North Carolina requires covered state officials to disclose significant financial interests annually but imposes no comparable uniform requirement on county and municipal elected officials. Instead, local governments must adopt ethics codes while retaining discretion over financial disclosure requirements. The resulting inconsistency is apparent in Mecklenburg and Forsyth Counties. Mecklenburg requires certain disclosures but uses a less stringent reporting threshold than the State, while Forsyth’s ethics code contains no general annual financial disclosure requirement. North Carolina should establish a uniform minimum disclosure standard for local elected officials to promote transparency and public accountability.
- North Carolina’s State Financial Disclosure Framework
North Carolina’s State Government Ethics Act seeks to prevent conflicts of interest and the improper use of public office for private benefit.[1] Under § 138A-22, covered officials generally must file statements of economic interest upon entering office and annually thereafter, by April 15.[2]
Section 138A-24 requires disclosure of specified financial interests, including sources of income, real estate, business ownership, gifts, and certain assets and liabilities.[3] Particularly relevant is § 138A-24(a)(2), which requires disclosure of specified assets valued at $10,000 or more, including qualifying interests in publicly traded companies.[4] Consequently, an official holding $25,000 in a publicly traded company’s stock generally must identify that investment, even if it represents only a small percentage of the company’s outstanding shares.[5]
These disclosures do not establish wrongdoing. Rather, they provide information that allows the public to identify potential conflicts and evaluate officials’ financial interests. By making these interests publicly accessible, financial disclosure promotes transparency and enables voters to hold officials accountable for potential conflicts before misconduct occurs.
- The Gap in Local Government Ethics Requirements
North Carolina imposes different requirements on local governments. Under N.C. Gen. Stat. §§ 153A-53 and 160A-86, county and municipal governing boards must adopt ethics codes addressing integrity, avoidance of impropriety, compliance with applicable laws, and openness in government.[6] Neither statute, however, establishes a statewide annual financial disclosure requirement comparable to § 138A-24.
Local officials remain subject to laws restricting conflicts of interest. Section 14-234 regulates certain financial interests in public contracts, while § 14-234.1 prohibits specified uses of confidential governmental information for financial benefit.[7] Although these provisions prohibit certain forms of misconduct, they do not require the routine public disclosure of an official’s financial interests. Consequently, the information available to voters depends substantially on the requirements adopted by individual local governments.
- Mecklenburg and Forsyth Counties show an Uneven Disclosure System
Mecklenburg County has adopted affirmative disclosure requirements. Section 7 of its Code of Ethics requires commissioners and certain senior officials to disclose specified business interests, employment relationships, and nonprofit affiliations.[8] These statements are publicly available, although officials need not resubmit them when their information remains unchanged.[9]
Nevertheless, Mecklenburg’s requirements are less stringent than the state framework. Its Code defines a reportable “Interest” through several categories, including ownership of at least 5% of a business, certain payments exceeding $5,000, and securities representing more than 25% of an official’s aggregate net worth.[10]
These thresholds differ significantly from the State’s $10,000 asset-disclosure requirement. Consider an official owning $25,000 in a publicly traded company without owning 5% of its total shares outstanding. Assuming the investment represents less than 25% of the official’s net worth and no other reporting category applies, it might not require disclosure under Mecklenburg’s Code, despite being reportable under § 138A-24(a)(2).
Forsyth County provides an even sharper contrast. In December 2024, its Board of Commissioners adopted a revised Code of Ethics through Resolution No. 2024-1469.[11] Canon Six directs commissioners to avoid financial dealings that interfere with official duties and manage their interests to minimize conflicts.[12] However, the Code does not establish a general annual requirement to disclose financial holdings.
Thus, while both counties have adopted ethics codes, their disclosure obligations differ considerably. Even Mecklenburg’s more detailed requirements may leave significant financial interests outside public view.
- Why Financial Disclosure Matters
Consider a county commissioner who owns $25,000 in a publicly traded utility company. The company seeks a substantial county contract, and the commissioner participates in the board’s consideration of the proposal. After the contract is awarded, the company’s stock appreciates, increasing the value of the commissioner’s investment.
Under the state framework, this investment would generally require disclosure.[13] Under Mecklenburg’s Code, however, it could remain undisclosed if the official’s ownership and financial circumstances fall below the applicable thresholds.[14] Forsyth’s Code would not independently require an annual statement identifying the investment.[15]
Although the commissioner’s participation would remain subject to applicable voting and conflict-of-interest laws, this hypothetical illustrates why financial disclosure serves a distinct purpose.[16] As McQuillin’s The Law of Municipal Corporations explains, legislatures have adopted financial disclosure requirements to address conflicts between public responsibilities and private financial gain.[17] Such requirements allow potential conflicts to be identified even when no misconduct has been established.
