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HomeMy WebLinkAbout1752 DensbergerPHONE: 717 -783 -1610 TOLL FREE: 1 -800- 932 -0936 In Re: Michelle Densberger, Respondent 0ry STATE ETHICS COMMISSION FINANCE BUILDING 613 NORTH STREET, ROOM 309 HARRISBURG, PA 17120 -0400 File Docket: X -ref: Date Decided: Date Mailed: FACSIMILE: 71 7- 787 -0806 WEBSITE: www &thics. a. ov 18 -012 Order No. 1752 516119 5110119 Before: Nicholas A. Colafella, Chair Mark R. Corrigan, Vice Chair Roger Nick Melanie DePalma Monique Myatt Galloway Michael A. Schwartz Shelley Y. Simms This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding possible violation(s) of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq., by the above -named Respondent. At the commencement of its investigation, the Investigative Division served upon Respondent written notice of the specific allegations. Upon completion of its investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an "Investigative Complaint." An Answer was filed and a hearing was requested. 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. ALLEGATIONS: That Michelle Densberger, a public official /public employee in her capacity as a Member and Chairperson of the Madison Township Board of Supervisors, violated Sections 1103(a), 1104(a), 1104(d), 1105(b)(5), 1105(b)(8), and 1105(b)(9) of the State Ethics Act (Act 93 of 1998) when she utilize dd tthe authority of her public position for the private pecuniary benefit of herself, member(s) of her immediate family, and /or a business with which she /members of her immediate family are /were associated when she: Participated in discussions and actions of the Township Board of Supervisors, Including but not limited to initiating, seconding and /or voting on official motions of the Township to borrow, transfer, and /or invest public funds of the Township with First Columbia Bank & Trust, a business with which she is associated; Participated in discussions and actions of the Township Board of Supervisors, including but not limited to motioning, seconding and /or voting on official motions of the Township to appoint, confirm, approve, etc., the hiring of her husband, Robert Densberger, as an employee of the Township for calendar years 2014, 2015, and 2017; Failed to file a calendar year 2013 Statement of Financial Interests with the Township; Densber, er, 18 -012 Page • Failed to identif the Township as a source of income for calendar years 2012, 2014, 20Y5, and 2016; • Failed to list her office, directorship or employment held with First Columbia Bank & Trust for calendar year 2016; and • Failed to list her office, directorship or employment held with R.L. Densberger Hauling Company for calendar years 2012, 2013, 2014, 2015, and 2016. IL FINDINGS: 1. Michelle Densberger ( "Densberger ") has served as a Supervisor for Madison Township ( "Township "), Columbia County, Pennsylvania, since January 2012. a. Densberger [has at times] served as Chairperson of the Madison Township Board of Supervisors ( "Board ") .... b. Densberger [has at times] served as Vice Chairperson of the Board .... 2. Densberger has served as the Madison Township Planning Commission Secretary ( "Planning Commission Secretary") from 2010 to the present. a. The Planning Commission Secretary is appointed by the Board each year during a reorganization meeting. b. The Planning Commission Secretary's duties include attending meetings, recording meeting minutes, maintaining records, and other duties as required. 3. Densberger participated in voting to approve her appointment as the Planning Commission Secretary from 2012 through 2016. a. Densberger abstained from voting to approve her appointment as the Planning Commission Secretary in 2017 and 2018. b. Densberger did not accept compensation as the Planning Commission Secretary. 4. The Board is comprised of three Members and is charged with general governance of the Township and corporate powers of the Township. 5. The Board holds one regular meeting on the second Monday of each month. 6. Board Members receive average yearly gross compensation of $1,200.00 for attending monthly meetings. a. Board Members are compensated $100.00 per meeting attended. b. Actual attendance at the meeting is required to receive compensation. 7. Voting at Board meetings occurs in a roll call fashion after a motion is made and properly seconded. a. All objections and/or abstentions cast are specifically noted within the meeting minutes. b. The Board does not utilize abstention forms to memorialize abstentions. Densber, eerr, 18 -012 Page 3 C. Densberger had no abstention memos filed with the Township. 8. Minutes of Board meetings are prepared by the Township Secretary. a. Board Members are given the opportunity to review the meeting minutes for accuracy prior to the following meeting. b. The Board votes to approve the accuracy of the minutes at each subsequent meeting. 9. The Board votes to approve bill lists at each monthly meeting. a. The bill lists include all bills received as well as monthly Township payroll. 10. Signature authority over financial accounts rests with the Board. a. Any deposit, account opening, withdrawal, endorsement, transfer of funds, approval of payees, or delegation of authority requires the signatures of two Board Members. b. The Board does not utilize signature stamps; all signatures are live signatures. THE FOLLOWING FINDINGS DETAIL DENSBERGER'S EMPLOYMENT WITH FIRST COLUMBIA BANK & TRUST. 11. First Columbia Bank & Trust was founded in 1899 as Bloomsburg National Bank. a. First Columbia Bank & Trust has fourteen current branch locations that serve Columbia, Northumberland, Union, Snyder, and Montour Counties of Pennsylvania. 12. Professionally, Densberger has been employed as a Mortgage Originator with First Columbia Bank & Trust since May 8, 2006. a. Densberger was promoted to Vice President and Mortgage Originator with First Columbia Bank & Trust on March 13, 2013, however, the title of Vice President is a nominal title at First Columbia Bank & Trust. 13. Densberger's job duties as a Mortgage Originator include mortgage origination, development of external business related to mortgages, preparation of mortgage documents, development of loan products, and participation in training requirements. 14. Densberger is compensated through mortgage origination commission and yearly bonuses. a. Densberger receives yearly bonuses based on overall bank performance. b. Yearly bonuses are determined by the First Columbia Bank & Trust Board of Directors. 15. Densberger's employment with First Columbia Bank & Trust is not predicated on the generation of new business for First Columbia Bank & Trust. a. Densberger's production goals are strictly for mortgage origination only. Densber, er, 18 -012 Page THE FOLLOWING FINDINGS DETAIL ACTIONS TAKEN BY DENSBERGER TO DESIGNATE FIRST COLUMBIA BANK & TRUST AS THE FINANCIAL DEPOSITORY FOR THE TOWNSHIP. 16. First Columbia Bank & Trust has been used as a depositary by the Township since 1991. a. The Township had one depository account with First Columbia Bank & Trust starting in 1991. 17. Densberger abstained from voting to approve First Columbia Bank & Trust as the financial depository for the Township during the January 3, 2012, January 4, 2016, January 3, 2017, and January 2, 2018, Board reorganization meetings. a. Densberger abstained from voting to approve First Columbia Bank & Trust as the financial depository for the Township because she is an employee of First Columbia Bank & Trust. 18. Densberger voted to approve First Columbia Bank & Trust as the financial depositoryry for the Township during the January 14, 2013, January 6, 2014, and January 5, 2015, Board reorganization meetings. 19. During a June 25, 2018, investigative interview, Densberger confirmed that she voted to approve First Columbia Bank & Trust as the Township financial depository for 2013, 2014, and 2015. a. Densberger explained at her first Township meeting on January 7, 2012, that she abstained because she worked for First Columbia Bank & Trust and wanted everyone to know she was employed there. THE FOLLOWING FINDINGS DETAIL DENSBERGER'S ACTIONS BETWEEN 2013 AND 2017 TO SECURE FINANCINGILOANSILEASES FOR TOWNSHIP VEHICLES AND EQUIPMENT FROMITHROUGH FIRST COLUMBIA BANK & TRUST. 20. Prior to Densberger taking office as a Supervisor in January 2012, the Township did not seek financing for vehicles or equipment. a. Needed vehicles and equipment were paid for in full out of the Township's General Fund. b. Between 2013 and 2017, the only financial institution utilized for Township vehicle /equipment financing was First Columbia Bank & Trust. 21. The Township's heavy equipment inventory consisted of aged and underpowered equipment. a. Discussions were held among the Supervisors about the need to purchase new /updated equipment. 22. Between 2013 and 2017, Densberger participated in actions of the Board to purchase vehicles with the knowledge that her employer, First Columbia Bank & Trust, would be used to finance the purchases. Purchase of 2006 Sterling _Dump Truck: 23. In a First Columbia Bank & Trust internal email dated June 20, 2013, Densberger contacted First Columbia Bank & Trust Vice President of Commercial Lending, Brandon Ortman ( "Ortman "). Densberger, 18 -012 age a. Densberger's email stated "Brandon, we are looking to purchase a newer truck for the township. I need to know if we spend approx. $45,000.00 on it what portion can the township borrow and what terms would we be looking at? Hoping to make a decision at the July meeting if we get any bids on the ad we are running." b. Ortman replied to Densberger on June 20, 2013, that First Columbia Bank & Trust lends to municipalities and a six -year loan would be a 2.95% interest rate. Ortman recommended a municipal lease because it would not count toward the Township's debt ceiling. 24. On July 8, 2013, following her email correspondence with Ortman, Densberger motioned and participated in voting to approve the purchase of a 2006 Sterling L- 7500 Single Axle Dump Truck ( "Sterling Dump Truck ") for $40,000.00. Densberger introduced Resolution #07082013A that authorized small borrowing for capital purposes at $1 0,000.00, for five ears, with an annual payment due in May with First Columbia Bank & Trus 1. Densberger participated in voting to approve Resolution #07082013A. 2. Densberger participated in signing Resolution #07082013A. The meeting minutes reflect [that the Board] authorized /approved financing the purchase of the Sterling Dump Truck through First Columbia Bank & Trust. 