HomeMy WebLinkAbout97-625 ConfidentialSTATE ETHICS COMMISSION
309 FINANCE BUILDING
P.O. BOX 11470
HARRISBURG, PA 17108 -1470
TELEPHONE (717) 783 -1610
ADVICE OF COUNSEL
November 18, 1997
97 -625
Re: Public Official /Employee, Superintendent, School District, FIS, Disclosure, Loan,
Judgment Note, Equity, Residence, Immediate Family, In -Law.
This responds to your letters of October 13 ,1997 and October 23, 1997 by
which you requested advice from the State Ethics Commission.
Issue: Whether the Public Official and Employe Ethics Law requires a School
Superintendent to file amended Statements of Financial Interests to disclose various
loans related to the construction of his home, which loans were secured by judgment
notes.
Facts: You have been authorized by Mr. A to request an advisory on his behalf.
Mr. A is the Superintendent of School District B.
Recently, Mr. A was contacted by the Auditor General's Office relative to a loan
which he and his wife had taken out in October, 1994. It was suggested by the
Auditor General's Office that the loan should have been reported on Mr. A's Statement
of Financial Interests (FIS). You submit the following factual background.
In 1992, Mr. and Mrs. A finished construction of their personal home. During
the course of construction, numerous problems had arisen with the contractor.
Ultimately, the contractor was thrown off the job by the bank which had provided the
primary mortgage on the premises. Because of such problems, the expenses on the
home were approximately $40,000 more than had originally been contemplated.
As a result, Mr. and Mrs. A borrowed $25,000 from their credit union and
$16,000 from their brother -in -law and sister -in -law to offset some of that expense.
Again, in 1994, Mr. and Mrs. A borrowed $10,000 from Mr. and Mrs. C.
You state that all of the above loans were necessitated by the construction of
Mr. and Mrs. A's new home. All of these loans were secured by judgment notes
Confidential Advice of Counsel, 97 -625
November 18, 1997
Page 2
which were signed by both Mr. and Mrs. A so that they could be, at the option of the
creditors, recorded against the marital residence.
The above loans were not included on Mr. A's FIS's for the years they were in
existence. You proffer that the reason that these loans were not disclosed on the
FIS's was that they were "secured by the equity in the personal residence." (Letter
of October 13, 1997 at 1).
The $25,000 credit union loan was paid off in April, 1997 when a second
mortgage was taken against the house to consolidate existing debts. At that time, a
substantial payment was made on the loan from Mr. and Mrs. C using the proceeds
of the mortgage. The balance of the note has since been paid in full. The loan from
Mr. and Mrs. A's brother -in -law and sister -in -law was, and is, being repaid monthly.
You state that Mr. A did not believe that it was necessary to disclose on his FIS
a loan that was secured by a judgment note, which you characterize as being against
the equity in his primary residence. However, you state that Mr. A does not want to
be in violation of the Ethics Law and is prepared to file amended FIS's if it is
determined that he must do so.
Discussion: It is initially noted that pursuant to Sections 7(10) and 7(11) of the
Ethics Law, 65 P.S. §§407(10), (11), advisories are issued to the requestor based
upon the facts which the requestor has submitted. In issuing the advisory based upon
the facts which the requestor has submitted, the Commission does not engage in an
independent investigation of the facts, nor does it speculate as to facts which have not
been submitted. It is the burden of the requestor to truthfully disclose all of the
material facts relevant to the inquiry. 65 P.S. §§407(10), (11). An advisory only
affords a defense to the extent the requestor has truthfully disclosed all of the material
facts.
It is further noted that pursuant to Sections 7(10) and (11) of the Ethics Law,
an opinion /advice may be given only as to prospective (future) conduct. If the activity
in question has already occurred, the Commission may not issue an opinion /advice but
any person may then submit a signed and sworn complaint which will be investigated
by the Commission if there are allegations of Ethics Law violations by a person who
is subject to the Ethics Law. In this case, although your inquiry involves past FIS's,
there is a question as to future conduct. Specifically, you inquire as to whether Mr.
A would be required to file amended Statements of Financial Interests. Thus, this
Advice is issued in order to address the proposed future conduct of Mr. A in that
regard.
As Superintendent for School District B, Mr. A is a public official as that term
is defined in the Public Official and Employe Ethics Law ( "Ethics Law "), and hence he
is subject to the provisions of that law.
Pursuant to Section 4(a) of the Ethics Law, Mr. A is required to file a Statement
of Financial Interests with School District B each year he holds the position as
Superintendent and the year after he leaves said position. 65 P.S. §404(a).
The financial disclosure which Mr. A is required to provide in the Statement of
Financial Interests form is statutorily mandated in detail at Section 5 of the Ethics Law,
Confidential Advice of Counsel, 97 -625
November 18, 1997
Page 3
65 P.S. §405. The pertinent subparagraph of Section 5 which pertains to your inquiry
provides as follows:
(b) The statement shall include the following information for the
prior calendar year with regard to the person required to file the
statement.
