HomeMy WebLinkAbout024-SL Interactive Travel Services
In Re: Interactive Travel Services Association, : File Docket: 12-005-L
Respondent : X-ref: Order No. 024-SL
: Date Decided: 4/12/12
: Date Mailed: 4/17/12
Before: Louis W. Fryman, Chair
Donald M. McCurdy
Raquel K. Bergen
Nicholas A. Colafella
Mark Volk
This is a final adjudication of the State Ethics Commission as to the alleged
delinquency and/or deficiency of registration statement(s) and/or expense report(s)
required to be filed pursuant to Pennsylvania’s lobbying disclosure law, 65 Pa.C.S. §
13A01 et seq., hereinafter referred to as the “Lobbying Disclosure Law.”
The Investigative Division initiated these proceedings by filing with the State Ethics
Commission and serving upon Respondent Interactive Travel Services Association
(hereinafter also referred to as “ITSA” and “Respondent”) a Notice of Alleged
Noncompliance. The Respondent did not file an Answer, Appeal, or other Request for
Hearing. A Stipulation of Findings and a Consent Agreement were subsequently
submitted by the parties to the Commission for consideration. The Stipulated Findings are
set forth as the Findings in this Order. The Consent Agreement has been approved.
I.ALLEGED NONCOMPLIANCE:
That ITSA, in its capacity as a principal registered with the Pennsylvania
Department of State pursuant to the Pennsylvania Lobbying Disclosure Law (65
Pa.C.S. § 13A04), failed to timely file a quarterly expense report pursuant to 65
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Pa.C.S. § 13A05, for the third (3) quarter of 2011.
II.FINDINGS:
1. Respondent is Interactive Travel Services Association (“Respondent”) and is a
registered principal as that term is defined by the Pennsylvania Lobbying
Disclosure Law (“Lobbying Disclosure Law”), Act 134 of 2006, 65 Pa.C.S. § 13A01,
et seq.
a. Respondent initially registered as a principal with the Department of State on
April 21, 2011, for the registration period January 1, 2011, through
December 31, 2012.
b. Respondent indicated on its registration statement for the period January 1,
2011, through December 31, 2012, that it commenced lobbying on January
1, 2011.
c. In filing its principal registration, Respondent identified its registered mailing
address as:
Interactive Travel Services Association, 12-005-L
Page 2
th
529 14 St., NW
Suite 750
Washington, DC 20045
2. Respondent filed a principal registration statement with the Pennsylvania
Department of State on April 21, 2011.
a. Respondent’s registration statement indicated that lobbying commenced on
January 1, 2011.
b. Arthur B. Sackler filed the principal registration statement on behalf of
Respondent.
1. Mr. Sackler indicated that his position with Respondent was/is
Executive Director.
2. By registering with the Department of State, Respondent consented to
receive service of notices, other official mailings or process at the
address listed on the registration statement.
c. Respondent was assigned the principal registration number “P28359.”
3. The Lobbying Disclosure Law, specifically 65 Pa.C.S. § 13A04, states the following
regarding the registration of an entity as a principal:
§ 13A04. Registration
a. General rule.--
Unless excluded under section 13A06 (relating to exemption
from registration and reporting), a lobbyist, lobbying firm or a principal must
register with the department within ten days of acting in any capacity as a
lobbyist, lobbying firm or principal. Registration shall be biennial and shall
begin January 1, 2007.
b. Principals and lobbying firms.--
1. A principal or lobbying firm required to register under subsection (a)
shall file a single registration statement setting forth the following
information with the department:
i. Name.
ii. Permanent address.
iii. Daytime telephone number.
iv. E-mail address, if available.
v. Name and nature of business.
vi. Name, registration number and acronym of any affiliated
political action committees.
vii. Name and permanent business address of each individual who
will for economic consideration engage in lobbying on behalf of
the principal or lobbying firm.
viii. Registration number when available.
****
d. Amendments.--
Interactive Travel Services Association, 12-005-L
Page 3
1. If there is a change of information required for the registration
statement under subsection (b)(1) or (2) or (c), an amended
registration statement shall be filed with the department within 14
days after the change occurs.
2. When there is a change in information required for the registration
statement under subsection (b)(3), an amended registration statement
shall be filed with the department within 14 days of the end of the
year in which the change occurs.
