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STATE ETHICS COMMISSION
FINANCE BUILDING
613 NORTH STREET, ROOM 309
HARRISBURG, PA 17120 -0400
In Re: American Bible Society,
Respondent
File Docket:
17-007 -L
X -ref: Order No.
129 -SL
Date Decided:
211118
Date Mailed:
219118
Before: Nicholas A. Colafella, Chair
Mark R. Corrigan, Vice Chair
Roger Nick
Melanie DePalma
Monique Myatt Galloway
Michael A. Schwartz
Shelley Y. Simms
FACSIMILE: 717- 787 -0806
WEBSITE: www.ethics.oa.aov
This is a final adjudication of the State Ethics Commission as to the alleged
delinquency and/or deficiency of expense reports) required to be filed pursuant to
Pennsylvania's lobbying disclosure law, 65 Pa.C.S. §§ 13A01 et seg., 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 American Bible Society (hereinafter also
referred to as "Respondent ") a Notice of Alleged Noncompliance. Respondent did notfile
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.
Effective January 1, 2017, the Pennsylvania Department of State ( "Department
of State ") increased the thresholds under 65 Pa.C.S. § 13A06 for registration under
65 Pa.C.S. § 13A04 and the threshold for reporting under 65 Pa.C.S. § 13A05(d) from
$2,500.00 to $3,000.00.
1. ALLEGED NONCOMPLIANCE:
That Respondent, in its capacity as a principal registered with the Department of
State pursuant to the 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 (2nd) quarter of 2017.
II. FINDINGS:
1. Respondent is American Bible Society ( "Respondent ") and is a registered principal
as that term is defined by the Lobbying Disclosure Law, Act 134 of 2006, 65
Pa.C.S. § 13A01, et s, etc..
a. Respondent initially registered as a principal with the Department of State on
June 12, 2017, for the registration period January 1, 2017, through
December 31, 2018.
b. Respondent's registration statement indicates that lobbying commenced on
.tune 1, 2017.
American Bible Societ , 17 -007 -L
Page
C, 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.
d. Respondent was assigned the principal registration number "P45864."
e. In filing its principal registration, Respondent identified its registered mailing
address as:
101 N. Independence Mail
Philadelphia, PA 19106
2. 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 reciistration 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
Mme 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. --
If there is a change of information required for the registration
statement under subsection %(1) or �2) or (c), an amended
registration statement shall be edd with he 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.
American Bible Society, 17 -007 -L
Page
65 Pa.C.S. § 13A04(a), (b)(1), (d).
3. 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).
4. 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
immediate families.
(ii) 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).
5. 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.
American Bible_Socie , 17 -007 -L
age 4
(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).
As a registered principal, Respondent is required to file with the Department of
tate either a quarterly expense report or a statement of failure to meet the
reporting threshold for each quarter it has been registered as a principal, by no later
than the 30th day after each nuarterly reporting period has ended. 65 Pa.C.S. §
13A05(a), (d); 51 Pa. Code § 5.1 (d)].
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 lobbyingg
exceed [$3,000] for a registered principal in a reporting period.
In a reporting period in which total expenses are [$3,000] or
less, a statement to that effect shall be filed.
65 Pa.C.S. § 13A05(d).
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
public boards or commissions
by the Governor or appointments to
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
American Bible Society, 17 -007 -L
Page 5
legislative action or administrative action. The term may include personnel
expenses and office expenses.
65 Pa.C.S. § 13A03.
9. Vtate s a registered principal, Respondent is required to file with the Department of
either a quarterly expense report or a statement of failure to meet the
reporting threshold for each quarter it has been registered as a principal, by no later
than the 30th day after each quarterly reporting period has ended. 65 Pa.C.S. §
13A05(a), (d); 51 Pa. Code § 55.1(d)],
a. Respondent did not file a second (2"d) quarter 2017 expense report by [the
filing deadline. Because July 30, 2017, was a Sunday, the filing deadline
was Monday, July 31, 2017, and the first date the second quarter of 2017
expense report was delinquent was August 1, 2017. See, 51 Pa. Code §
51.2.]
10. 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).
11. [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 [$3,000] in a quarterly reporting period. The threshold of
[f$3,000] 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.
American Bible Society, 17 -007 -L
age
(b) For a quarterly reporting period in which the total lobbying expenses of a
registered principal, registered lobbyin firm or registered lobbyist lobbying
on the principal's behalf, together, are $3,0001 or less, a statement to that
effect shall be filed with the Department y 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).
12. By Warning Notice letter dated August 24, 2017, 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 for the second (2"d) quarter
of 2017.
a. Said Warning Notice was mailed to:
American Bible Society
101 N. Independence Mall
Philadelphia, PA 19106
b. This is the same address as listed on Respondent's principal registration
statement.