25. Meeting minutes from July 8, 2013, record the following action: OPENING OF BIDS (truck) One bid was received from Auto Wholesalers Used Trucks & Parts for a 2006 Sterling L -7500 Single Axle Dump Truck in the amount of $40,000.00. Claire Swartz stated they did look over the truck and it seems to have everything we are looking for at a very reasonable pprice. He did have some concerns about an automatic transmission. He has spoken to other townships that have the automatic transmission and they have no problems. Most of the newer trucks are now coming with automatic. Nancy Welliver questioned the automatic for plowing snow. Michelle Densberger noted you can shift an automatic. Nancy Welliver asked if anyone around here is using it. Claire Swartz said Penn Dot and HRI in Bloomsburg are using them. He doesn't think the automatic transmission will be any problem. Michelle Densberger noted that an automatic transmission is now a $30,000.00 update on new vehicles. Gary Williams asked if it has been serviced. Michelle Densberger did a car fax on the truck and nothing showed up for repairs or accidents. We will take it immediately to have it serviced. Nancy Welliver questions how we will pay for the truck. Michelle Densberger reported Brandon Ortman, from First Columbia Bank and Trust, is working with us on a loan at 2.95% that will not change. Nancy Welliver asked why we don't use the Liquid Fuel Reserve, noting we probable aren't getting much interest on that money. Claire Swartz said we have other equipment that is old and will be needing repairs and they would like to have some reserve money for emergencies. Nancy Welliver questioned how many hours are put on the Grader. Why not hire someone to do the grading or look into renting one. Michelle Densberger noted there Densber, eerr, 18 -012 Page 6 aren't many peo le out there that can do the grading, or at the time we need them. Glenn Titman stated they use the grader three to four days every week, especially in the summer. Claire Swartz said we can't find one to rent. Michelle Densberger said to rent a new one it is $200.00 an hour. Pine Township will help us with their grader and driver, and then we will help them at some time. Michelle Densberger made a motion to accept the bid or $40, 000.00 to purchase the 2006 Sterling L -7500 Single Axle Dump Truck from Auto Wholesalers Used Trucks & Parts. Glenn Titman seconded the motion. Motion carried. Michelle Densberger introduced Resolution #07082013A authorizing Small Borrowing For Capital Purposes at a rate of $90, 000.00 forfive years, with an annual payment in May. Glenn Titman seconded the motion. Motion carried. 26. Following the Township meeting and enactment/passage of Resolution #07082013A, Densberger emailed Ortman the next day (July 9, 2013) through First Columbia Bank & Trust's internal email to inform Ortman of the following: Brandon, the Township agreed by resolution last night to purchase the truck and finance $40,000.00 at 2.95% for 5 years with 1 annual payment per year due in May or June of each year (not sure what you can do). I have the specs below, please let me know what you need from us and how quickly we can sign in order to go pick it up. Price was $43,900.00. We paid $3,900 for the deposit (snow plow) Borrow $40,000 Peggy has a copy of the bid if you need it I can have her fax it to you {what # }, the bid will only show the $40,000.00 as we already gave them $3900.00 for the plow. a. Ortman replied to Densberger on July 9, 2013, requesting a copy of the Township Resolution for vehicle financing. b. Ortman advised Densberger that the Township Resolution should include the loan amount, term, interest rate, persons authorized to sign, and name of the bank. C. Ortman informed Densberger that he could have the documents prepared within one day. d. "Peggy" refers to Township Secretary Peggy Long. 27. On July 9, 2013, the Sterling Dump Truck was financed with First Columbia Bank & Trust (loan number 502807039391) in the amount of $40,000.00, with an interest rate of 2.95 %. a. Yearly payments in the amount of $8,689.95 were scheduled in May for five years. 28. On July 12, 2013, Densberger, as a Township representative, executed the lease with option to purchase agreement regarding the Sterling Dump Truck between the Township and First Columbia Bank & Trust. a. On the same date, July 12, 2013, First Columbia Bank & Trust check no. 074922, in the amount of $40,000.00, was issued to the Township for the purchase of the Sterling Dump Truck. Densberger, 18 -012 agP _e7 29. At the time Densberger took action to enact Resolution #07082013A, she had already contacted First Columbia Bank & Trust regarding financing and possessed a reasonable expectation that financing would be through a business with which she is associated. Purchase of 2008 New Holland Tractor: 30. In June 2014, the Township sought to purchase a new tractorlbackhoe for use by the Township road department. Township meeting minutes of June 9, 2014, record the following: Claire Swartz noted with the project we will be doing, from the grant money received, we will need a better Back Hoe that will be reliable. We have looked at a couple, there are a lot available. Claire thinks we should buy a used Back Hoe and sell the one we have. Secretary has to have the ad in by June 12, 2014, a second time on June 16, 2014, so we can meet and open bids on June 27. Bob McWilliams asked if there is money in the budget for the Back Hoe. Michelle noted we did budget money for a payment. There was $20,000.00 budgeted for equipment. Bob asked where we would finance the purchase. Michelle called M & T bank, but no one returned her call. She spoke to Brandon Ortman, at First Columbia Bank, for a 3 yrs. term it would be 2.3% fixed. Bob asked if the financing has to be put out for bid. Michelle said not the financing, but if the vehicle is over $18,500.00 for the vehicle, than it would have to be bid. Glenn Titman asked at the Credit Union, but they would only do it if he applied personally for the loan. Michelle noted we financed the truck with First Columbia. They did it as a municipal lean instead of a loan. Which means it does affect any future borrowing Michelle Densbergermade a motion to advertise forbid for a used New Holland Back Hoe to be opened at a special meeting on June 27, 2094, at 3:00 PM at the Jerseytown Community Center. Claire Swartz seconded the motion. Motion carried. Glenn Titman made a motion to advertise a Special Meeting be help on June 27, 2094, 3:00 PM to oppen bids or any other business. Glenn Titman secondedthe motion. Motion carried. 31. In a June 4, 2014, First Columbia Bank & Trust internal email, Ortman informed Densberger of the following "I didn't have time to put a proposal together but wanted to get you the rates. They are lower than we have offered in the past 2.30% fixed for 3 years or 2.50% fixed for 5 years. Let me know if you need anything more." a. [Ortman's email was sent to Densberger] approximately five days prior to the Board meeting held June 9, 2014. 32. During the June 27, 2014, Board meeting, Densberger recommended financing a 2008 New Holland B95 Tractor ( "New Holland Tractor ") through First Columbia Densberger, 18 -012 Page 8 Bank & Trust for $30,000.00. a. Densberger seconded the motion to adopt Resolution #06272014, authorizing the Township to enter into a lease with option to purchase agreement for the New Holland Tractor with First Columbia Bank & Trust, at a rate of 2.30 %. b. At the time Densberger took official action regarding Resolution #06272014, she was aware financing would be through First Columbia Bank & Trust, a business with which she is associated. 33. On June 27, 2014, Densberger, as a Township representative, executed the commercial loan application and lease with option to purchase agreement regarding the New Holland Tractor with First Columbia Bank & Trust. a. By executing the agreement(s), Densberger finalized the New Holland Tractor financing with First Columbia Bank & Trust (loan no. 502807039645) in the amount of $30,000.00, with an interest rate of 2.30 %, on June 27, 2014. 34. In a June 30, 2014, internal email from Ortman to Densberger, Ortman asked Densberger if she had a Township Resolution. a. Densberger replied to Ortman's email on June 30, 2014, and stated, "We will have that on Wed morning to be signed by us and I can give you a copy then if that works." b. In addition to seconding the motion and voting to approve Resolution #06272014, Densberger also signed Resolution #06272014, officially enacting it. 35. On July 2, 2014, First Columbia Bank & Trust issued check no. 079218 in the amount of $30,000.00 as payment to the Township for the purchase of the New Holland Tractor. a. The check was issued following Ortman's communications with Densberger. 36. At the time Densberger took action to enact Resolution #06272014, she had already contacted First Columbia Bank & Trust regarding financing and possessed a reasonable expectation that financing would be through a business with which she is associated. Purchase of 2004 Ford F660 Super Duty Truck: 37. Township meeting minutes from June 8, 2015, record the following: Orange Township has a 2004 Ford F550 truck for sale. Supervisors looked over the truck and feel it is in ood shape. They are asking $15,000.00 but Michelle got them down to $14,000.00. We can us the money from the sale of our old truck and there is $3,580.00 left in our Major Equipment Budget we could use at the end of the year if not needed. Michelle Densbergermade a motion to purchase the 2004 Ford F550 Truck from Orange Township and use First Columbia for the financing for 36 months @ 2.9 % tax exempt fixed rate. Glenn Titman seconded motion. Motion carried. Densberger, 18 -012 Page Michelle Densberger made a motion to approve Resolution #06082015E for a Lease with Option to Purchase with First Columbia Bank. Glenn Titman seconded the motion. Motion carried. Michelle Densberger made a motion to advertise forbids to purchase the 1999 Ford F550 Dump Truck. No plow or spreader (they will go on the 2004) bids to be open at July 13, 2015 meeting. Claire Swartz seconded motion. Motion carried. 38. Densberger, during a June 8, 2015, Board the meeting, motioned and voted to approve Resolution err Duty through First iColumbia Bank & Trust fori$14,000.00. Ford p Y 9 a. In addition to taking action by motion inglvoting on Resolution #06082082015E, Densberger also signed Resolution #06082082015E into law. b. At the time Densberger took official action regarding Resolution #06082082015E, she knew financing would be through First Columbia Bank & Trust, a business with which she is associated. 