65 Pa.C.S. § 13A04(a), (b)(1), (d).
4. In addition to the Lobbying Disclosure Law, the duly promulgated Regulations
provide further information in relation to registration periods and reporting periods:
§ 51.3. Registration periods and reporting periods.
a. Registration under section 13A04 of the act (relating to registration) shall be
biennial. The first registration period which commenced January 1, 2007,
continues through December 31, 2008. Subsequent registrations shall
commence on January 1 of each odd numbered year.
51 Pa. Code § 51.3(a).
5. Section 13A05 of the Lobbying Disclosure Law sets forth, in part, the following
requirements for the contents of quarterly reporting forms filed by principals.
§ 13A05. Reporting
(a) General rule.--
A registered principal shall, under oath or affirmation, file
quarterly expense reports with the department no later than 30 days after the
last day of the quarter.
(b) Content.--
(1) Each expense report must list the names and registration numbers
when available of all lobbyists by whom lobbying is conducted on
behalf of the principal and the general subject matter or issue being
lobbied.
(2) Each expense report shall include the total costs of all lobbying for
the period. The total shall include all office expenses, personnel
expenses, expenditures related to gifts, hospitality, transportation and
lodging to State officials or employees, and any other lobbying costs.
The total amount reported under this paragraph shall be allocated in
its entirety among the following categories:
(i) The costs for gifts, hospitality, transportation and lodging given
to or provided to State officials or employees or their
imme-diate families.
(ii) The costs for direct communication.
(iii) The costs for indirect communication.
Interactive Travel Services Association, 12-005-L
Page 4
(iv) Expenses required to be reported under this subsection shall
be allocated to one of the three categories listed under this
section and shall not be included in more than one category.
65 Pa.C.S. § 13A05(a), (b)(1)-(2).
6. In addition to the Lobbying Disclosure Law, the duly promulgated Regulations
provide further instructions in relation to registration periods and reporting periods:
§ 51.3. Registration periods and reporting periods.
(b) Reporting under section 13A05 of the act (relating to reporting) shall be
quarterly within each calendar year: for January through March; April
through June; July through September; and October through December.
Quarterly expense reports shall be filed on or before the 30th day after the
quarterly reporting period ends.
51 Pa. Code § 51.3(b).
7. As a principal, Respondent is required to file, under oath or affirmation, quarterly
expense reports with the Department of State no later than thirty (30) days after the
last day of the quarter.
8. Section 13A05 of the Lobbying Disclosure Law additionally sets forth the threshold
with regard to reporting expenditures:
(d) Thresholds for reporting.--
An expense report required under
this section shall be filed when total expenses for lobbying
exceed $2,500 for a registered principal in a reporting period.
In a reporting period in which total expenses are $2,500 or
less, a statement to that effect shall be filed.
65 Pa.C.S. § 13A05(d).
9. Section 13A03 of the Lobbying Disclosure Law defines the following terms:
“Lobbying.”
An effort to influence legislative action or administrative action
in this Commonwealth. The term includes:
(1) direct or indirect communication;
(2) office expenses; and
(3) providing any gift, hospitality, transportation or lodging to a State
official or employee for the purpose of advancing the interest of the
lobbyist or principal.
“Legislative action.”
An action taken by a State official or employee
involving the preparation, research, drafting, introduction, consideration,
modification, amendment, approval, passage, enactment, tabling,
postponement, defeat or rejection of:
(1) legislation;
(2) legislative motions;
(3) a veto by the Governor; or
Interactive Travel Services Association, 12-005-L
Page 5
(4) confirmation of appointments by the Governor or appointments to
public boards or commissions by a member of the General Assembly.
“Legislation.”
Bills, resolutions, amendments and nominations pending or
proposed in either the Senate or the House of Representatives. The term
includes any other matter which may become the subject of action by either
chamber of the General Assembly.
“Direct communication.”
An effort, whether written, oral or by any other
medium, made by a lobbyist or principal, directed to a State official or
employee, the purpose or foreseeable effect of which is to influence
legislative action or administrative action. The term may include personnel
expenses and office expenses.
65 Pa.C.S. § 13A03.
10. As a registered principal, Respondent is required to file quarterly expense reports
with the Department of State.
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a. Respondent did not file a third (3) quarter 2011 expense report by October
31, 2011.
11. The Regulations promulgated under the Lobbying Disclosure Law specifically
provide the following in relation to a delinquent filing:
§ 51.4. Delinquency.