The value of public disclosure is illustrated by recent reporting on North Carolina’s congressional delegation.[18] In July 2026, WRAL News analyzed federal financial disclosures and reported that three North Carolina representatives may have earned six-figure profits from stock trading in 2025.[19] Based on the reported financial ranges, Representative Tim Moore may have earned as much as $342,000, Representative Mark Harris as much as $159,200, and Representative Virginia Foxx as much as $107,000.[20] Although these figures represent potential profits rather than verified earnings, and the disclosures concerned federal officials, the reporting demonstrates how publicly available financial information enables journalists and voters to scrutinize elected officials’ investments and evaluate potential conflicts of interest.
Local officials make consequential decisions involving public contracts, infrastructure, land use, and development incentives. Requiring disclosure of significant financial interests would extend similar transparency benefits to local voters, enabling them to identify potential conflicts, evaluate officials’ financial relationships, and hold their representatives accountable before controversies arise.
- A Uniform Minimum Disclosure Requirement
North Carolina should establish a statewide minimum annual financial disclosure requirement for county and municipal elected officials, modeled on relevant provisions of § 138A-24.
Such a requirement should cover significant business ownership, qualifying stock holdings, outside income, relevant real estate, and financial relationships with entities conducting business with local governments. A dollar-value threshold would capture investments that are financially meaningful to an official even when they represent a small ownership percentage of a corporation.
Critics may argue that additional disclosure requirements would impose unnecessary administrative and financial burdens on local governments, particularly smaller counties and municipalities with limited resources. Unlike the State, these governments may lack the personnel and funding necessary to administer extensive financial reporting systems. Requiring each locality to develop and maintain its own disclosure process could therefore divert resources from other governmental responsibilities.
These concerns, however, do not justify abandoning a statewide minimum. Rather than requiring individual local governments to create separate reporting systems, North Carolina could provide a standardized disclosure form and centralized electronic filing system. Although such a system would impose administrative costs on the State, it could reduce the need for counties and municipalities to develop and maintain separate reporting processes. Officials should file upon assuming office and annually thereafter, while reasonable reporting thresholds and privacy protections would limit unnecessary disclosures. Local governments would remain free to adopt stricter requirements.
This proposal would complement, rather than replace, existing conflict-of-interest laws. Those laws regulate improper conduct, while financial disclosure allows voters to identify potential conflicts before misconduct is alleged.
Conclusion
North Carolina recognizes the importance of financial transparency for covered state officials but leaves local elected officials subject to inconsistent disclosure requirements. Mecklenburg’s narrower thresholds and Forsyth’s absence of a general annual filing requirement demonstrate the limitations of relying on local discretion alone.
Although a statewide disclosure requirement would create additional administrative responsibilities, a standardized, state-administered system could reduce the burden on local governments while providing voters with meaningful financial information. Financial disclosure cannot prevent every conflict of interest, but it can strengthen public accountability by making potential conflicts visible before misconduct is alleged. Public access to that information should not depend on the county in which an official serves.
[1] N.C. Gen. Stat. § 138A-2 (2025).
[2] N.C. Gen. Stat. § 138A-22 (2025).
[3] N.C. Gen. Stat. § 138A-24 (2025).
[4] N.C. Gen. Stat. § 138A-24(a)(2) (2025).
[5] Id.
[6] N.C. Gen. Stat. § 153A-53 (2025); id. § 160A-86.
[7] N.C. Gen. Stat. § 14-234 (2025); id. § 14-234.1.
[8] Mecklenburg Cnty., N.C., Bd. of Cnty. Comm’rs Code of Ethics § 7 (2026), https://bocc.mecknc.gov/Code-of-Ethics.
[9] Id.
[10] Id. Definitions “Interest”.
[11] Forsyth Cnty., N.C., Res. 2024-1469, Resolution Adopting a Revised Code of Ethics to Guide Actions by Members of the Forsyth County Board of Commissioners in the Performance of the Members’ Official Duties (Dec. 12, 2024).
[12] Id. Canon 6.
[13] N.C. Gen. Stat. § 138A-24(a)(2).
[14] Mecklenburg Cnty. Code of Ethics § 7.
[15] Forsyth Cnty., N.C., Res. 2024-1469, Canon 6.
[16] N.C. Gen. Stat. § 153A-44 (2025); Mecklenburg Cnty. Code of Ethics § 6 (addressing when commissioners may be excused from voting on matters involving their own financial interests).
[17] 3 Eugene McQuillin, The Law of Municipal Corporations § 12:173.24 (3d ed., Westlaw June 2026 update).
[18] Will Doran, Should Congress Trade Stocks? Where NC’s Politicians Stand, and How Much They Trade, WRAL (July 23, 2026), https://www.wral.com/news/nccapitol/congress-stock-trade-ban-restrict-nc-house-vote-july-2026/.
[19] Id.
[20] Id.
