HomeMy WebLinkAbout87-517 NobleDavid A. Noble
Department of Community Affairs
Municipal Consulting Services Division
Room 535, Forum Building
Harrisburg, Pennsylvania 17120
STATE ETHICS COMMISSION
308 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
February 26, 1987
ADVICE OF COUNSEL
87 -517
Re: Former Public Employee; Section 3(e), Municipal Finance Consultant,
Department of Community Affairs
Dear Mr. Noble:
This responds to your letter of January 23, 1987, in which you requested
advice from the State Ethics Commission.
Issue: You ask whether the Ethics Act presents any restrictions upon your
potential employment following your termination of service with the the
Pennsylvania Department of Community Affairs.
Facts: You currently are employed by the Pennsylvania Department of Community
Affairs as a Municipal Finance Consultant in the Department's Bureau of Local
Governmental Services. You further indicate that you are a certified public
accountant and you are currently considering the possibility of developing a
private accounting practice. As such, you have requested the advice of the
State Ethics Commission relating to what, if any, restrictions are imposed
upon you by the State Ethics Act. In your position with the Pennsylvania
Department of Community Affairs, you are generally invovled in providing
municipal and governmental accounting consulting assistance to local
governments in the Commonwealth of Pennsylvania. A review of your job
description indicates that your services were generally performed in three
different areas. You were involved in the coordination of the Consultant
Division's Pension Consulting Program, directing and supervising the divisions
grant accounting technical assistance program, and providing municipal and
governmental accounting consultant services. In addition to reviewing your
job description, we have also reviewed the position specification, 1672. This
document indicates that an employee in this position provides advance
professional work relating to consultive services in the field of finance
administration. An employee in this class develops, implements and evaluates
a program of consultive services to assist local governments in increasing the
David A. Noble
February 26, 1987
Page 2
effectiveness of their financial and finance administration programs. An
important aspect of this work is the participation on multi - discipline teams
to develop programs of integrated services consultation and the testing of
newly developed integrated services to operationalize the consutant's roles
and activities. An important aspect of the work is direct continuous contact
with local officials to proivide direct consultive services designed to
increase the effectiveness of their finance administration. You also were
responsible for making recommendations on overall consulting polices and goals
for the department. As noted above, we have reviewed both your job
description and classification specification and incorporated those documents
herein by reference.
In relation to this matter you have asked four specific questions as
follows:
1. Whether you may participate in the audit of local governments as a
private CPA.
2. Whether you may perform other accounting services for local
governments.
3. Whether you may audit or perform other services with respect to grant
funds that were distributed by the Department of Community Affairs.
4. Whether you may audit or perform other accounting services for
municipalities who receive grant funds distributed by other
Commonwealth agencies.
5. Whether you may be a principle in an accounting firm involved in the
above items.
6. Whether you may be an employee of an accounting firm that does any of
the aforementioned items.
Discussion: At the outset, it must be noted that the Ethics Commission may
only address your question within the purview of the Ethics Act. The
Commission may not and will not offer advice with respect to any duties or
obligations that may be imposed by other provisions of law such as the State
Adverse Interest Act or the Governor's Code of Conduct.
As a Municipal Finance Consultant for the Pennsylvania Department of
Community Affairs, hereinafter, the Department, you are to be considered a
"public employee" within the definition of that term as set forth in the
Ethics Act and the regulations of this Commission. 65 P.S. §402; 51 Pa. Code
§1.1. This conclusion is based upon your job description, which when reviewed
on an objective basis, indicates clearly that you have the power to take or
David A. Noble
February 26, 1987
Page 3
recommend official action of a non - ministerial nature with respect to
contracting, procurement, planning, inspecting or other activities where the
economic impact is greater than de minimus on the interests of another person.
See Conner, 84 -623.
Consequently, upon termination of this employment, you would become a
"former public employee" subject to Section 3(e) of the Ethics Act. Section
3(e) of the Ethics Act provides that:
Section 3. Restricted activities.
(e) No former official or public employee shall represent
a person, with or without compensation, on any matter
before the governmental body with which he has been
associated for one year after he leaves that body.
65 P.S. 403.
Initially, to answer your request we must identify the "governmental
body" with which you were associated while working with the Then,
we must review the scope of the prohibitions associated with the concept and
term of "representation ". In this context, the Ethics Commission has
previously ruled that the "governmental body" with which an individual may be
deemed to have been associated during his tenure of public office or
employment extends to those entities where he had influence, responsibility,
supervision, or control. See Ewing, 79 -010. See also Kury vs. Commonwealth
of Pennsylvania, State Ethics Commission, 435 A.2d 940 (1981).
