HomeMy WebLinkAbout110-SL Pennsylvania Consumer Credit AssociationIn Re: Pennsylvania Consumer Credit Association File Docket: 15 -029 -L
Respondent, X -ref. Order No. 110 -SL
Date Decided: 1/21/16
Date Mailed: 1/28/16
Before: Nicholas A. Colafella, Chair
Mark R. Corrigan, Vice Chair
Roger Nick
Kathryn Streeter Lewis
Maria Feeley
Melanie DePalma
This is a final adjudication of the State Ethics Commission as to the alleged
delinquency and /or deficiency of expense report(s) required to be filed pursuant to
Pennsylvania's lobbying disclosure law, 65 Pa.C.S. § 13A01 et sec ., 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 Pennsylvania Consumer Credit Association
hereinafter also referred to as "Respondent ") a Notice of Alleged Noncompliance. 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.
ALLEGED NONCOMPLIANCE:
That Respondent, 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), negligently failed to timely file a quarterly expense report
pursuant to 65 Pa.C.S. § 13A05, for the second (2" ) quarter of 2015.
II. FINDINGS:
Respondent is Pennsylvania Consumer Credit Association ( "Respondent ") and is a
former 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 seg.
Respondent initially registered as a principal with the Department of State on
September 10, 2012, for the registration period January 1, 2011, through
December 31. 2012.
Respondent's registration statement indicates that lobbying commenced on
September 10, 2012.
Respondent filed a principal registration statement with the Pennsylvania
Department of State for the registration period January 1, 2015, through December
31, 2016.
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a. 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.
b. Respondent was assigned the principal registration number "P37489."
C. In filing its principal registration, Respondent identified its registered mailing
address as:
208 N. Third Street
Suite 202
Harrisburg, PA 17101
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. --
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.--
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.
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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 laterthan 30 days afterthe
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:
The costs for gifts, hospitality, transportation and lodging given
to or provided to State officials or employees or their
immediate families.
The costs for direct communication.
(iii) The costs for indirect communication.
(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:
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§ 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 afterthe
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
(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.
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"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.
a. Respondent did not file a second (2nd) quarter 2015 expense report by July
30, 2015.
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 undersection 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
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.
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(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 August 28, 2015, 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
that Respondent failed to file a quarterly expense report forthe second (2 ) quarter
of 2015.
a. Said Warning Notice was mailed to:
208 N. Third Street
Suite 202
Harrisburg, PA 17101
b. This is the same address as listed on Respondent's principal registration
statement.
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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
second (2" ) quarter of 2015 with the Department of State within thirty (30) days
from the mailing date of the Warning Notice letter.
16. The Deputy Commissioner for the Bureau of Commissions, Elections and
Legislation conducted a search of the Department of State's records, and, as of
October 28, 2015, no second (2nd) quarter 2015 expense report was found to have
been filed with the Department of State for Pennsylvania Consumer Credit
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 December 7, 2015, Respondent filed a quarterly expense report with the
Pennsylvania Department of State for the second (2 nd ) quarter of 2015.
19. For the purposes ofjhis agreement, the delinquent period is calculated from the first
date the second (2 ) quarter 2015 expense report was delinquent (July 31, 2015)
until August 24, 2015, said period being 25 days.
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, negligently failed to timely file a quarterly expense report
pursuant to 65 Pa.C.S. § 13A05 for the second quarter of 2015.
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
September 10, 2012, for the registration period January 1, 2011, through December 31,
2012. Respondent's registration statement indicated that lobbying commenced on
September 10, 2012.
Respondent registered as a principal with the Department of State for the
registration period January 1, 2015, through December 31, 2016. Respondent was
assigned the principal registration number "P37489."
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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 30th or a statement of failure to meet the reporting
threshold by no later than the 30 day after each quarterly reporting period ends. 51 Pa.
Code § 55.1(d).
The parties are in agreement that having registered for the registration period
January 1, 2015, through December 31, 2016, Respondent was required to file a quarterly
expense report for the second quarter of 2015. Respondent failed to file a quarterly
expense report for the second quarter of 2015 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 August 28, 2015, 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 second quarter of 2015 with the Department of State within thirty (30) days of
the mailing date of the Warning Notice letter.
As of October 28, 2015, no second quarter 2015 expense report was found to have
been filed with the Department of State for Respondent.
On December 7, 2015, Respondent filed a quarterly expense report with the
Department of State for the second quarter of 2015.
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 second quarter of 2015 was 25 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 Respondent, in its capacity as a Principal
registered with the Pennsylvania Department of State
pursuant [to] the Pennsylvania Lobbying Disclosure
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Law (65 Pa.C.S. § 13A04), failed to timely file a
Quarterly Expense Report pursuant to 65 Pa.C.S. §
13A05, for the second (2nd) quarter of 2015.
b. That the transgressions of the Lobbying Disclosure Law
outlined in paragraph (a) above are deemed to be
negligent in nature.
C. Respondent was deficient in filing its second (2nd)
quarter 2015 Expense Report by a total of 25 days,
calculated as set forth below:
On August 28, 2015, a Warning Notice
regarding the delinquent quarterly expense
report was sent to Respondent via First Class
United States Mail;
Respondent did not file the outstanding
Quarterly Expense Report for the second (2n )
quarter of 2015 within the stated cure period;
[iii]. For purposes of this Consent Agreement only,
the delinquent period is calculated from the first
d
date the second (2 ) quarter 2015 Expense
Report was delinquent (July 31, 2015) until the
date August 24, 2015.
