Texas Form CIQ is the one-page conflict of interest questionnaire that a vendor files with a local governmental entity when the vendor has a qualifying personal, business, or gift-based connection to one of that entity’s officers. It is required by Chapter 176 of the Texas Local Government Code, it goes to the entity’s records administrator rather than to the state, and it must be filed within seven business days of the triggering event. Skipping it is a Class C misdemeanor and, more often, a reason a contract stalls.1Texas Ethics Commission. Conflict of Interest
When You Have to File
If you are a vendor doing business or trying to do business with a local governmental entity in Texas, you must file Form CIQ if any one of these three situations applies:2State of Texas. Texas Code Local Government Code – Chapter 176
- You have an employment or other business relationship with a local government officer of that entity, or with a family member of that officer, that produces taxable income for the officer or the family member.
- You have given one or more gifts to a local government officer or a family member of that officer with a total value over $100 in a 12-month period. Section 176.003(a-1) excludes certain categories of gifts, so not every item counts toward the threshold.
- You are related to a local government officer of the entity by blood or marriage.
The triggers are independent. Only one has to apply.
Who Counts as a Vendor, Officer, or Family Member
Chapter 176 uses several terms in specific ways, and the answer to whether you have to file usually turns on them.
A vendor is any person who enters into or seeks to enter into a contract with a local governmental entity. The definition reaches agents acting on the vendor’s behalf, so a subcontractor or representative bidding for you has the same disclosure obligation you do.2State of Texas. Texas Code Local Government Code – Chapter 176
A local governmental entity covers counties, municipalities, school districts, junior college districts, and other political subdivisions. It also includes local government corporations, boards, commissions, districts, and authorities whose members are appointed by a county commissioners court, a mayor, or a municipal governing body.
A local government officer is either a member of the governing body (a city council member, county commissioner, or school board trustee) or the entity’s designated top executive, such as a superintendent, city manager, or president.
A family member means someone related within the first degree by consanguinity or affinity. In practice that is a parent, child, or spouse. Siblings, grandparents, aunts, uncles, and cousins fall outside the definition for Chapter 176 purposes.
Filling Out Form CIQ
Download the current version from the Texas Ethics Commission’s conflict of interest page at ethics.state.tx.us. The form has seven numbered sections.3Texas Ethics Commission. Texas Form CIQ Conflict of Interest Questionnaire
Sections 1 Through 3: Who Is Filing and About Whom
Section 1 is the vendor’s name. Individual contractors use their full legal name; a company uses its legal entity name.
Section 2 is a single checkbox you mark only if this filing updates a questionnaire you already submitted to the same entity. Leave it blank on an initial filing.
Section 3 is the name of the local government officer the disclosure concerns. If you have connections to more than one officer of the same entity, file a separate Form CIQ for each officer.
Section 4: The Relationship Itself
This is where most of the substance lives. Describe every employment or business relationship you have with the officer named in Section 3 or with a family member of that officer, and describe any family relationship with the officer. Then answer two sub-questions:
- 4A asks whether the officer or a family member is receiving or likely to receive taxable income (other than investment income) from you. Yes or no.
- 4B asks whether you are receiving or likely to receive taxable income (other than investment income) from or at the direction of the officer or a family member, where that income does not come from the local governmental entity itself. Yes or no.
Be specific. “Consulting arrangement” is vague. “Officer’s spouse provides monthly bookkeeping services to vendor under a $2,000/month retainer” is the level of detail that keeps the filing from coming back as incomplete. Attach additional pages if you need more room.
Section 5: Officer’s Role in a Business You Deal With
Section 5 covers a different angle. It asks whether you have an employment or business relationship with a corporation or other business entity in which the officer serves as an officer or director, or holds an ownership interest of one percent or more. If the officer sits on the board of a company your firm does business with, that connection goes here.
Sections 6 and 7: Gifts and Signature
Section 6 is a checkbox for gifts. Mark it if you gave the officer or a family member gifts with a total value over $100 in a 12-month period, keeping the statutory exclusions in mind.
Section 7 is your signature, printed name, and the date. No notary is required. An unsigned form does not satisfy the filing obligation.
Where to File and By When
File the completed questionnaire with the records administrator of the local governmental entity you are contracting with. That is usually the city secretary, county clerk, or another person the entity has designated to keep Chapter 176 filings. The form is hosted on the Texas Ethics Commission site, but it is not filed there.1Texas Ethics Commission. Conflict of Interest
Delivery methods vary. Some entities accept mail or in-person delivery; many use a vendor portal or email. If the solicitation documents include filing instructions, follow them.
The deadline is no later than the seventh business day after the later of two events:
- The date you begin discussions or negotiations with the entity, or the date you submit an application, bid response, correspondence, or any other writing related to a potential contract.
- The date you become aware of the qualifying relationship, gift threshold, or family tie.
The clock runs from whichever date is later. If you submitted a bid last month and only today learned that a board member’s spouse works at your company, the seven business days start today.
Updating a Filed Questionnaire
If circumstances change after you file, whether because a new relationship forms, a gift crosses the $100 line, or you realize the original filing was incomplete, submit an updated questionnaire within seven business days of becoming aware of the change. Check the box in Section 2 to mark it as an update.
There is also an annual refresh. If you filed your initial questionnaire before June 1 of a given year and you still have a pending or active contract with the entity, file an updated questionnaire by September 1 of that year.
What Happens If You Do Not File
Failing to file when required, or filing late, is a Class C misdemeanor under Section 176.006(f). A Class C misdemeanor carries a maximum fine of $500 and no jail time.2State of Texas. Texas Code Local Government Code – Chapter 176
The larger practical risk is usually the contract. Many local governmental entities will not execute a contract or approve a purchase order until a completed CIQ is on file, and some treat a missing form as a non-responsive bid. A missing questionnaire can stall or kill the deal regardless of whether anyone pursues the misdemeanor charge.