American Bible Society, 17 -007 -L
gage
13. Said Warning Notice letter set forth the nature of the alleged noncompliance and
the administrative and criminal penalties for failing to file.
14. Said Warning Notice letter provided Respondent an opportunityy. 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 penod covering the
second (2 "d) quarter of 2017 with the Department of State within thirty (30) days
from the mailing date of the Warning Notice letter.
15. The Chief of the Division of Campaign Finance and Lobbying Disclosure for the
Commonwealth of Pennsylvania Department of State conducted a search of the
Department of State's records, and, as of October 5, 2017, no second (2nd) quarter
2017 expense report was found to have been filed with the Department of State for
Respondent.
16. The Lobbying Disclosure Law provides for civil and criminal penalties for failingg to
comply with the registration statement filing and quarterly expense re orting
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).
17. The delinquent period is calculated from the first date the second (2nd) quarter 2017
expense report was delinquent (July 31, 2017) until, for the purposes of this
settlement, October 11, 2017, said period being 73 days.
*[sic]. [Because July 30, 2017, was a Sunday, the filing deadline was Monday, July
31, 2017, and the first date the second quarter of 2017 expense report was
delinquent was August 1, 2017. See, 51 Pa. Code § 51.2. However, we shall
accept the parties' stipulation as to the number of days the expense report was
delinquent, specifically, 73.]
18. As of the date of [the parties' Consent Agreement, December 14, 2017],
Respondent has filed all outstanding quarterly expense reports for the quarters that
said entity was registered as a principal with the Pennsylvania Department of State
.... The reports indicate that Respondent has engaged in no lob
expenses. Respondent simultaneously terminated its regi bying or lobbying
stration with the
Pennsylvania Department of State pursuant to the Pennsylvania Lobbying
Disclosure Law (65 Pa.C.S. § 13A04).
Ill. 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 2017.
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 June
12, 2017, for the registration period January 1, 2017, through December 31, 2018.
Respondent's registration statement indicated that lobbying commenced on June 1, 2017.
Respondent was assigned the principal registration number "P45864."
American Bible Society, 17 -007 -L
age
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 $3,000 far 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 $3,000 or less,
a statement to fihat 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
#hreshold by no later than the 30th day after each quarterly reporting period ends. 51 Pa.
Code § 55.1 (d).
Having registered on June 12, 2017, for the registration period January 1, 2017,
through December 31, 2018, Respondent was required to file a quarterly expense report
for the second quarter of 2017. Respondent failed uo file a quarterly expense report for the
second quarter of 2017 by the fling 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 24, 2017, 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 Warn ing 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 2017 with the Department of State within thirty (30) days of
the mailing date of the Warning Notice letter.
As of October 5, 2017, no second quarter 2017 expense report was found to have
been filed with the Department of State for Respondent.
2017. Respondent has now submitted a quarterly expense report for the second quarter of
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 2017 was 73 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:
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), failed to timely file a Quarterly
Expense Report pursuant to 65 Pa. S. § 13A05, for
American Bible Society, 17 -007 -L
age
the second (2nd) quarter of 2017.
b. Respondent reports that Registration was submitted by
an employee who was not authorized to Register on
behalf of Respondent, that said employee negligently
failed to communicate the Registration to Respondent's
officers, and that said employee failed to file Quarterly
Expense Reports when due;
C. That the transgression(s) of the Lobbying Disclosure
Law outlined in paragraph (a) above [is /are] deemed to
be negligent in nature.
d. Respondent was deficient in filing its second (2nd)
quarter of 2017 Expense Report by a total of 73 days,
calculated as set forth below:
i. On August 24, 2017, a Warning Notice regarding
the delinquent quarterly expense report was sent
to Respondent via First Class Unites States Mail;
ii. Respondent did not file the outstandin
Quarterly Expense Report for the second (2a)
quarter of 2017 within the stated cure period;
iii. For purposes of this Consent Agreement only,
the delinquent period is calculated from the first
date the second (2nd) quarter of 2017 Expense
Report was delinquent (July 31, 2017)* until
October 11, 2017, said period being 73 days.
*[sic]. �ecause July 30, 2017, was a Sunday, the filing deadline was
onday, July 31, 2017, and the first date the second quarter of
2017 expense report was delinquent was August 1, 2017.
See, 51 Pa. Code § 51.2. However, we shall accept the
parties' stipulation as to the number of days the expense report
was delinquent, specifically, 73.]
Respondent agrees to pay the sum of $2,440.00 in settlement
of this matter.
Pursuant to Section 13A09(c)(1) of the Lobbying
Disclosure Law, 65 Pa.C.S. § 13A0%c)(1), Respondent
agrees to pay an administrative penallty in the amount
of $30.00 per day during the delinquent period as
outlined above for a total amount of $2,190.00 (73 days
x $30.00 per diem) , which shall be made payable to the
Commonwealth of Pennsylvania within thirty (30) days
of the final order in this matter.
