interest of one percent or more.

Section 7 — Gifts and signature. Check the box if you have given the officer or a family member gifts exceeding the $100 aggregate threshold. Sign and date the form. Your signature certifies that the information is true and correct to the best of your knowledge.¹

Write your descriptions in Sections 5 and 6 knowing they will be read outside the transaction. Every questionnaire filed under Chapter 176 is a public record, and if the local entity has a website, it must provide access to filings there.² Competitors, journalists, and taxpayers can look up what you wrote.

Where and When to File

File the completed form with the records administrator of the local governmental entity you are contracting with. Each city, county, school district, and special district maintains its own records administrator. There is no state-level submission.

The deadline is the seventh business day after the later of two events: the date you begin discussions or negotiations to enter a contract, or the date you submit a bid, proposal, application, or other written correspondence related to a potential contract.¹ That window is tight. The safest practice is to complete the form before you submit a bid and deliver both together.

Many entities now accept the form through an electronic portal or by email to the purchasing office or clerk. If yours does not, hand-deliver the form or send it by certified mail with a return receipt so you can prove the submission date. The deadline is entirely your responsibility; the entity is not required to remind you or grant an extension.

Updating a Prior Filing

Your obligation does not end after the initial filing. If any statement on a previously filed questionnaire becomes incomplete or inaccurate, you must file an updated version no later than the seventh business day after you become aware of the change.⁵ A new family relationship with an officer, a partner leaving your firm, or a gift that pushes you past the $100 threshold would all warrant an update.

There is no separate amendment document. You refile the same Form CIQ with corrected answers, and this time you check the box in Section 2 to flag it as an update.

Penalties for Not Filing

A vendor who knowingly violates the filing requirements under Section 176.006 commits a criminal offense. The class scales with the contract amount:

Class C misdemeanor if the contract is worth less than $1 million or has no stated amount. Fine up to $500.
Class B misdemeanor if the contract is worth at least $1 million but less than $5 million. Fine up to $2,000 and up to 180 days in jail.
Class A misdemeanor if the contract is worth $5 million or more. Fine up to $4,000 and up to one year in jail.²

Beyond the criminal exposure, a missing or late questionnaire is easy to spot in a public records request and can damage your standing with the contracting entity on future work.

1
Texas Ethics Commission. Form CIQ Conflict of Interest Questionnaire
2
State of Texas. Texas Local Government Code Chapter 176
3
State of Texas. Texas Local Government Code 176.003
4
Texas Ethics Commission. Conflict of Interest Forms
5
State of Texas. Texas Local Government Code 176.006