Summary of Reporting Thresholds
This guide provides the specific dollar amounts and ownership percentages that trigger a mandatory disclosure during the Current Period (May 1, 2025 – April 30, 2026). If any interest or transaction meets or exceeds these values, it must be reported on your Conflict of Interest form.
| Category | Threshold / Trigger | What to Report |
|---|---|---|
| Business Transactions | $5,000 | Ownership or investment interest in any entity providing (or negotiating) goods or services to the University. |
| Publicly Traded Company | 1% | Any ownership interest representing at least 1% of a publicly traded company that does business with the University. |
| Privately-Owned Company | 5% | Any ownership interest representing at least 5% of a privately-owned company that does business with the University. |
| Material Interest (Ownership) | > 5% | Ownership of more than 5% in any entity (excluding passive interest in publicly traded entities). |
| Material Interest (Income) | $10,000 | Any relationship with an entity resulting in payments of $10,000 or more in the preceding 12 months. |
| Business Relationships | $10,000 | Direct or indirect transactions (sale, lease, license, loan or services) between you and another person associated with the University. |
| Independent Status | $10,000 | Total compensation or payments received from the University as an independent contractor (excluding Trustee expense reimbursements). |
| Joint Ventures | > 10% | Any new or ongoing joint venture where your (or an Interested Person’s) profit or capital interest exceeds 10%. |
| Business Control | > 35% | Any entity where you, a Family Member, or a University Officer/Trustee possesses more than a 35% ownership interest. |
| Related Entity | > 35% | Any entity that is 35% controlled by you and/or your Family Members. |
| Gifts and Favors | “Substantial” | Any gifts, favors or sponsored/reimbursed travel expenses that are not nominal in value. |
Key Rules for Calculation
- Identifying a Related Entity: Under the 35% rule, you must aggregate the interests of all Family Members (spouse, ancestors, siblings, children, grandchildren and their spouses). If the combined control exceeds 35%, it is a Related Entity and its transactions with the University must be disclosed.
- Aggregate Value: For the $10,000 threshold in Business Relationships, calculate the total value of all transactions with that person or entity between May 1 and April 30.
- The “Preceding 12 Months” Rule: For a Material Interest involving payments or influence, look back at the 12-month period leading up to your current date.
- University Related Organizations: All thresholds apply equally to transactions with University-controlled entities, such as a University-controlled Real Estate LLC or bond-issuing authorities.
- Interested Persons: If you are a Trustee, Officer or Principal Investigator, you are an Interested Person. Any entity 35% owned by you or your family is a Related Entity and must be reported if it interacts with the University.