65 P.S. §405(b)(4).
The term "immediate family" is defined in the Ethics Law as follows:
Section 2. Definitions
65 P.S. §402.
(4) The name and address of each creditor to
whom is owed in excess of $5,000 and the interest rate
thereon. However, loans or credit extended between
members of the immediate family and mortgages securing
real property which is the principal or secondary residence
of the person filing shall not be included.
"Immediate family." A parent, spouse, child, brother
or sister.
In applying the above provisions of the Ethics Law to the facts which you have
submitted, it is clear that a brother or sister is a member of immediate family, but a
brother -in -law or sister -in -law is not included in the definition.
It is also clear that a judgment note is not a mortgage and consequently, would
not fall within the exception to disclosure for "mortgages securing real property which
is the principal or secondary residence of the person filing." Consequently, the mere
fact that a debt is secured by a judgment note would not relieve a public official /public
employee from the statutory duty to disclose the name and address of the creditor and
the interest rate.
With regard to the 1992 loan of $25,000 from the credit union, based upon the
facts which have been submitted, such loan was secured by a judgment note and not
by a mortgage. Therefore, that debt would be subject to disclosure on the Statement
of Financial Interests form.
With regard to the 1992 loan of $16,000 from Mr. and Mrs. A's "brother -in -law
and sister -in -law," it is noted that the facts as submitted preclude a determination of
whether a member of Mr. A's immediate family was a creditor. It is not clear whether
either of the individuals from whom these funds were borrowed was a brother or sister
of Mr. A. The relationship such individuals may have with Mrs. A is irrelevant in that
she is not the person required to file the Statement of Financial Interests. In the
absence of more precise facts, this Advice shall be limited to providing the following
general guidance. Any such debt obtained exclusively from member(s) of Mr. A's
immediate family need not be disclosed. On the other hand, any such debt for which
Confidential Advice of Counsel, 97 -625
November 18, 1997
Page 4
any one or more of the creditors is not a member of Mr. A's immediate family must
be disclosed.
With regard to the 1994 loan of $ 10,000 from Mr. and Mrs. C, the facts as
submitted do not represent that such individuals are members of Mr. A's immediate
family. Therefore, the debt would be subject to disclosure on the Statement of
Financial Interests.
Finally, with regard to the 1997 second mortgage taken against the house for
the purpose of consolidating existing debts, based upon the facts submitted, that debt
would be a mortgage against the principal residence. It would therefore be within the
statutory exceptions to disclosure and would not be subject to disclosure on the
Statement of Financial Interests.
In response to your specific inquiry, amended Statements of Financial Interests
should be filed. The Ethics Law requires that the forms be kept on file for five years,
65 P.S. §407(9). The earliest of the reportable loans were taken out in 1992. Such
loans would have properly been disclosed in the Statement of Financial Interests due
May 1, 1993. Such forms would still be within the five year period for remaining on
file for public disclosure and copying. Disclosure must be made as to each year such
loans were in existence:
Conclusion: As Superintendent of School District B, Mr. A is a public official
subject to the provisions of the Ethics Law, and specifically the requirement to file
Statements of Financial Interests. A judgment note is not a mortgage, and the mere
fact that a debt is secured by a judgment note does not relieve a public official /public
employee from the statutory duty to disclose the name and address of the creditor and
the interest rate pursuant to 65 P.S. §405(b)(4). Mr. A is advised to file amended
Statements of Financial Interests to disclose: the 1992 loan in the amount of $25,000
from his credit union, which loan was secured by a judgment note and not by a
mortgage; the 1992 loan of $16,000 from Mr. and Mrs. A's "brother -in -law and sister -
in -law, to the extent that any such creditor was not a member of Mr. A's immediate
family; and the 1994 loan of $10,000 from Mr. and Mrs. C. Disclosure must be made
as to each year such loans were in existence. The 1997 second mortgage taken
against the A's house need not be disclosed. Lastly, the propriety of the proposed
conduct has only been addressed under the Ethics Law.
Pursuant to Section 7(11), this Advice is a complete defense in any enforcement
proceeding initiated by the Commission, and evidence of good faith conduct in any
other civil or criminal proceeding, providing the requestor has disclosed truthfully all
The material facts and committed the acts complained of in reliance on the Advice
given.
This letter is a public record and will be made available as such.
Finally, if you disagree with this Advice or if you have any reason to
challenge same, you may appeal the Advice to the full Commission. A personal
appearance before the Commission will be scheduled and a formal Opinion will
be issued by the Commission.
Confidential Advice of Counsel, 97 -625
November 18, 1997
Page 5
Any such appeal must be in writing and must be actually received at the
Commission within thirty (30) days of the date of this Advice pursuant to 51
Pa. Code §13. 2(h 1. The appeal may be received at the Commission by hand
delivery, United States mail, delivery service, or by FAX transmission (717 -787-
0806). Failure to file such an appeal at the Commission within thirty (30) days
may result in the dismissal of the appeal.
S,u cerely,
Vincent opko
Chief Counsel