(a) A registration statement or report required to be filed under section 13A04 or
13A05 of the act (relating to registration; and reporting) is delinquent if not
received by the Department on the date due as follows:
(1) Hard copy filings must be received by 5 p.m. in the office. For
quarterly expense reports, from 5 p.m. until 12 a.m. midnight, a hard
copy filing may be filed with the Department's designee. The filing
location and the Department's designee will be on the Department's
web site.
(2) Electronic filings may be filed until 12 a.m. midnight.
(b) A failure to timely file a registration statement, a quarterly expense report, a
separate expense report, a notice of termination or an amendment to one of
these filings constitutes a failure to register or report as required by the act;
delinquency continues until the filing is received by the Department in proper
form.
51 Pa. Code § 51.4(a)-(b).
12. [In relation] to the filing requirements of quarterly expense reports, the Regulations
read, in part:
§ 55.1. Quarterly expense reports.
(a) A quarterly expense report is required to be filed as set forth in this section
when the total lobbying expenses of a registered principal, registered
Interactive Travel Services Association, 12-005-L
Page 6
lobbying firm or registered lobbyist lobbying on the principal's behalf,
together, exceed $2,500 in a quarterly reporting period. The threshold of
$2,500 includes any economic consideration paid by a principal to a
lobbying firm or lobbyist for lobbying. Individuals exempt under section
13A06 of the act (relating to exemption from registration and reporting) need
not register or report.
(b) For a quarterly reporting period in which the total lobbying expenses of a
registered principal, registered lobbying firm or registered lobbyist lobbying
on the principal's behalf, together, are $2,500 or less, a statement to that
effect shall be filed with the Department by checking the appropriate block
on the quarterly expense report form.
****
(d) The principal shall file a quarterly expense report or statement of failure to
meet the reporting threshold on or before the 30th day after the quarterly
reporting period ends.
****
(g) A quarterly expense report of a principal required to be registered under the
act must include at least the following information:
(3) The total costs of all lobbying for the period. The total must include all
office expenses, personnel expenses, expenditures related to gifts,
hospitality, transportation and lodging to State officials or employees,
and any other lobbying costs.
(i) The total amount reported under this paragraph shall be
allocated in its entirety among the following categories:
(A) The costs for gifts, hospitality, transportation and
lodging given to or provided to State officials or
employees or their immediate families.
(B) The costs for direct communication.
(C) The costs for indirect communication.
(ii) Registrants shall use a good faith effort to allocate expenses
required to be reported under this subsection to one of the
three categories listed herein. A given expense may not be
included in more than one category. . . .
51 Pa. Code § 55.1(a), (b), (d), (g)(3)(i)-(ii).
13. By Warning Notice letter dated December 15, 2011, Respondent was served with
notice in accordance with Section 13A09 of the Lobbying Disclosure Law and
Section 63.4(1) of the Lobbying Disclosure Regulations of the specific allegations
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that Respondent failed to file a quarterly expense report for the third (3) quarter of
2011.
a. Said Warning Notice was mailed to:
Interactive Travel Services Association, 12-005-L
Page 7
Interactive Travel Services Association
th
529 14 St., NW
Suite 750
Washington, DC 20045
b. This is the same address as listed on Respondent’s principal registration
statement.
c. By submitting the principal registration statement, Respondent consented to
receipt of service of notices, other official mailings or process, at the address
listed on the registration statement. (See, Paragraph 2(b)(2) above).
d. Respondent maintains that the responsible persons with Respondent’s
association did not receive the December 15, 2011, Warning Notice.
14. Said Warning Notice letter set forth the nature of the alleged noncompliance and
the administrative and criminal penalties for failing to file.
15. Said Warning Notice letter provided Respondent an opportunity to cure the alleged
noncompliance and avoid the institution of these proceedings as to alleged
noncompliance by filing a quarterly expense report for the time period covering the
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third (3) quarter of 2011 with the Department of State within thirty (30) days from
the mailing date of the Warning Notice letter.
16. The Acting Chief of the Division of Campaign Finance and Lobbying Disclosure
conducted a search of the Department of State’s records, and, as of February 2,
rd
2012, no third (3) quarter 2011 expense report was found to have been filed with
the Department of State for Interactive Travel Services Association.
17. The Lobbying Disclosure Law provides for civil and criminal penalties for failing to
comply with the registration statement filing and quarterly expense reporting
requirements thereof. Specifically, the Lobbying Disclosure Law provides that:
a. Negligent failure to register or report, as required by the Law, is punishable
by an administrative penalty not exceeding $50.00 for each late day. 65
Pa.C.S. § 13A09(c)(1).