From the description and analysis of your duties and responsibilities and
based upon the facts outlined above, your jurisdiction, responsibility,
influence and control appears to have been exercised within the Department's
Bureau of Local Government Services, hereinafter the Bureau. Thus, the
"governmental body" with which you have been "associated" upon the termination
of your employment would be the Bureau. Therefore, within the first year
after you would leave the Department, Section 3(e) of the Ethics Act would
apply and restrict your "representation" of persons or new employers vis -a -vis
the Bureau.
The Ethics Act would not affect your ability to appear before agencies or
entities other than with respect to the the Bureau. Likewise, there is no
general limitation on the type of employment in which you may engage,
following your departure from the Department. As a result, there is no
general limitation on your becomming a principle or becomming associated with
any particular CPA firm even though those firms may perform work for local
governments that have had relationships with the Department or with the
Commonwealth generally. We do note, however, that the conflicts of interest
law is primarily concerned with financial conflicts and violations of the
public trust. The intent of the law generally is that during the term of a
David A. Noble
February 26, 1987
Page 4
person's public employment he must act consistently with the public trust and
upon departure from the public sector, that individual should not be allowed
to utilize his association with the public sector, officials or employees to
secure for himself or a new employer, treatment or benefits that may be
obtainable only because of his association with his former public employer.
See Anderson, 83 -014; Zwikl, 85 -004.
In respect to the one year representation restriction the Ethics
Commission has promulgated regulations to define "representation" as follows:
Section 1.1. Definitions.
Representation - -- Any act on behalf of any person
including but not limited to the following activities:
personal appearances, negotiating contracts, lobbying, and
submitting bid or contract proposals which are signed by
or contain the name of the former public official or
public employe. 51 Pa. Code 1.1.
The Commission, in its opinions, has also interpreted the term
"representation" as used in Section 3(e) of the Ethics Act to prohibit:
1. Personal appearances before the governmental body or bodies with
which you have been associated, (that is the Bureau), including, but not
limited to, negotiations or renegotiations on contracts with the (2);
2. Attempts to influence the Bureau;
3. Participating in any matters before the Bureau over which you had
supervision, direct involvement, or responsibility while employed by the
Department;
4. Lobbying, that is representing the interests of any person or
employer before the Bureau in relation to legislation, regulations, etc. See
Russell, 80 -048 and Seltzer, 80 -044.
The Commission has also held that preparing and signing a proposal,
document or bid, or listing your name as the person who will provide technical
assistance on such proposal, document, or bid, if submitted to or reviewed by
the Bureau, constitutes an attempt to influence your former governmental body.
See Kilareski, 80 -054. Therefore, within the first year after you leave the
Department, you should not engage in the type of activity outlined above.
David A. Noble
February 26, 1987
Page 5
You may, assist in the preparation of any documents presented to the
Bureau so long as you are not identified as the preparer. You may also
counsel any person regarding that person's appearance before the Bureau. Once
again, however, your activity in this respect should not be revealed to the
Bureau. Of course, any ban under the Ethics Act would not prohibit or
preclude you from making general informational inquiries of the Bureau to
secure information which is available to the general public. See Cutt,
79 -023. This, of course, must not be done in an effort to indirectly
influence these entities or to otherwise make known to the Bureau your
representation of, or work for your new employer. Finally, the Commission has
concluded that if you are administering an existing contract as opposed to
negotiating or renegotiating a contract, your activities would not be
prohibited by the Ethics Act. See Dalton, 80 -056 and Beaser, 81 -538.
In addition, it appears as though you did not participate, while an
employee of the Department, in any of the grant approval or distribution
activities of that agency. As such, there appears to be no reason why you may
not participate in auditing local governments and providing other accounting
services for local governments.
Additionally, we note that Section 403(b) of the State Ethics Act would
prohibit any public employee or public official from accepting a position of
employment if said position has been offered based upon the understanding that
the official conduct of the employee or official, while working for his former
governmental body, was influenced by such offer. See 65 P.S. §403(b).
Conclusion: As a Municipal Finance Consultant, you are to be considered a
"public employee" as defined in the Ethics Act. Upon termination of your
service with the Pennsylvania Department of Community Affairs, you would
become a "former public employee" subject to the restrictions imposed by
Section 3(e) of the Ethics Act. As such, your conduct should conform to the
requirements of the Ethics Act as outlined above. Your governmental body for
the purpose of the one year representation restriction is the Bureau of Local
Government Services.
Further, should you terminate your employment or service, as outlined
above, you are reminded that the Ethics Act also requires you to file a
Statement of Financial Interests for the year following your termination of
service.
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.
David A. Noble
February 26, 1987
Page 6
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 formal
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.
Si
oh n J ontino
A 'ng General Counsel