39. On June 10, 2015, Densberger, as .a Township representative, executed the First Columbia Bank & Trust commercial loan application and lease with option to purchase agreement for the 2004 Ford F550 Super Duty Truck. a. Densberger entered into a binding agreement between the Township and First Columbia Bank & Trust that resulted in a First Columbia Bank & Trust loan (no. 502807039911) for $14,000.00, with an interest rate of 2.10 %. b. Regular payments in the amount of $4,867.06 were scheduled in June for three years. 40. At the time Densberger took action to enact Resolution #06082082015E, she had already contacted First Columbia Bank & Trust regarding financing and possessed a reasonable expectation that financing would be through a business with which she is associated. Purchase of Peterbilt 335 Dump Truck: 41. In 2017, the Township had interest in purchasing a larger dump truck for use by the Township road department. a. Township meeting minutes from April 10, 2017, record the following: New Business: Terry requested permission to put truck out for bid. Motion by Michelle Densberger 2nd by Terry Rider. Motion carried Motion: to advertise for truck bids with specs from Bradco or comparative specs b. Meeting minutes from May 8, 2017, record the opening of bids concerning the dump truck: Opening of Bids: Dump Truck: Received one bid from Bradco in the amount of $50,000 Den_ somber er, 18 -012 Page 10 Used 2009 Peterbilt Model 335 Dump Truck Motion by Glenn Titman 2nd by Terry Rider to accept Bradco bid $50,000 for 2009 used Peterbilt Dump Truck. Discussion was held on the financing of the equipment being purchased as approved earlier in the meeting. The tractor will be paid for with funds from the Liquid Fuels account. The dump truck will be purchased using a lease purchase. A rate quote was received from First Columbia Bank and Secretary Lutcavage will get rates from multiple other banks for both a 3 and 5 year lease purchase with no prepayment penalty. 42. In May 2017, Township Secretary Beverly Lutcavage contacted PNC Bank, M &T Bank, First National Bank, and First Keystone Bank in an effort to obtain information regarding loan interest rates. a. Densberger contacted First Columbia Bank & Trust. b. In a May 8, 2017, First Columbia Bank & Trust internal email to Ortman, Densberger stated "Any Quotes for me?" C. Ortman replied to Densberger on May 8, 2017, and provided her with First Columbia Bank & Trust vehicle loan interest rates of 2.38% for a five -year loan and 2.10% for a three -year loan. 43. On the same date Densberger contacted Ortman (May 8, 2017), during a Board meeting, Densberger motioned and voted to approve financing a Peterbilt 335 Dump Truck ( "Peterbilt Dump Truck ") from the financial institution that provided the best interest rate. 44. The Peterbilt Dump Truck was financed through First Columbia Bank & Trust (loan no. 502807040497) on May 17, 2017, for $50,000.00, with an interest rate of 2.10 %. a. Yearly payments of $17,381.69 were scheduled in May for three years. 45. On May 24, 2017, Densberger, as a Township representative, executed a commercial loan application and lease with option to purchase agreement with First Columbia Bank & Trust. a. On the same date as the execution of the loan /lease agreement, First Columbia Bank & Trust check no. 088445 in the amount of $50,000.00 was issued to the Township for the purchase of the Peterbilt Dump Truck. 46. At the time Densberger took official action as a Supervisor, she was aware financing would be through First Columbia Bank & Trust, a business with which she is associated. 47. The chart below details all vehicle and equipment loans obtained through First Columbia Bank & Trust and the total amount of interest paid to First Columbia Bank & Trust. Denber, err, 18 -012 Page 11 Loan No Date of Loan Veh. /E ui ment Loan Amount Paid Interest Balance 502807039391 12- Jul -13 Dump Truck $40,000M $2,839.60 $5.23 502807039645 2- Jul -14 Tractor $30,000.00 $1,286.09 $0.00 502807039911 10- Jun -15 Ford F550 $14,000,00 $502.50 $0.00 502807040497 24-May-1 7 Dump Truck $50,000.00 $1,064.58 $33,682.8Q Total $5,692.77 48. Densberger, as a Supervisor, utilized the authority of her public office when she: a. Participated in Board discussions regarding financing vehicles and equipment with First Columbia Bank & Trust; b. Obtained interest rates and vehicle and equipment financing information from her employer, First Columbia Bank &' rust; C. Voted to approve financing vehicles and equipment with First Columbia Bank & Trust between 2013 and 2017; d. Signed Township Resolutions that authorized financing vehicles and equipment with First Columbia Bank & Trust; and e. Signed loan agreements with First Columbia Bank & Trust. 49. First Columbia Bank & Trust, a business with which Densberger is associated, received interest and principal payments made by the Township to First Columbia Bank & Trust, at a time when Densberger voted to approve payment of loans outstanding to First Columbia Bank & Trust, as detailed above. a. First Columbia Bank & Trust received payment of interest in association with the financing arranged byy Densberger between the Township and First Columbia Bank & Trust, thereb , First Columbia Bank & Trust realized a pecuniary benefit as defined in the Ethics Act. b. Densberger received no ascertainable pecuniary benefit from First Columbia Bank & Trust, her employer, as a result of the Board approving and repaying the outstanding loans detailed above. THE FOLLOWING FINDINGS DETAIL THE HIRING OF DENSBERGER'S HUSBAND, ROBERT DENSBERGER, AS A PART -TIME TOWNSHIP EMPLOYEE. 50. Robert Densberger ( "Mr. Densberger") is the husband of Densberger and a member of her immediate family. 51. Mr. Densberger was hired as a part-time Township road worker in January 2012, at or about the same time that Densberger took office as a Supervisor. a. Mr. Densberger's hours of employment with the Township varied from year to year based on the needs of the Township. b. Mr. Densberger was hired based on his possession of a Commercial Driver's License (CDL) and his experience in operating trucks and heavy equipment. 52. Mr. Densberger's duties included snow removal, operating heavy equipment, and assisting with various Township road projects. Densber, er, 18 -012 Page 53. Densberger did not lobby or participate in discussions regarding the hiring of Mr. Densberger as a part -time road worker. 54. Each year during the Board reorganization meeting, the Board took action to hirelrehire part -time road workers. a. Densberger abstained from voting to approve Mr. Densberger's hiring as a part-time laborer during the Board reorganization meetings for 2012, 2013, 2014, and 2016. Although Densberger abstained from the vote, she did make the motion to hire Mr. Densberger during the January 6, 2014, meeting of the Board. 2. Meeting minutes reflect that Densberger abstained from the actual vote because Mr. Densberger is her husband. b. Densberger participated in voting for Mr. Densberger's hiringlrehiring by the Township during the Board reorganization meetings for 20'115 and 2017. C. Densberger claims that her votes during the 2015 and 2017 reorganization meetings were taken as a group, and her votes /participation were an oversight. 55. Densberger participated in voting to approve the pair rate for part -time road workers, including Mr. Densberger, during the Board reorganization meetings in 2013 through 2017. a. Mr. Densberger was compensated $12.25 per hour in 2013; $12.35 per hour in 2014; $12.50 per hour in 2015; $13.50 per hour in 2016; and $14.50 per hour in 2017, the same amount payable to all part-time workers in his class. b. The Township employed the following number of part -time road /labor employees per year, including Mr. Densberger, as detailed below: Year Number of Part-time Employees 2013 11 0 0 0 2017 3 C. Calendar years 2013, 2014, and 2015 include the appointment of all three Supervisors as part-time/as-needed labor. 56. Densberger did not participate in discussions or take official action to obtain more work hours or additional compensation for Mr. Densberger as a part-time Township road worker. a. Densberger voted and participated in the hiring/rehiring of Mr. Densberger in 2015 and 2017. THE FOLLOWING FINDINGS DETAIL DENSBERGER'S ACTIONS BETWEEN 2013 AND 2017 TO TRANSFER TOWNSHIP FUNDS TO FIRST COLUMBIA BANK & TRUST. Den�sber e�r, 18 -012 Page 13 57, Between 2013 and 2017, Densberger participated in discussions and actions of the Board to open accounts with and/or transfer Township funds to First Columbia Bank & Trust, which included purchasing certificates of deposit, transferring State Liquid Fuels accounts, and moving Pennsylvania Local Government Investment Trust accounts. Purchase of Certificates of Deposit ( "CDs"); 58. The Pennsylvania Local Government Investment Trust ( "PLGIT ") was created in 1981 to meet the short -term investment needs of local governments, school districts, municipal authorities, and other governmental entities in the Commonwealth of Pennsylvania. a. PLGIT offers a wide array of investment options and cash management services, including the following: 1. No minimum investment or balance requirements for PLGIT -Class shares or PLGIT /PRIME; 2. Fixed -rate, fixed -term investment options, including FDIC - insured CDs; 3. Unlimited number of accounts; 4. Unlimited checking; 5. Unlimited next -day transfers; 6. Up to two same -day transfers each month at no cost; 7. Direct deposit of subsidy payments and other revenues; and 8. Online account access, transactions, and online statements. b. PLGIT serviced the majority of the Township's depository accounts until August 2016. 1. In August 2016, the Board agreed to close any remaining depository accounts with PLGIT and transfer the funds to First Columbia Bank & Trust. 59. In June 2012, Densberger participated in a discussion of the Board concerning the investment/reinvestment of Township funds in financial institutions other than PLGIT. a. Meeting minutes from the Board's June 11, 2012, meeting record the following: NEW BUSINESS: "Michelle Densberger suggested pulling money from PLGIT to get a CD for better rates. Bloomsburg Bank Columbia Trust [First Columbia Bank & Trust] has a CD that allows you to make one withdraw without a penalty. We will do more checking to get as much interest as we can. Table until next month.' b. At the Board's July 9, 2012, meeting, the following action was taken by the Board: Denber, eerr, 18 -012 Page 14 NEW BUSINESS: "Peggy Lang checked to see if State Funds can be put into a CD. They encourage you to do so. Michelle has rates from First Columbia Bank. Peggy will check with M & T Bank. We need to have a flex CD in case we have an emergency." C. Long received investment rates from M &T Bank, which were presented to the Board. 