Respondent agrees to pay the sum of $750.00 in settlement of
this matter to be paid as follows:
Pursuant to Section 13A09(c)(1) of the Lobbying
Disclosure Law, 65 Pa. C.S. § 13A09(c)(1), Respondent
agrees to pay an administrative penalty in the amount
of $20.00 per day during the delinquent period as
outlined above for a total amount of $500.00 (25 days x
$20.00 per diem), which shall be made payable to the
Commonwealth of Pennsylvania.
b. Respondent agrees to pay the amount of $250.00,
representing a portion of the costs incurred by the
Commission in the investigation and enforcement of this
matter, which shall be made payable to the
Pennsylvania State Ethics Commission.
C. Said settlement payments (certified check or money
order) shall be forwarded to the Pennsylvania State
Ethics Commission upon execution of this agreement,
and are 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 shall submit said settlement
payments for deposit.
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To the extent it has not already done so, Respondent agrees
to file all outstanding quarterly expense reports for the
quarter(y) 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.
Respondent agrees to timely file all future quarterly
expense reports for the quarter(y) that said entity
is /remains a Registered Principal with the Pennsylvania
Department of State, in accordance with the
Pennsylvania Lobbying Disclosure Law (65 Pa.C.S. §
13A01 et seg.) and the Regulations of the Lobbying
Disclosure Law (51 Pa. Code § 51.1 et seq.)
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 Respondent, or any individual or
representative of Respondent. 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 second quarter of 2015 as required by
Section 13A05 of the Lobbying Disclosure Law.
Accordingly, we hold that Respondent as a registered principal failed to timely file a
quarterly expense report with the Department of State for the second quarter of 2015 as
required by Section 13A05 of the Lobbying Disclosure Law. We accept the
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 25 days delinquent in filing its
quarterly expense report for the second quarter of 2015.
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 $500.00 (25 days x
$20.00 per day), payable to the Commonwealth of Pennsylvania and forwarded to this
Commission upon execution of the Consent Agreement. Respondent also agreed to pay
$250.00 to this Commission, representing a portion of the costs incurred by the
Commission in the investigation and enforcement of this matter, to be made payable to the
Pennsylvania State Ethics Commission. The Consent Agreement provided that said
settlement payments 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 payments for deposit.
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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
Pennsylvania Consumer Credit Association in the amount of $500.00 for its delinquent
quarterly expense report for the second quarter of 2015.
Additionally, per the Consent Agreement of the parties, Respondent is directed to
pay the amount of $250.00, representing a portion of the costs incurred by the Commission
in the investigation and enforcement of this matter, to be made payable to the
Pennsylvania State Ethics Commission.
To the extent it has not already done so, Respondent Pennsylvania Consumer
Credit Association is directed to pay the aforesaid administrative penalty in the amount of
$500.00 by way of certified check or money order in the amount of $500.00 payable to the
Commonwealth of Pennsylvania and forwarded to this Commission by no later than the
thirtieth (30th) day after the mailing date of this adjudication and Order.
To the extent it has not already done so, Respondent Pennsylvania Consumer
Credit Association is directed to pay the aforesaid additional amount of $250.00 by way of
certified check or money order in the amount of $250.00 payable to the Pennsylvania State
Ethics Commission and forwarded to this Commission by no later than the thirtieth (30t )
day after the mailing date of this adjudication and Order.
Noncompliance will result in the institution of an order enforcement action.
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 "P37489," Pennsylvania Consumer
Credit Association has been subject to the reporting requirements of Section 13A05
of Pennsylvania's lobbying disclosure law ( "Lobbying Disclosure Law "), 65 Pa.C.S.
§ 13A05.
2. Pennsylvania Consumer Credit Association, in its capacity as a principal registered
with the Department of State, failed to timely file a quarterly expense reportwith the
Department of State for the second quarter of 2015 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 $500.00 (25 days x $20.00 per day) and the
payment to this Commission in the amount of $250.00, representing a portion of the
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costs incurred by the Commission in the investigation and enforcement of this
matter, are warranted.
In Re: Pennsylvania Consumer Credit Association File Docket: 15 -029 -L
Respondent, Date Decided: 1/21/16
Date Mailed: 1/28/16
ORDER NO. 110 -SL
1. Pennsylvania Consumer Credit Association, in its capacity as a principal registered
with the Pennsylvania Department of State ( "Department of State ") under principal
registration number "P37489," failed to timely file a quarterly expense report with
the Department of State for the second quarter of 2015 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 Pennsylvania
Consumer Credit Association in the amount of $500.00 for its delinquent quarterly
expense report for the second quarter of 2015.
4. To the extent it has not already done so, Pennsylvania Consumer Credit
Association is directed to pay the aforesaid administrative penalty in the amount of
$500.00 by way of certified check or money order in the amount of $500.00 payable
to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State
Ethics Commission by no later than the thirtieth (30t ) day after the mailing date of
this Order.
5. To the extent it has not already done so, Pennsylvania Consumer Credit
Association is directed to pay by way of certified check or money order the
additional amount of $250.00, representing a portion of the costs incurred by the
Commission in the investigation and enforcement of this matter, payable to the
Pennsylvania State Ethics Commission and forwarded to the Pennsylvania State
Ethics Commission by no later than the thirtieth (30t ) day after the mailing date of
this Order.
Non - compliance with Paragraph 4 or 5 of this Order will result in the Commission
initiating appropriate enforcement action(s).
BY THE COMMISSION,
Nicholas A. Colafella, Chair