18. On or about March 17, 2012, the Department of State received Respondent’s
outstanding principal quarterly expense reports.
a. The Department of State received the following quarterly expense reports:
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1. Third (3) quarter 2011.
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19. The delinquent period is calculated from the date the third (3) quarter 2011
*
expense report was delinquent (October 31, 2011) until the date Petitioner filed the
Notice of [Alleged] Noncompliance with the Commission, that date being February
21, 2012, for a total of one hundred and fourteen (114) days.
*
[Because October 30, 2011, was a Sunday, the filing deadline for the third quarter 2011
expense report would have been extended to the following Commonwealth business day
(51 Pa. Code § 51.2), and the expense report would have been delinquent as of November
1, 2011; however, the parties are using the indicated date in the negotiated settlement of
Interactive Travel Services Association, 12-005-L
Page 8
this matter.]
III. DISCUSSION:
In the instant matter, the alleged noncompliance is that Respondent, as a principal
registered with the Pennsylvania Department of State (“Department of State”) pursuant to
the Lobbying Disclosure Law, failed to timely file a quarterly expense report pursuant to 65
Pa.C.S. § 13A05 for the third quarter of 2011.
The relevant provisions of the Lobbying Disclosure Law are set forth in the Fact
Findings above. Certain relevant provisions of the Lobbying Disclosure Regulations, 51
Pa. Code § 51.1 et seq., are also set forth in the Fact Findings.
As noted above, the parties have submitted a Consent Agreement and Stipulation of
Findings. The parties' Stipulated Findings are set forth above as the Findings of this
Commission. We shall now summarize the relevant facts as contained therein.
Respondent initially registered as a principal with the Department of State on April
21, 2011, for the registration period January 1, 2011, through December 31, 2012.
Respondent was assigned the principal registration number “P28359.” Respondent
indicated on its registration statement for the period January 1, 2011, through December
31, 2012, that it commenced lobbying on January 1, 2011.
Pursuant to Section 13A05 of the Lobbying Disclosure Law, 65 Pa.C.S. § 13A05,
and Section 51.3 of the Lobbying Disclosure Regulations, 51 Pa. Code § 51.3, expense
reports are filed on a quarterly basis. When a registered principal’s total expenses for
lobbying exceed $2,500 for a reporting period/quarter, the principal is required to file a
quarterly expense report with the Department of State by no later than 30 days after the
last day of such quarter. For a reporting period in which total expenses are $2,500 or less,
a statement to that effect must be filed by the principal. Thus, a registered principal must
file either a quarterly expense report or a statement of failure to meet the reporting
threshold by no later than the 30th day after each quarterly reporting period ends. 51 Pa.
Code § 55.1(d).
For the registration period January 1, 2011, through December 31, 2012,
Respondent was a registered principal as of April 21, 2011; therefore, Respondent was
required to file a quarterly expense report for the third quarter of 2011. Respondent failed
to file a quarterly expense report for the third quarter of 2011 by the filing deadline.
Failure to timely file a quarterly expense report constitutes a failure to report as
required by the Lobbying Disclosure Law, and the delinquency continues until the filing is
received by the Department of State in proper form. 51 Pa. Code § 51.4(b).
By Warning Notice letter dated December 15, 2011, Respondent was served with
notice of the alleged noncompliance in accordance with Section 63.4(1) of the Lobbying
Disclosure Regulations, 51 Pa. Code § 63.4(1). The Warning Notice letter provided
Respondent an opportunity to cure the alleged noncompliance and avoid the institution of
these proceedings by filing a quarterly expense report for the third quarter of 2011 with the
Department of State within thirty (30) days of the mailing date of the Warning Notice letter.
Respondent maintains that the responsible persons with Respondent’s association did not
receive the December 15, 2011, Warning Notice.
As of February 2, 2012, no third quarter 2011 expense report was found to have
been filed with the Department of State for Respondent .
Interactive Travel Services Association, 12-005-L
Page 9
On or about March 17, 2012, the Department of State received Respondent’s
quarterly expense report for the third quarter of 2011.
Negligent failure to register or report as required by the Lobbying Disclosure Law is
punishable by an administrative penalty of up to $50.00 for each late day. 65 Pa.C.S. §
13A09(c)(1). Per the Consent Agreement and Stipulation of Findings, the parties are in
agreement that Respondent’s expense report for the third quarter of 2011 was 114 days
delinquent.