60. During the August 13, 2012, Board meeting, Densberger motioned and voted to approve the transfer of funds from the Township PLGIT accounts to open two new CD accounts with First Columbia Bank & Trust. a. Minutes from August 13, 2012, record the following action by Densberger: OLD BUSINESS: "Michelle Densberger made a motion to set up two CDs, one from General Fund and one from State Liquid Fuel Fund in the amount of $50,000.00 each. Signature cards will have to be signed at the bank, requiring a signature of one of the three Supervisors, and one of the secretary (same as on checks). Claire Swartz seconded the motion. Motion carried." b. First Columbia Bank & Trust CD accounts 80842 and 80843 were opened on August 15, 2012, with an initial deposit of $50,000.00 to each account. 1. PLGIT check no. 6500 details a $50,000.00 payment to First Columbia Bank & Trust from PLGIT account no. 15820191 on August 14, 2012. 2. PLGIT check no. 875 details a $50,000.00 payment to First Columbia Bank & Trust from PLGIT account no. 15820357 on August 14, 2012. 3. The memo portion for each check details the check was allocated for purchase of a CD. C. Meeting minutes of the Township's September 10, 2012, meeting record the Board's approval of the transfer of $50,000.00 into a First Columbia Bank & Trust CD account as detailed below: FINANCIAL REPORTS: The financial statements and bills list were reviewed. Claire Swartz made a motion to approve the financial reports and to $a bills as presented. Bills paid from General Fund were 6$1.54. Bills paid from Liquid Fuel Fund were $12050.29 (but hold check #880 $89.95 for now). Bills paid during the month from the General Fund totaled $50331.15 ($50,000.00 into a CD). Bills paid during the month from Liquid Fund were $50,000.00 (into a CD). Michelle Densberger seconded the motion. Motion carried. d. First Columbia Bank & Trust deposit records confirm additional deposits Densber. eerr, 18 -012 Page 15 totaling $95,000.00 were made to CD accounts 80842 and 80843 on May 15, 2013. Deposits of $60,000.00 and $35,000.00 were made to CD accounts 80843 and 80842, respectively. 2. No vote was taken by the Board to approve the transfer of the additional $95,000.00 of PLGIT funds to the First Columbia Bank & Trust CD accounts. e. Densberger's signature appears on a $35,000.00 PLGIT check (no. 940 representing a deposit into First Columbia Bank & Trust CD account 8084 dated May 9, 2013. Densberger's signature on PLGIT check no. 940 was affixed as a Township authorized signatory, authorizing deposit of check no. 940 into First Columbia Bank & Trust CD account 80842. Densberger's signature is not affixed to PLGIT check no. 6808, dated May 9, 2013, representing the $60,000.00 transfer to First Columbia Bank & Trust. The signatures of Supervisor Claire Swartz and Township Secretary Peggy Long are affixed to check no. 6808. 61. During the August 8, 2016, Board meeting, Densberger participated in actions of the Board by voting to approve closing First Columbia Bank & Trust CD accounts 80842 and 80843. a. Densberger discussed moving the CD account funds to new Repurchase Accounts at First Columbia Bank & Trust because the Repurchase Accounts provided a better interest rate than the existing CD accounts. A Repurchase Account is also referred to as a "sweep account" and is an investment mechanism in which excess funds from a deposit account (as set by the customer) are "swept" into a short -term investment. Proceeds from the investment are deposited back into the original deposit account. b. First Columbia Bank & Trust deposit records reflect that $101,971.13 was transferred from account 80842 to First Columbia Bank & Trust Repurchase Account 761699 and that $112,295.45 was transferred from account 80843 to First Columbia Bank & Trust Repurchase Account 761556 on August 11, 2016. C. Densberger, as a Township representative, signed the signature cards for First Columbia Bank & Trust Repurchase Accounts 761699 and 761556. Transfer of State Liquid Fuels Funds; 62. The Township receives State Liquid Fuels funds from the Pennsylvania Department of Transportation yearly in March. a. Township State Liquid Fuels funds were deposited into PLGIT account no. 1582035 until March 2016, at which time most Township PLGIT accounts were closed and any remaining funds were transferred to First Columbia Bank & Trust. 63. From .Tune 2013 until December 2013, Densberger participated in discussions Densber, eerr, 18 -012 Page 16 pertaining to transferring State Liquid Fuels funds maintained by PLGIT accounts to First Columbia Bank & Trust. a. Minutes from the May 13, 2013, Board meeting confirm that Densberger participated in discussions regarding transferring PLGIT -held Township funds to accounts managed by First Columbia Bank & Trust, as detailed below: NEW BUSINESS: Consideration of changing from PLGIT to First Columbia Bank. The interest rates are not much different, but the checks are very costly through PLGIT. Michelle noted the first checks are free from First Columbia Bank and then there would be a charge. The difference would be that with First Columbia Bank you can purchase your checks from an outside company for way less cost. PLGIT does not allow that. Let's wait to see what Pauline O'Brian from First Columbia Bank has to say. The Board tabled further discussion on the matter until August 12, 2013, during which the following discussion took place: OLD BUSINESS: "Peggy received a proposal from Pauline of First Columbia Bank. It was given to Michelle Densberger to look over. Millville Borough did change over from PLGIT to First Columbia Bank. Michelle explained the Bank would sweep the funds over night, invest the funds, and then put them back the next morning. We would not notice what was happening. We would be earning way more money with the repurchase program than with PLGIT. Claire Swartz questioned what was, "way more money ?" Michelle said when you get $.00 a $1.00 is way more money. Claire Swartz said he did not want to vote to change for a $1.00. Michelle Densberger said with the repurchase program it is going to be variable, you aren't going to know that for a while because it will depend on how much is in the accounts each night. No guarantee, but on the average it should be at least .05 %. Gary Williams asked if it is guaranteed we won't lose the principal. Michelle Densberger technically we could lose, but the bank agrees that its obligation shall be secured under Federal Agencies. In the event of a default, the depositor will have the right to direct the Bank to sell the security and apply the proceeds in satisfaction of the Banks obligation to the Depositor. The Bank would have to give the money back. We would not be out the money, but the Bank could be. Claire Swartz said he is not sold. He would like to consider further before putting all the eggs in one basket." C. At the November 11, 2013, Board meeting, Densberger motioned and voted to transfer funds from the PLGIT General Fund and State Liquid Fuels Accounts to First Columbia Bank & Trust, as detailed below: Densber, er, 18 -012 Page OLD BUSINESS: Michelle Densberger made a motion to move the funds from PLGIT's General Fund and State Liquid Fuel accounts to First Columbia Bank & Trust. Glenn Titman seconded the motion. Motion carried. The State Liquid Fund Plus Fund and the Municipal Authority Fund will be left with PLGIT. 64. Following the Board's discussion /action on November 11, 2013, the Township o ened Repurchase Account no. 0691552 at First Columbia Bank & Trust on November 26, 2013, with an initial deposit of $25,000.00. a. Densberger's signature is affixed to the signature card as a Supervisor. b. A December 31, 2013, First Columbia Bank & Trust statement confirms a deposit of $25,000.00 into Repurchase Account no. 0691552 on December 3, 2013. C. PLGIT check no. 997 in the amount of $25,000.00 was deposited into Repurchase Account no. 0691552 on December 3, 2013. 1. Densberger's signature as a Township official is affixed to PLGIT check no. 997. 2. A memo on PLGIT check no. 997 details that the PLGIT funds were moved to First Columbia Bank & Trust. 65. PLGIT Automated Clearing House (ACH) records confirmed that on March 2, 2014, the Pennsylvania Treasury deposited $136,261.15 into the Township's PLGIT account no. 1582015. a. A Commonwealth State Liquid Fuels Allocation Report for calendar year 2014 details a $136,261.15 payment to the Township for Liquid Fuels for calendar year 2014. b. On March 5, 2014, $137,769.87 was transferred from the Township's PLGIT account no. 1582035 to First Columbia Bank & Trust Repurchase Account no. 0691552. C. The memo on the check details moving funds from PLGIT to First Columbia Bank & Trust. 66. On July 21, 2014, a $50,000.00 deposit was made as a result of the Board voting on November 11, 2013, to approve transferring funds from PLGIT General Funds to First Columbia Bank & Trust. a. During the November 11, 2013, meeting, Densberger motioned and voted to approve transferring funds from PLGIT to First Columbia Bank & Trust. b. Glen Titman and Peggy Long signed check no. 7294 for $50,000.00. C. PLGIT check no. 7294 in the amount of $50,000.00 was deposited into First Columbia Bank & Trust account no. 2700880814. 67. On March 5, 2015, a $150,008.30 transfer was made from the Township's PLGIT account no. 1582015 to First Columbia Bank & Trust Repurchase Account no. Dens�berc er., 18 -012 Page 18 0691552. a. The source of the $150,008.30 was a deposit made into the Township's PLGIT account no. 1582015 on March 2, 2015, from the Pennsylvania Treasury in the form of a State Liquid Fuels allocation. b. The State Liquid Fuels allocation report for calendar year 2015 reflects a $150,008.30 payment to the Township for Liquid Fuels for calendar year 2015. 68. From March 2016 until March 2018, Township State Liquid Fuels funds were electronically deposited into First Columbia Bank & Trust Repurchase Account no. 0691552. 2n16. • The Township was allocated $175,074.24 for the 2016 calendar year from State Liquid Fuels. • A March 31, 2016, First Columbia Bank & Trust statement for Repurchase Account no. 0691552 confirms a $175,074.24 deposit on March 1, 2016, from the Pennsylvania Treasury. 2017: • The Township was allocated $183,089.05 for the 2017 calendar year from State Liquid Fuels. • A March 31, 2017, First Columbia Bank & Trust statement for Repurchase Account no. 0691552 reflects a $183,089.05 deposit on March 1, 2017, from the Pennsylvania Treasury. 