HomeMy WebLinkAbout85-547 McCulloughMr. Samuel A. McCullough
President and Chief Executive Officer
Meridian Bancorp, Inc.
35 N. 6th Street
P.O. Box 1102
Reading, PA 19608
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
May 28, 1985
ADVICE OF COUNSEL
85 -547
Re: Conflict of Interest, Bank Corporation, Governmental Body, Participation
in Limited Partnership
Dear Mr. McCullough:
This responds to your request for advice from the State Ethics Commission
dated May 17, 1985.
Issue: Whether, within the purview of the State Ethics Act, a governmental
body may invest in a limited partnership where the chariman of that body is
also a chief executive officer in a banking institution that is also a member
of the partnership.
Facts: You are the chairman of the Public School Employee's Retirement Board.
You are also the chief executive officer of Meridian Bancorp, Inc. The Public
School Employee's Retirement' Board, hereinafter the Board, consists of fifteen
(15) members and exercises broad powers regarding the control and management
of retirement funds and accounts of public school employees._ 24 Pa. C.S.A.
§8501; §8521.
On February 27, 1985 Meridian Bancorp committed to invest $1 million in
the NEPA Venture Fund. NEPA is a Pennsylvania limited partnership formed to
provide venture capital to new and growing technology- oriented companies whose
principal business operations are located in the Mid - Atlantic region of the
United States, particularly northeastern Pennsylvania.
Mr. Samuel McCullough
May 28, 1985
Page 2
You have indicated that the Board has also been actively considering
venture capital investments. As a result, the Public School Employee's
Retirement System and representatives of NEPA have discussed the possibility
of the system investing in the NEPA fund. You have also i ndi catd that based
upon the system's investment coordinator's recommendation, NEPA, along with
several other venture capital firms, have been interviewed as potential
investment possibilities. You do not indicate, and we will assume that you
did not participate in such interviews and /or recommendations.
The Board held an executive session on April 26, 1985 at which time you
fully disclosed to the Board the facts relating to the Meridian investment
with NEPA. You informed the Board that you would not vote on any Board motion
regarding the initiation of this investment.
A regularly scheduled public meeting of the Public School Employee's
Retirement Board was also held on April 26, 1985. At that meeting a rnotion
was made that the Board invest $1 million in the NEPA fund. The motion was
seconded by another Board member and passed unanimously. You abstained from
voting on that motion.
The result is that both the Board and Meridian Bancorp, Inc. will be
limited patners in NEPA, each entity investing $1 million with the general
partner. It is important to note that the general partner has almost complete
control and discretion over the invested funds. It should also be noted that
the Board will not be transferring funds to Meridian Bancorp, nor will
Meridian be providing services to the Board or otherwise be employed by the
Board.
You have requested the advice of the State Ethics Commission regarding
any restrictions that may be applicable to the above situation within the
purview of the State Ethics Act.
Discussion: At the outset, it must be noted that the Ethics Commission may
only address your question within the parameters of the Ethics Act. The
Commission will not offer advice with respect to any duties, obligations or
restrictions that may be imposed by other provisions of law such as the State
Adverse Interest Act, the Governors Code of Conduct or the Public School
Employee's Retirement Code. a
As a member and chairman of the Board, you are a public official as that
term is defined in the State Ethics Act. 65 P.S. §402; Hershey, 80 -038;
Cavill, 79 -041. As such, your conduct must conform to the requirements of the
Act.
Mr. Samuel McCullough
May 28, 1985
Page 3
Generally, the Ethics Act provides that:
Section 3. Restricted activities.
(a) No public official or public employee shall use his
public office or any confidential information received
through his holding public office to obtain financial gain
other than compensation provided by law for himself, a
member of his immediate family, or a business with which
he is associated. 65 P.S. 403(a).
Within this provision you, as a public official, would be prohibited from
taking any action that may be financially beneficial to yourself or a business
with which you are associated. Thus, if the Board's participation in the
limited partnership could be in any way financially beneficial to Meridian,
you may not participate in any Board action regarding the investment. We also
note that pursuant to Section 3(a) you may not use any confidential
information obtained as a public official for similar purposes. Thus, if in
your position with the Board you become privy to confidential information
regarding the Boards investment in the partnership which may be of interest to
or beneficial to Meridian, you may not within the above provisions, use such
information to benefit Meridian.