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 within thirty (30)
days of the final order in this matter.
American Side Socieiy, 17 -007 -L
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As of the date of this agreement, Respondent has filed all
outstanding quarterly expense reports for the quarters that said
entity was Registered as a Principal with the Pennsylvania
Department of State as of the date of this agreement. The
reports indicate that Respondent has engaged in no lobbying
or lobbying expenses. Respondent simultaneously terminated
its Registration with the Pennsylvania Department of State
pursuant to the Pennsylvania Lobbying Disclosure Law (65
PaC.S. § 13A04).
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 initiatin 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 -2.
In considering the Consent Agreement and Stipulation of Findings, we agree with
the parties that Respondent as a registered rincipal faded to timely file a quarterly
expense report with the Department of State for Fhe second quarter of 2017 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 2017 as
required by Section 13A05 of the Lobbying Disclosure Law. We accept the
recommendation of the parties for a determination that the transgression of the Lobbying
Disclosure Law outlined immediately above is deemed to be negligent in nature.
The parties have agreed that Respondent was 73 days delinquent in filing its
quarterly expense report for the second quarter of 2017.
As part of the Consent Agreement, Respondent agreed to pay an administrative
penalty in the amount of $2,190.00 (73 days x $30.00 per day), ppayable to the
Commonwealth of Pennsylvania and forwarded to this Commission within thirt days of the
issuance of the final Order in this matter. 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 and forwarded to this Commission within thirty days of the
issuance of the final Order in this matter.
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
American Bible Society in the amount of $2,190.00 for its delinquent quarterly expense
report for the second quarter of 2017.
American Bible Society, 17- 007 -L.
Pa—ge–T
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 American Bible Society is
directed to pay the aforesaid administrative penalty in the amount of $2,190.00 to be made
payable to the Commonwealth of Pennsylvania and forwarded to this Commission by no
later than the thirtieth (30#'') day after the mailing date of this adjudication and Order.
To the extent it has not already done so, Respondent American Bible Society is
directed to pay the aforesaid additional amount of $250.00 to be made payable to the
Pennsylvania State Ethics Commission and forwarded to this Commission by no laterthan
the thirtieth (30th) day after the mailing date of this adjudication and Order.
Noncompliance will result in the institution of an order enforcement action.
IV. CONCLUSIONS OF LAW:
1. As a principal registered with the Pennsylvania Department of State ( "Department of
State ") under principal registration number "P45864," American Bible Society has
been subject to the reporting requirements of Section 13A05 of Pennsylvania's
lobbying disclosure law ( "Lo) bying Disclosure Law "), 65 Pa.C.S. § 13A05.
2. American Bible Society, 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 second quarter of 2017 as required by Section 13A05 of the Lobbying
Disclosure Law, 65 Pa.C.S. § 13A05.
3. The transgression of the Lobbying Disclosure Law outlined in paragraph 2
immediately above is 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.
Based upon the totality of the circumstances in this case, the imposition of an
administrative penalty in the amount of $2,190.00 (73 days x $30.00 per day) and
the payment to this Commission in the amount of $250.00, representing a portion of
the costs incurred by the Commission in the investigation and enforcement of this
matter, are warranted.
In Re: American Bible Society, File Docket: 17 -007 -L
Respondent, Date Decided: 211118
Date Mailed: 219118
ORDER NO. 129 -SL
1. American Bible Society, in its capacity as a principal registered with the
Pennsylvania Department of State ( "Department of State ") under principal
registration number "P45864," failed to timely file a quarterly expense report with the
Department of State for the second quarter of 2097 as required by Section 13A05 of
Pennsylvania's lobbying disclosure law ( "Lobbying Disclosure Law "), 65 Pa.C.S. §
13A05.
2. The transgression of the Lobbying Disclosure Law outlined in paragraph 1
immediately above is deemed to be negligent in nature.
3. This Commission hereby levies one administrative penalty against American Bible
Society in the amount of $2,190.00 for its delinquent quarterly expense report for
the second quarter of 2017.
4. To the extent it has not already done so, American Bible Society is directed to pay
the aforesaid administrative penalty in the amount of $2,190.00 to be made payable
to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State
Ethics Commission by no later than the thirtieth (30th) day after the mailing date of
this Order.
5. To the extent it has not already done so, American Bible Society is directed to pay
the additional 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 and forwarded to the
PPennsylvania State Ethics Commission by no later than the thirtieth (301'') day after
the mailing date of this Order.
6. Non - compliance with Paragraph 4 or 5 of this Order will result in the Commission
initiating appropriate enforcement action(s).
BY THE COMMISSION,
is o as o a e a, air