2018: • The TownshKwas allocated $191,880.17 for the 2018 calendar year from State Liquid els. • A March 31, 2018, First Columbia Bank & Trust statement for Repurchase Account no. 0691552 details a $191,880.17 deposit on March 1, 2018, from the Pennsylvania Treasury. 69. Between March 2014 and March 2018, a total of $836,312.91 of State Liquid Fuels funds was transferred or electronically deposited to First Columbia Bank & Trust. a. Densberger participated in Board actions which resulted in these transfers. Closure of PLGIT Accounts: 70. Between April 2016 and August 2016, Densberger participated in discussions of the Board regarding closing PLGIT accounts and #ransferring most of the remaining PLGIT -held Township funds to First Columbia Bank & Trust. 71. At the April 11, 2016, Board meeting, Densberger inquired as to how much interest the Township was receiving from PLGIT. a. Densberger advised the Board that she would inquire into possibly taking $45,000 from the PLGIT account and opening a Repurchase Account with First Columbia Bank & Trust. Densber, eerr, 18 -012 Page 19 b. Minutes of the April 11, 2016, Board meeting record the following action: Michelle questioned how much interest we are getting from PLGIT on the plus. Michelle will check to see if we could put the $45,000.00 into the First Columbia Repurchase account. We may have to add $5,000.00 to make it $50,000.00 and list as a separate account. Nancy asked how much interest we are getting for the CDs. Michelle said it is close to the repurchase but not as good. The reason we have the CDs was to have untouched money. Nancy said all money should be listed. Gary Williams heard on news there is some legislation so the tax payers know exactly what is going on in the townships. Michelle said we are not hiding anything it probable -ust got missed putting them on the report. We've onlly had them for two years. Michelle asked do we want to put the PLGIT Plus into the repurchase account. Township Secretary Beverly Lutcavage contacted First Keystone, M &T Bank, and PNC Bank between June and July 2016 to obtain interest rates for Repurchase Accounts. d. Densberger coordinated obtaining interest rate information from First Columbia Bank & Trust. 72. During the Board's July 11, 2016, meeting, Densberger informed the Board that she was discussing with First Columbia Bank & Trust "wording changes" for the Repurchase Agreement. 73. During the August 8, 2016, Board meeting, Densberger motioned to close PLGIT accounts and CD accounts and transfer the funds to Repurchase Accounts at First Columbia Bank & Trust. Densberger participated in voting to approve the closure of the PLGIT accounts and CD accounts and to transfer the funds to First Columbia Bank & Trust. (Vote 3 -0). At the time Densberger took action regarding the transfer of Township PLGIT monies, she was aware that First Columbia Bank & Trust was a business with which she is associated. 74. Following the August 8, 2016, vote of the Board, including Densberger, to close all of the Townships remaining PLGIT accounts and transfer the funds to First Columbia Bank & Trust, two transfers were made from the Township's PLGIT accounts to First Columbia Bank & Trust Repurchase Account no. 0691552. a. First Columbia Bank & Trust deposit records reflect that on August 26, 2016, $50,000.00 was transferred from PLGIT to First Columbia Bank & Trust Repurchase Account no. 0691552. On December 13, 2016, Township PLGIT account no_ 1582035 was closed and $61,133.07 was transferred to First Columbia Bank & Trust Repurchase Account no. 0691552. Densber, er, 18 -012 Page First Columbia Bank & Trust Repurchase Account no. 0691552 was opened on November 26, 2013. C. On December 13, 2016, Township PLGIT account no. 1582019 was closed and $46,544.31 was transferred to First Columbia Bank & Trust Repurchase Account no. 2700880814. 75. From August 2012 until December 2016, Densberger participated in Board actions resulting in $715,455.55 of Township funds held in PLGIT accounts, including Liquid Fuels monies, being transferred to First Columbia Bank & Trust. 76, First Columbia Bank & Trust realized a pecuniary benefit as a result of the transfer of public monies of the Township to First Columbia Bank & Trust, a business with which Densberger is associated. a. The transfer of public monies of the Township to First Columbia Bank & Trust had not, as of the date of the Consent Agreement [(April 5, 2019)], caused a pecuniary detriment to the Township. 77. Densberger did not receive any personal pecuniary benefit from the Township's transfer of public monies to First Columbia Bank &Trust. THE FOLLOWING FINDINGS RELATE TO THE ALLEGATIONS REGARDING DENSBERGER'S STATEMENT OF FINANCIAL INTERESTS FORMS FOR CALENDAR YEARS 2012 THROUGH 2016. 78. On March 6, 2018, a Statement of Financial Interests compliance review was conducted at the Madison Township Office by a State Ethics Commission Investigator. a. The purpose of the compliance review was to review the Statement of Financial Interests forms that were completed and on file for all Township officials /employees who were required to file. 79. The compliance review revealed that Densberger failed to file a Statement of Financial Interests for the 2013 calendar year. a. Densberger filed a Statement of Financial Interests with the Township for calendar year 2013 on June 4, 2018. 80. Densberger failed to include her office, directorship or employment, namely her position as Vice President of First Columbia Bank & Trust, on her 2016 filing. 81. Densberger received $100.00 for attendance at each meeting of the Board. a. Any fluctuation in yearly compensation was due to additional Board meetings. 82. Densberger received the following Supervisor salary from the Township as reported on W -2 Wage and Tax Statements for calendar year 2013: a. 2013: $1,100.00. 83. Densberger neglected to include income in excess of $1,300.00 received from the Township on Statements of Financial Interests filed for calendar years 2012, 2014, 2015, and 2016. 84. On June 4, 2018, Densberger filed amended Statements of Financial Interests for Densber, eerr, 18 -012 Page 21 calendar years 2012 through 2017. 85. Densberger, during a June 25, 2018, investigative interview, stated that her role in R.L. Densberger Hauling Company is to assist with bookkeeping and as a cosigner on the business checking account, used by her only to sign checks in the event that Robert Densberger is unavailable to sign the same. a. R.L. Densberger Hauling Company is owned by Densberger's husband, Robert Densberger. b. Densberger confirmed that she makes payments for the company and balances the finances of the company. C. Densberger stated that she receives no income from R.L. Densberger Hauling Company. 86. No evidence was developed during the course of the investigation to suggest that First Columbia Bank & Trust had knowledge of any conflict of interest as set forth above. 87. No evidence was developed during the course of the investigation to suggest that First Columbia Bank & Trust offered or provided any investment accounts or loans to the Township at an rates, conditions, or terms that were not otherwise offered to other local municipalities. III. DISCUSSION: As a Supervisor for Madison Township ( "Township "), Columbia Countyy, Pennsylvania, since January 2012, Respondent Michelle Densberger, also referred to hereinafter as Respondent, Respondent Densberger, and Densberger, has been a public official subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq. The allegations are that Densberger violated Sections 1103(a), 1104(a), 1104(d), 1105(b)(5), 1105(b)(8), and 1105(b)(9) of the Ethics Act: (1) When she utilized the authority of her public position for the private pecuniary benefit of herself, member(s) of her immediate family, and/or a business with which she /members of her immediate family are /were associated when she: (a) Participated in discussions and actions of the Township Board of Supervisors, includin but not limited to initiating, seconding and /or voting on official mo�ions of the Township to borrow funds from, transfer Township funds to, and /or invest Township funds with First Columbia Bank & Trust, a business with which she is associated; and (b) Participated in discussions and actions of the Township Board of Supervisors, including but not limited to initiating, seconding and /or voting on official motions of the Township to appoint, confirm, approve, etc., the hiring of her husband, Robert Densberger, as an employee of the Township for calendar years 2014, 2015, and 2017; (2) When she failed to file a calendar year 2013 Statement of Financial Interests with the Township; (3) When she failed to identify the Township as a source of income for calendar years 2012, 2014, 2015, and 2016; Debera�r, 18 -012 Page 22 (4) When she failed to list her office, directorship or employment with First Columbia Bank & Trust for calendar year 2016; and (5) When she failed to list her office, directorship or employment with R.L. Densber er Hauling Company for calendar years 20'12, 2013, 2014, 2015, and 2016. Pursuant to Section 1103(a) of the Ethics Act, a public official/public employee is prohibited from engaging in conduct that constitutes a conflict of interest: § 1103. Restricted activities (a) Conflict of interest. —No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 Pa.C.S. § 1103(a). The term "conflict of interest" is defined in the Ethics Act as follows: § 1102. Definitions "Conflict" or "conflict of interest." Use by a public official or public employee of the authority of his office or employment or any confidential information received through his holding public office or employment for the private pecuniary benefit of himself, a member of his immediate family or a business with which he or a member of his immediate family is associated. The term does not include an action having a de minimis economic impact or which affects to the same degree a class consisting of the general public or a subclass consisting of an industry, occupation or other group which includes the public official or public employee, a member of his immediate family or a business with which he or a member of his immediate family is associated. 