Having highlighted the Stipulated Findings and issues before us, we shall now apply
the Lobbying Disclosure Law to determine the proper disposition of this case.
The parties' Consent Agreement sets forth a proposed resolution of the allegations
as follows:
3. The Investigative Division will recommend the following
conclusions in relation to the above deficiencies:
a. That ITSA , in its capacity as a Principal registered with
the Pennsylvania Department of State pursuant [to] the
Pennsylvania Lobbying Disclosure Law (65 Pa.C.S. §
13A04), failed to timely file a Quarterly Expense Report
rd
pursuant to 65 Pa.C.S. § 13A05, for the Third (3)
Quarter of 2011.
b. That the transgressions of the Lobbying Disclosure Law
outlined in paragraph (a) above are deemed to be
negligent in nature.
c. ITSA was deficient in filing its Third Quarter 2011
Expense Report by a total of 114 days, calculated as
set forth below:
i. On December 15, 2011, a Warning Notice
regarding the delinquent quarterly expense
report was sent to Respondent via First Class
United States Mail;
ii. Respondent did not file the outstanding
rd
Quarterly Expense Report for the third (3)
quarter 2011 within the stated cure period;
iii. Respondent filed the delinquent Quarterly
Expense Report with the Pennsylvania
rd
Department of State for the Third (3) Quarter
2011 on or about March 17, 2012;
iv. For purposes of this Consent Agreement only,
the delinquent period was calculated from the
rd
date the Third (3) Quarter 2011 Expense
Report was delinquent (October 31, 2011) until
the date Petitioner filed the Notice of [Alleged]
Noncompliance with the Commission, that date
Interactive Travel Services Association, 12-005-L
Page 10
being February 21, 2011, said period being 114
days.
4. ITSA agrees to pay an administrative penalty, by way of
certified check or money order, in the amount of $5,700.00
(114 days x $50.00 per diem) in settlement of this matter,
payable to the Commonwealth of Pennsylvania, and forwarded
to the Pennsylvania State Ethics Commission upon execution
of this agreement.
a. Said settlement payment (certified check or money
order) is to be held by the Investigative Division until
such time as the Commission accepts this Consent
Agreement and issues a Final Order. Upon issuance of
the Final Order of this matter by the Commission, the
Investigative Division will submit said settlement
payment for deposit into the Treasury of the
Commonwealth.
5. To the extent it has not already done so, ITSA agrees to file all
outstanding quarterly expense reports for the quarter(s) that
said entity was/is Registered as a Principal with the
Pennsylvania Department of State, within fifteen (15) days of
the execution of this agreement.
a. ITSA agrees to timely file all future quarterly expense
reports for the quarter(s) that said entity is/remains a
Registered Principal with the Pennsylvania Department
of State, in accord with the Pennsylvania Lobbying
Disclosure Law (65 Pa.C.S. § 13A01 et seq.) and the
Regulations of the Lobbying Disclosure Law (51 Pa.
Code § 51.1 et seq.)
6. The Investigative Division will recommend that the State Ethics
Commission take no further action in this matter; impose no
further sanctions and make no specific recommendations to
any law enforcement or other authority to take action in this
matter as to either ITSA, or any individual or representative of
ITSA. Such, however, does not prohibit the Commission from
initiating appropriate enforcement actions in the event of
Respondent’s failure to comply with this agreement or the
Commission’s Order or cooperating with any other authority
who may so choose to review this matter further.
Consent Agreement, at 1-3.
In considering the Consent Agreement and Stipulation of Findings, we agree with
the parties that Respondent as a registered principal failed to timely file a quarterly
expense report with the Department of State for the third quarter of 2011 as required by
Section 13A05 of the Lobbying Disclosure Law.
Accordingly, we hold that that Respondent as a registered principal failed to timely
file a quarterly expense report with the Department of State for the third quarter of 2011 as
required by Section 13A05 of the Lobbying Disclosure Law. We shall accept the
Interactive Travel Services Association, 12-005-L
Page 11
recommendation of the parties for a determination that the transgression(s) of the
Lobbying Disclosure Law outlined immediately above are deemed to be negligent in
nature.
The parties have agreed that Respondent was 114 days delinquent in filing its
quarterly expense report for the third quarter of 2011.