You have indicated that to date you have not participated in any action
relating to this investment by the Board. As such, you have acted in
accordance with the Ethics Act. We note that Meridian will not be employed by
the general partner in any respect regarding this investment. This is an
important factor and in the event that this situation should chapge, it may be
advisable to seek the further advice of the Commission.
In addition to the foregoing, the Ethics Act provides that:
Section 3. Restricted activities.
(c) No public official or public employee or a member of
his immediate family or any business in which the person
or a member of the person's immediate family is a
director, officer, owner or holder of stock exceeding 5%
of the equity at fair market value of the business shall
enter into any contract valued at $500 or more with a
governmental body unless the contract has been awarded
through an open and public process, including prior public
notice and subsequent public disclosure of all proposals
considered and contracts awarded. Any contract made in
violation of this subsection shall be voidable by a court
of competent jurisdiction if the suit is commenced within
90 days of making of the contract. 65 P.S. 403(c).
Mr. Samuel McCullough
May 28, 1985
Page 4
While it does not appear that the Board will be directly contracting with
Meridian, the business in which you are an officer, the Board, your
governmental body, will technical ly be entering into a partnership arrangement
with the corporation. This will be transacted we assume through the execution
of a written investment agreement. Because of this, we believe that Section
3(c) of the Act is applicable.
It should be emphasized, that even though Section 3(c) of the Ethics Act
presents no absolute prohibition to the contract between NEPA and the Board
certain requirements as to the open an public process must be met. In its
opinions in Howard, 79 -044 and Fields, 82 -006, the Commission stated that an
open and pub i'r c process in the traditional contract situation is met by
applying the following standards:
1. prior public notice of the employment or contracting possibility;
2. sufficient time for a reasonable and prudent competitor /applicant
to be able to prepare and present an application or proposal;
3. public disclosure of all applications or proposals considered; and
4. public disclosure of the terms of the final contract, (in this case,
the investment). See also Cantor, 82 -004.
In determining whether the requirements of Section 3(c) of the Ethics Act
have been met, the Commission has adopted a "reasonableness test" which means
that reasonable and prudent competitors of NEPA should be provided a
sufficient time within which to submit their proposals and, of course, should
have had prior notice of the opportunity to secure such a contract.
Since you indicate that the Board has reviewed other investment sources
and proposals in relation to this matter, we believe that this aspect of the
open and public process requirements of the Ethics Act have been satisfied.
It also suggested that conditions 3 and 4 above should be met. Such public
disclosure of the Boards procedure will insure compliance with the Ethics Act.
Finally, we note that the Ethics Commission may address other areas of
possible conflict. 65 P.S. §403(d). .Generally, the Ethics Act is intended to
insure that the financial interests of a public official,,are pot in conflict
with the public trust and do not lend to the appearance of such a conflict.
Such a conflict exists when an individual serves or attempts to serve
competing or adverse interets. Alfano, 80 -007.
Mr. Samuel McCullough
May 28, 1985
Page 5
Here, such an appearance could develop if you were to participate in the
Boards decisions regarding the partnership in which both Meridian and the
Board are involved. Such an appearance may be avoided by abstaining
canpletely from participation in any matter relating to the Boards decisions
regarding this investment both now and in the future. In this way,, you would
avoid both a conflict and the appearance of such. See Matson, No. 214.
Conclusion: Under the facts as outlined herein, there would be no Ethics Act
prohibition regarding the Board's proposed action. As a public official, you
must conform your activities in relation to this matter to the requirements of
the Act as set forth above.
Pursuant to Section 7(9)(ii), this Advice is a complete defense in any
enforcement proceeding initiated by the Commission, and evidence of good faith
conduct in any other civil or criminal proceeding, providing the requestor has
disclosed truthfully all the material facts and committed the acts complained
of in reliance on the Advice given.
This letter is a public record and will be made available as such.
Finally, if you disagree with this Advice or if you have any reason to
challenge same, you may request that the full Commission review this Advice. A
personal appearance before the Commission will be scheduled and a foimal
Opinion from the Commission will be issued. Any such appeal must be made, in
writing, to the Commission within 15 days of service of this Advice pursuant
to 51 Pa. Code 2.12.
JJC /sfb
Sincerely,
John J. ino
Gen- -. Counsel