65 Pa.C.S. § 1102. Section 1103(a) of the Ethics Act prohibits a public official /public employee from using the authority of public office /employment or confidential information received by holding such a public position for the private pecuniary benefit of the public official/public employee himself, any member of his immediate family, or a business with which he or a member of his immediate family is associated. Section 1104(a) of the Ethics Act provides that each public official/public employee must file a Statement of Financial Interests ( "SFI ") for the preceding calendar year, each year that he holds the position and the year after he leaves it. Section 1104(d) of the Ethics Act provides that no public official shall be allowed to take the oath of office, or enter or continue upon his duties, nor shall he receive compensation from public funds, unless he has filed an SFI as required by the Ethics Act. Section 1105(b) of the Ethics Act and its subsections detail the financial disclosure that a person required to file the SFI form must provide. Densber, er, 18 -012 age Subject to certain statutory exceptions not applicable to this matter, Section 1105(b)(5) of the Ethics Act requires the filer to disclose on the SFI the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more. Section 1105(b)(8) of the Ethics Act requires the filer to disclose on the SFI any office, directorship or employment in any business entity. Section 1105(b)(9) of the Ethics Act requires the filer to disclose on the SFI any financial interest in any legal entity en aged in business for profit. The term "financial interest" is defined in the Ethics Act as "fa]ny financial interest in a le al entity engaged in business for profit which comprises more than 5% of the equity of t9e business or more than 5% of the assets of the economic interest in indebtedness." 65 Pa.C.S. § 1102. 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. Background Densberger has served as a Township Supervisor since January 2012. Densberger has at times served as Chairperson or Vice Chairperson of the Township Board of Supervisors ( "Board "). The Board consists of three Members. Township Supervisors are compensated $100.00 per meeting attended. Signature authority over financial accounts rests with the Board. Any deposit, account opening, withdrawal, endorsement, transfer of funds, approval of payees, or delegation of authority requires the signatures of two Supervisors. The Board does not utilize signature stamps. Densberger has been employed as a Mortgage Originator with First Columbia Bank & Trust (the "Bank ") since May 8, 2006. Densberger was promoted to Vice President and Mortgage Originator with the Bank on March 13, 2013. Densberger is compensated through mortgage origination commission and yearly bonuses that are based on overall bank performance. The Township has used the Bank as a depository since 1991. Densberger abstained from Board votes that approved the Bank as the financial depository for the Township for 2012, 2016, 2017, and 2018. Densberger participated in Board votes that approved the Bank as the financial depository for the Township for 2013, 2014, and 2015. Re: Bank Financing for the Purchase of Township Vehicles/Equip ment Prior to Densberger taking office as a Supervisor in January 2012, the Township did not seek financing for vehicles or equipment. Needed vehicles and equipment were paid for in full out of the Township's General Fund. The Township's heavy equipment inventory consisted of aged and underpowered equipment, and the Supervisors discussed the need to purchase new /updated equipment. In an internal Bank email dated June 20, 2013, Densberger asked the Bank's Vice President of Commercial Lending, Brandon Ortman ( "Ortman "), what the Bank's terms for financing would be with regard to the Township's potential purchase of a newer truck for approximately $45,000.00. Ortman replied that the interest rate for a six -year loan would be 2.95 %. At the July 8, 2013, meeting of the Board, Densberger made a motion and voted to approve the purchase of a 2006 Sterling L-7500 Single Axle Dump Truck ( "Sterling Dump Truck ") for 40,000.00. Densberger then introduced, voted to approve, and signed Resolution #07082013A, which authorized financing used to purchase the Sterling Dump Densberger, 18 -012 age Truck through the Bank. On July 12, 2013, Densberger, as a Township representative, executed a lease with option to purchase agreement with the Bank for the Sterling Dump Truck. The Bank loaned the Township the amount of $40,000.00, at the interest rate of 2.95% for five years, to purchase the Sterling Dump Truck. In June 2014, the Township sought to purchase a new tractorlbackhoe for use by the Township road department. In a June 4, 2014, internal Bank email, Ortman informed Densberger of the fixed interest rates for three -year and five -year loans. During a Board meeting on June 27, 2014, Densberger recommended financing the purchase of a 2008 New Holland B95 Tractor ( "New Holland Tractor ") for $30,000.00 through the Bank. Densberger seconded the motion to adopt Resolution #06272014, which authorized the Township to enter into a lease with option to purchase agreement with the Bank for the New Holland Tractor. Densberger also voted to approve and signed Resolution #06272014. On June 27, 2014, Densberger, as a Township representative, executed a commercial loam application and lease with option to purchase agreement with the Bank for the New Holland Tractor. The Bank loaned the Township the amount of $30,000.00, at the interest rate of 2.30 %, to purchase the New Holland Tractor. At the Board's meeting on June 8, 2015, Densberger made a motion and voted to approve Resolution #06082082015E, which authorized the purchase of a 2004 Ford F550 Super Duty Truck ( "Ford Truck") with financing b the Bank. Densberger also signed Resolution #06082082015E. On June 10, 2015, Densberger, as a Township representative, executed the Bank's commercial loan application and lease with option to purchase agreement for the Ford Truck. The Bank loaned the Township the amount of $14,000.00, at the interest rate of 2.10% for three years, to purchase the Ford Truck. In 2017, the Township had interest in purchasing a larger dump truck for use by the Township road department. On May 8, 2017, Densberger contacted Ortman by an internal Bank email, and he provided her with interest rates for three -year and five -year vehicle loans. Also on May 8, 2017, during a Board meeting, Densberger made a motion and voted to approve financing the purchase of a Peterbilt 335 Dump Truck ( "Peterbilt Dump Truck ") through the financial institution that provided the best interest rate. On May 24, 2017, Densberger, as a Township representative, executed a commercial loan application and lease with option to purchase agreement with the Bank for the Peterbilt Dump Truck. The Bank loaned the Township the amount of $50,000.00, at the interest rate of 2.10% for three years, to purchase the Peterbilt Dump Truck. Re; The Transfer of Township Investments and Depository_ Accounts to the Bank The Pennsylvania Local Government Investment Trust ( "PLGIT ") offers investment options and cash management services to local governments in Pennsylvania. Until August 2016, PLGIT serviced the majority of the Township's depository accounts. In June 2012, Densberger participated in a Board discussion concerning the investment/reinvestment of Township funds with financial institutions other than PLGIT. At the August 13, 2012, meeting of the Board, Densberger made a motion and voted to approve the transfer of funds from the Township's PLGIT accounts in order to open two new certificate of deposit ( "CD ") accounts in the amount of $50,000.00 each with the Bank. On August 15, 2012, two CD accounts were opened with the Bank, and a PLGIT check in the amount of $50,000.00 was deposited into each CD account. On May 15, 2013, additional deposits totaling $95,000.00 were made to the two CD accounts. Densberger's signature as an authorized Township signatory was affixed to a PLGIT check in the amount of $35,000.00 that was deposited into one of the CD accounts on that date. Densberger, 18 -012 Page During the August 8, 2016, Board meeting, Densberger discussed moving the funds in the two CD accounts at the Bank to new accounts at the Bank that would provide a better interest rate, and she voted to approve closing the two CD accounts. On August 11, 2016, the amounts of $101,971.13 and $112,295.45 were transferred from the two CD accounts to two new accounts at the Bank. Densberger, as a Township representative, signed the signature cards for the two new accounts. In March of each year, the Township receives State Liquid Fuels funds from the Pennsylvania Department of Transportation. In May 2013 and August 2013, Densberger participated in Board discussions with regard to transferring Township State Liquid Fuels funds from accounts maintained by PLGIT to accounts managed by the Bank. At the Board's meeting on November 11, 2013, Densberger made a motion and voted to transfer funds from the Township's PLGIT General Fund Account and State Liquid Fuels Account to the Bank. On November 26, 2013, the Township opened Repurchase Account no. 0691522 (the "Repurchase Account ") at the Bank. Densberger's signature as a Supervisor was affixed to the signature card for the Repurchase Account. Densberger's signature as a Supervisor was also affixed to a PLGrf check in the amount of $25,000.00 that was deposited into the Repurchase Account on December 3, 2013. As a result of the Board's vote on November 11, 2013, the amount of $50,000.00 was subsequently deposited into a different account that the Township had with the Bank. In March 2014 and March 2015, the Pennsylvania Treasury deposited State Liquid Fuels funds that were allocated to the Township into Township PLGIT account no. 1582015 ( "PLGIT Account 1582015 "). The State Liquid Fuels funds were then transferred from PLGIT Account 1582015 to the Repurchase Account at the Bank. In March 2016, March 2017, and March 2018, the Pennsylvania Treasury electronically deposited State Liquid Fuels funds that were allocated to the Township into the Repurchase Account. Between March 2014 and March 2018, State Liquid Fuels funds totaling $836,312.91 were transferred to or electronically deposited into the Repurchase Account. Between April 2016 and August 2016, Densberger participated in discussions and actions of the Board with regard to closing all remainin Township PLGIT accounts and transferring the funds to the Bank. At the April 11, 216, Board meeting, Densberger inquired as to how much interest the Township was receiving from PLGIT, and she advised the Board that she would inquire into whether the Township could take $45,000.00 from a PLGIT account and open an account with the Bank. During the Board's August 8, 2016, meeting, Densberger made a motion and voted to close the Township's PLGIT accounts and transfer the funds to accounts with the Bank. Between August 26, 2016, and December 13, 2016, the amounts of $50,000.00, $61,133.07, and $46,544.31 were transferred to Township accounts at the Bank, and two