As part of the Consent Agreement, Respondent agreed to pay an administrative
penalty, by way of certified check or money order, in the amount of $5,700.00 (114 days x
$50.00 per day) in settlement of this matter, payable to the Commonwealth of
Pennsylvania and forwarded to this Commission upon execution of the Consent
Agreement. The Consent Agreement provided that said settlement payment would be held
by the Investigative Division until this Commission would accept the Consent Agreement
and issue a final Order, whereupon the Investigative Division would submit said settlement
payment for deposit into the Treasury of the Commonwealth.
To the extent it had not already done so, Respondent further agreed to file all
outstanding quarterly expense reports for the quarter(s) that Respondent had been
registered as a principal with the Department of State, within fifteen (15) days of the
execution of the Consent Agreement.
The Consent Agreement was fully executed as of March 28, 2012.
Respondent also agreed to timely file all future quarterly expense reports for the
quarter(s) that it is/remains a registered principal with the Department of State, in
accordance with the Lobbying Disclosure Law and the Lobbying Disclosure Regulations.
We determine that the Consent Agreement submitted by the parties sets forth a
proper disposition for this case, based upon our review as reflected in the above analysis
and the totality of the facts and circumstances. Accordingly, we approve the Consent
Agreement that has been submitted by the parties.
This Commission hereby levies one administrative penalty against Respondent
Interactive Travel Services Association in the amount of $5,700.00 for its delinquent
quarterly expense report for the third quarter of 2011. To the extent it has not already
done so, Respondent is directed to pay the aforesaid administrative penalty in the amount
of $5,700.00 by way of certified check or money order in the amount of $5,700.00 payable
to the Commonwealth of Pennsylvania and forwarded to this Commission by no later than
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the thirtieth (30) day after the mailing date of this adjudication and Order. Noncompliance
will result in the institution of an order enforcement action.
Per the Consent Agreement and Stipulation of Findings, Respondent filed a
quarterly expense report for the third quarter of 2011 on or about March 17, 2012.
As for Respondent’s agreement to file all outstanding and future quarterly expense
reports as set forth in the Consent Agreement, we note that failure to do so may result in
further proceedings before this Commission.
IV.CONCLUSIONS OF LAW:
1. As a principal registered with the Pennsylvania Department of State (“Department
of State”) under principal registration number “P28359,” Interactive Travel Services
Association has been subject to the reporting requirements of Section 13A05 of
Interactive Travel Services Association, 12-005-L
Page 12
Pennsylvania’s lobbying disclosure law (“Lobbying Disclosure Law”), 65 Pa.C.S. §
13A05.
2. Interactive Travel Services Association, in its capacity as a principal registered with
the Department of State, failed to timely file a quarterly expense report with the
Department of State for the third quarter of 2011 as required by Section 13A05 of
the Lobbying Disclosure Law, 65 Pa.C.S. § 13A05.
3. The transgression(s) of the Lobbying Disclosure Law outlined in paragraph 2
immediately above are deemed to be negligent in nature.
4. The prerequisite service of a warning notice in accordance with Section 63.4(1) of
the Lobbying Disclosure Regulations, 51 Pa. Code § 63.4(1), was satisfied.
5. Based upon the totality of the circumstances in this case, the imposition of an
administrative penalty in the amount of $5,700.00 (114 days x $50.00 per day) is
warranted.
In Re: Interactive Travel Services Association, : File Docket: 12-005-L
Respondent : Date Decided: 4/12/12
: Date Mailed: 4/17/12
ORDER NO. 024-SL
1. Interactive Travel Services Association, in its capacity as a principal registered with
the Pennsylvania Department of State (“Department of State”) under principal
registration number “P28359,” failed to timely file a quarterly expense report with
the Department of State for the third quarter of 2011 as required by Section 13A05
of Pennsylvania’s lobbying disclosure law (“Lobbying Disclosure Law”), 65 Pa.C.S.
§ 13A05.
2. The transgression(s) of the Lobbying Disclosure Law outlined in paragraph 1
immediately above are deemed to be negligent in nature.
3. This Commission hereby levies one administrative penalty against Interactive
Travel Services Association in the amount of $5,700.00 for its delinquent quarterly
expense report for the third quarter of 2011.
4. To the extent it has not already done so, Interactive Travel Services Association is
directed to pay the aforesaid administrative penalty in the amount of $5,700.00 by
way of certified check or money order in the amount of $5,700.00 payable to the
Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics
th
Commission by no later than the thirtieth (30) day after the mailing date of this
Order.
a. Noncompliance will result in the institution of an order enforcement action.
BY THE COMMISSION,
___________________________
Louis W. Fryman, Chair