Township PLGIT accounts were closed. Re: The Hiring of Densberger's Husband as a Part -time Township Employee Robert Densberger ( "Mr. Densberger ") is Densberger's husband. Mr. Densberger was hired as a part-time Township road worker in January 2012, at or about the same time that Densberger took office as a Supervisor. Densberger abstained from voting to approve Mr. Densberger's hiring as a part -time Township road worker for 2012. Each year during the Board's reorganization meetin in January, the Board took action to hire/rehire part-time road workers. Densberger abs ?ained from voting to approve Mr. Densberger's hiring /rehiring as a part-time road worker for 2013. During the Board's January 6, 2014, reorganization meeting, Densberger made a motion to hire/rehire Mr. Densberger for 2014, but she abstained from the Board's vote that approved Mr. Dente, 18 -012 Page 26 Densberger's hiring /rehiring for 2014. Densberger voted to approve her husband's hiringlrehiring for 2015, abstained from voting to approve his hiringlrehiring for 2016, and voted to approve his hiring/rehiring for 2017. Mr. Densberger's duties as a part-time Township road worker included snow removal, operating heavy equipment, and assisting with various Township road projects. Mr. Densberger's hours of employment with the Township varied from year to year based on the needs of the Township. Re: Densberger's SFIs On March 6, 2018, a State Ethics Commission Investigator conducted an SFI compliance review at the Township Office. The compliance review revealed that Densberger failed to file an SFI for calendar year 2013. Densberger neglected to include income in excess of $1,300.00 that she received from the Township on her SFIs for calendar years 2012, 2014, 2015, and 2016. Densberger failed to include her position as Vice President of the Bank on her SFI for calendar year 2016. On June 4, 2018, Densberger filed an SFI for calendar year 2013 and amended SFIs for calendar years 2012 and 2014 through 2017 with the Township. Having highlighted the Stipulated Findings and issues before us, we shall now apply the Ethics Act 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 in relation to the above allegations: The actions of Densberger participating in discussions and actions of the Township Board of Supervisors, which resulted in the Township utilizing First Columbia Bank & Trust as a banking /financial institution, constituted a conflict of interest pursuant to Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1103(a), as First Columbia Bank & Trust is a business with which she is associated as an officerlemployee. The actions of Densberger participating in discussions and actions of the Township Board of Supervisors, which resulted in the appointment/reappointment of Robert Densberger as an as-needed/part-time employee of the Township for calendar year 2015, constituted a technical conflict of interest pursuant to Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. & 1103(a), as Robert Densberger is her husban (member of her immediate family. i. That no violation of Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1103(a), occurred in relation to Densberger participating in discussions and actions of the Township Board of Densber, eer,, 18 -012 Page 27 Supervisors, resulting in the hiring of her husband, Robert Densberger, as an as- needed /part -time employee of the Township for calendar year 2014, as she took no action resulting in her husband's appointment/reappointment. ii. That no violation of Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1103(a), occurred in relation to Densberger participating in discussions and actions of the Township Board of Supervisors, resulting in the hiring of her husband, Robert Densberger, as an as- needed/part-time employee of the Township for calendar year 2017, as any gain realized by her husband ($152.25) is deemed de minimis. That a technical violation of Section 1104(x) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1104(a), occurred by Densberger not having a 2013 calendar year Statement of Financial Interests filed with the Township. d. That a technical violation of Section 1105(b)(5) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1105(b)(5), occurred by Densberger neglecting to include the Township as a source of income upon Statements of Financial Interests filed for the 2012, 2014, 2015, and 2016 calendar years. That a technical violation of Section 1105(b)(8) of the Public Official and Employee Ethics AAct, 65 Pa.C.S. § 1105(b)(8), occurred by Densberger neglecting to include her employment with First Columbia Bank & Trust upon her 2016 calendar year Statement of Financial Interests. That no violation of Section 1105(b)(9) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1105(b)(9), occurred regarding the allegation due to insufficient clear and convincing evidence. Densberger agrees to make payment in the amount of $4,000.0-0 in settlement of this matter payable to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics Commission within thirty (30) days of the issuance of the final adjudication in this matter. To the extent she has not already done so, Densberger agrees to file complete and accurate amended Statements of Financial Interests with Madison Township, through the Pennsylvania State Ethics Commission, for calendar years Densber, er, 18 -012 Page 28 2012, 2013, 2014, 2015, and 2016 within thirty (30) days of the issuance of the final adjudication in this matter. 6. Densberger agrees to not accept any reimbursement, compensation or other payment from Madison Township representing a full or partial reimbursement of the amount paid in settlement of this matter. 7. The Investigative Division will recommend that the State Ethics Commission take no further action in this matter; and make no specific recommendations to any law enforcement or other authority to take action in this matter. 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 2 -3. It ap ears that the Investigative Division in the exercise of its prosecutorial discretion has electeTto no pros those portions of the allegations pertaining to: (1) Section 1104(d) of the Ethics Act; and (2) Densberger's failure to list her office, directorship or employment with R.L. Densberger Hauling Company for calendar years 2012, 2013, 2014, 2015, and 2016. We therefore need not address those particular allegations. In considering the Consent Agreement, we accept the recommendation of the parties for a finding that Densberger's participation in discussions and actions of the Board, which resulted in the Township utilizing the Bank as a banking/financial institution, constituted a conflict of interest pursuant to Section 1103(a) of the Ethics Act, as the Bank is a business with which she is associated as an officer /employee. The Bank is a business with which Densberger is associated in her capacity(ies) as an officer /employee (Vice President and Mortgage Originator). From 2013 through 2017, Densberger repeatedly used the authority of her public office as a Supervisor in matters related to the Township's utilization of the Bank for the provision of various financial services. Densberger's uses of office included: (1�ownship participating in Board votes that approved the Bank as the financial depository for the for 013, 2014, and 2015; R ) making or seconding motions, participating in Board votes, signing Township esolutions, and executing commercial loan applications and /or lease wi h option to purchase agreements pertaining to financing the purchase of Township vehicles and equipment through the Bank; (3) participating in a Board discussion pertaining to moving the funds in two CD accounts at the Bank to new accounts at the Bank, voting to approve closing the two CD accounts, and signing, as a Township representative, signature cards for two new accounts at the Bank; (4) participating in Board discussions with regard to transferring Township State Liquid uels funds from accounts maintained by PLGIT to accounts managed by the Bank, making a motion and voting to transfer funds from the Township's PLGIT General Fund Account and State Liquid Fuels Account to the Bank, and signing the signature card for an account at the Bank into which State Liquid Fuels funds were subsequently transferred or electronically deposited; and (5) making a motion and voting to close the Township's PLGIT accounts and transfer the funds to accounts with the Bank. Based upon the Stipulated Findings and the Consent Agreement, we hold that Densberger's participation in discussions and actions of the Board, which resulted in the Township utilizing the Bank as a banking /financial institution, constituted a conflict of interest pursuant to Section 1103(a} of the Ethics Act, 65 Pa.C.S. § 1103(a), as the Bank is a business with which she is associated as an officer /employee. Dens29 ber, er, 18 -012 agP a We accept the parties' recommendations with regard to Densberger's participation in the hiring/rehiring of her husband, Robert Densberger, as a part -time Township employee for 2015 and 2017. The Stipulated Findings reflect that Densberger participated in the Board vote that approved her husband's hiring /rehiring for 2015. Although the Stipulated Findings do not =rger's the private pecuniary benefit realized by Mr. Densberger as a result of participation in his hiring /rehiring for 2015, based upon the Consent Agreement, it appears that the parties are in agreement that such private pecuniary benefit was greater than de minimis. The Stipulated Findings further reflect that Densberger participated in the Board vote that approved her husband's hiring/rehiring for 2017. However, based upon the Consent Agreement, the parties are in agreement that any gain realized by Mr. Densberger as a result of Densberger's participation in his hiring/rehiring for 2017 (i.e., $152.25) was de minimis. Based upon the Stipulated Findings and the Consent Agreement, we hold that Densberger's participation in discussions and actions of the Board, which resulted in the appointment/reappointment of Robert Densberger as an as- needed /part-time employee of the Township for 2015, constituted a technical conflict of interest pursuant to Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), as Robert Densberger is her husband /a member of her immediate family. We further hold that no violation of Section I I 03(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred in relation to Densberger's participation in discussions and actions of the Board, which resulted in the hiring of her husband, Robert Densberger, as an as- neededlpart-time employee of the Township for 2017, as any gain realized by her husband ($152.25) is deemed to be de minimis. The parties have recommended a finding that no violation of Section 1103(a) of the Ethics Act occurred in relation to the allegation that Densberger participated in discussions and actions of the Board, which resulted in the hiring/rehiring of Mr. Densberger as a part- time Township employee for 2014, for the proffered reason that she took no action resulting in her husband's appointment/reappointment. However, the Stipulated Findings establish that although Densberger abstained when the Board voted to approve Mr. Densberger's hiring /rehiring for 2014, she made a motion to hire /rehire Mr. Densberger for 2014, which constituted a use of the authority of her office as a Supervisor. Nevertheless, we recognize the "give and take" that is involved in the negotiation of a Consent Agreement, as well as the prosecutorial discretion of the Investigative Division. Therefore, we will treat the parties' recommendation for a finding of no violation of Section 1103(a) of the Ethics Act as a "non pros" by the Investigative Division. Accordingly, we hold that no violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred in relation to Densberger's participation in discussions and actions of the Board, which resulted in the hiring of her husband, Robert Densberger, as an as- neededlpart-time employee of the Township for 2014, based upon a non pros by the Investigative Division. Turning to the allegations regarding Densberger's SFIs, we hold that: (1) a technical violation of Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), occurred in relation to Densberger not having an SFl for calendar year 2013 on file with the Township; (2 a technical violation of Section 1105(b)(5) of the Ethics Act, 65 Pa.C.S. § 1105(b} 5), occurred in relation to Densberger neglectingg to include the Township as a source of income upon SFIs filed for the 2012, 2014, 20'I5, and 2016 calendar years; a technical violation of Section 1105(b)(8) of the Ethics Act, 65 Pa.C.S. 1105(b)(8�3) , occurred in relation to Densberger neglecting to include her employment with the Bank upon her SFI Denber, eerr, 18 -012 Page 30 for the 2016 calendar year; and (4) no violation of Section 1105(b)(9) of the Ethics Act, 65 Pa.C.S. § 1105(b)(9), occurred based upon an insufficiency of evidence. As art of the Consent Agreement, Densberger has agreed to make payment in the amount of $4,000.00 payable to the Commonwealth of Pennsylvania and forwarded to this Commission within thirty (30) days of the issuance of the final adjudication in this matter. Densberger has further agreed to not accept any reimbursement, compensation or other payment from the Township representing a full or partial reimbursement of the amount paid n settlement of this matter. Finally, to the extent she has not already done so, Densberger has agreed to file complete and accurate amended SFIs with the Township, through this Commission, for calendar ears 2012, 2013, 2014, 2015, and 2016 within thirty (30) days of the issuance of the final' adjudication 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, per the Consent Agreement of the parties, Densberger is directed to make payment in the amount of $4,000.00 payable to the Commonwealth of Pennsylvania and forwarded to this Commission by no later than the thirtieth (30ffi) day after the mailing date of this adjudication and Order. Per the Consent Agreement of the parties, Densberger is directed to not accept any reimbursement, compensation or other payment from the Township representing a full or partial reimbursement of the amount paid in settlement of this matter. To the extent she has not already done so, Densberger is directed to file complete and accurate amended SFIs for calendar years 2012, 2013, 2014, 2015, and 2016 with the Township, through this Commission, by no later than the thirtieth (30th) day after the mailing date of this adjudication and Order. Compliance with the foregoing will result in the closing of this case with no further action by this Commission. Noncompliance will result in the institution of an order enforcement action. IV. CONCLUSIONS OF LAW; 1. As a Supervisor for Madison Township ( "Township' Columbia County, Pennsylvania, since January 2012, Respondent Michelle Densberger ( "Densberger ") has been a public official sub'ect to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "q, 65 Pa.C.S. § 1101 et seq. 2. Densberger's participation in discussions and actions of the Township Board of Supervisors, which resulted in the Township utilizing First Columbia Bank & Trust as a banking /financial institution, constituted a conflict of interest pursuant to Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), as First Columbia Bank & Trust is a business with which she is associated as an officer /employee. 3. Densberger's participation in discussions and actions of the Township Board of Supervisors, which resulted in the appointment/reappointment of Robert Densberger as an as-needed/part-time employee of the Township for 2015, constituted a technical conflict of interest pursuant to Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), as Robert Densberger is her husbandla member of her immediate family. 4. No violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § '1103(a), occurred in relation to Densberger's participation in discussions and actions of thhe Township Board of Supervisors, which resulted in the hiring of her husband, Robert Densber, er, 18 -012 age Densberger, as an as- neededlpart -time employee of the Township for 2014, based upon a non pros by the Investigative Division. 5. No violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 11 03 a , occurred in relation to Densberger's participation in discussions and actions o t e Township Board of Supervisors, which resulted in the hiring of her husband, Robert Densberger, as an as-needed/part-time employee of the Township for 2017, as any gain realized by her husband $152.25) is deemed to be de minimis. 6. A technical violation of Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), occurred in relation to Densberger not having a Statement of Financial Interests for calendar year 2013 on file with the Township. 7. A technical violation of Section 1105(b)(5) of the Ethics Act, 65 Pa.C.S. § 1105(b)(5), occurred in relation to Densberger neglectin g to include the Township as a source of income upon Statements of Financial Interests filed for the 2012, 2014, 2015, and 2016 calendar years. 8. A technical violation of Section 1105(b)(8) of the Ethics Act, 65 Pa.C.S. § 1105(b)(8), occurred in relation to Densberger neglecting to include her employment with FFirst CColumbia Bank & Trust upon her Statement of Financial Interests for the 2016 calendar year. 9. No violation of Section 1105(b)(9) of the Ethics Act, 65 Pa.C.S. § 1105(b)(9), occurred based upon an insufficiency of evidence. In Re: Michelle Densberger, : File Docket: 18 -012 Respondent Date Decided: 516119 Date Mailed: 5110119 ORDER NO. 1 752 The participation of Michelle Densberger "Densberger ") —as a Supervisor for Madison Township ( "Townshi "), Columbia County, Pennsylvania —in discussions and actions of the Township Board of Supervisors, which resulted in the Township utilizing irst Columbia Bank & Trust as a banking /financial institution, constituted a conflict of interest pursuant to Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), as First Columbia Bank & Trust is a business with which she is associated as an officerlemployee. 2. Densberger's participation in discussions and actions of the Township Board of Supervisors, which resulted in the appointment/reappointment of Robert Densberger as an as-needed/part-time employee of the Township for 2015, constituted a technical conflict of interest pursuant to Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), as Robert Densberger is her husbandla member of her immediate family. 3. No violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103�a), occurred in relation to Densberger's participation in discussions and actions o thhe Township Board of Supervisors, which resulted in the hiring of her husband, Robert Densberger, as an as- needed /part -time employee of the Township for 2014, based upon a non pros by the Investigative Division. 4. No violation of Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), occurred in relation to Densberger's participation in discussions and actions of the Township Board of Supervisors, which resulted in the hiring of her husband, Robert Densberger, as an as-needed/part-time employee of the Township for 2017, as any gain realized by her husband $152.25) is deemed to be de minimis. 5. A technical violation of Section 1104(a) of the Ethics Act, 65 Pa.C.S. § 1104(a), occurred in relation to Densberger not having a Statement of Financial Interests for calendar year 2013 on file with the Township. 6. A technical violation of Section 1105(b)(5) of the Ethics Act, 65 Pa.C.S. § 1105(b)(5), occurred in relation to Densberger neglecting to include the Township as a source of income upon Statements of Financial Interests filed for the 2012, 2014, 2015, and 2016 calendar years. 7. A technical violation of Section 1105(b)(8) of the Ethics Act, 65 Pa.C.S. § 1105(b)(8), occurred in relation to Densberger neglecting to include her employment with FFirst CColumbia Bank & Trust upon her Statement of Financial Interests for the 2016 calendar year. 8. No violation of Section 1102)(9) of the Ethics Act, 65 Pa.C.S. § 1105(b)(9), occurred based upon an insufficiency of evidence. 9. Per the Consent Agreement of the parties, Densberger is directed to make payment in the amount of $4,000.00 payable to the Commonwealth of Pennsylvania and Densberc e,r, 18 -012 Page 33 forwarded to the Pennsylvania State Ethics Commission by no later than the thirtieth (30th) day after the mailing date of this Order. 10. Densberger is directed to not accept any reimbursement, compensation or other payment from the Township representing a full or partial reimbursement of the amount paid in settlement of this matter. 11. To the extent she has not already done so, Densberger is directed to file complete and accurate amended Statements of Financial Interests for calendar years 2012, 2013, 2014, 2015, and 2016 with the Township, through the Pennsylvania State Ethics Commission, by no later than the thirtieth (30th) day after the mailing date of this Order. 12. Compliance with paragraphs 9, 10, and 11 of this Order will result in the closing of this case with no further action by this Commission. a. Noncompliance will result in the institution of an order enforcement action. BY THE COMMISSION, , � a