Loading...
HomeMy WebLinkAbout888 MolnarSTATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 • In Re: John R. Molnar : File. Docket: 92- 012 --C2 - : Date Decided: June 28, Date Mailed: June 30, 1993 Before: James M. Howley, Chair Daneen E. Reese, Vice Chair Dennis C. Harrington Roy W. Wilt Austin M. Lee Allan M. Kluger Joseph W. Marshall, III The State Ethics Commission received •,a complaint regarding a possible violation of the State Ethics Act, Act 9 of 1989, 65 P.S. S401 et sec. -Written no of the specific allegation (s) was served at the; commencement of the investigation. A Findings Report was issued and - served, ':Yipon completion..of-the investigation, which constituted the :Complaint by the Investigtiontpivision. An Answer was filed and a hearing waived. AConsect `Order was submitted by the parties-.:t.° the Commissim for constideration which was subsequently approved. This adjudication 01 _the Commission is hereby issued which sets forth the individual Allegations, Findings of Fact, Discussion, Conclusions of Law and Order. This adjudication is final and will be -made available as a public document fifteen days after issuance. However, reconsideration may be requested which will -defer public release of this adjudication pending action on the 'request by the Commission. A request for reconsideration, however, does not affect the finality of this adjudication. A reconsideration request must be received at this Commission within fifteen days of issuance and must include a detailed explanation of the reasons as to why reconsideration should be granted in conformity with 51 Pa. Code §21.29(b) . The files in this case will remain confidential in accordance with Act 9 of 1989, 65 P.S. §408(h) during the fifteen day period and no one unless the right to challenge this'Order is may violate confidentiality by releasing, discussing or circulating this Order. However, confidentiality does not preclude discussing this case with an attorney at law. -_ Any person who violates confidentiality of the Ethics Act is guilty of_ a. misdemeanor subject to ar fine -of' not more than $1,000 or imprisounent, fbr not more than one year, 65 P.S. §409(e). MQ 24- 012 -C2 Page .2 I. LEGATION: That John R. Molnar violated the following sections of the Public Officials and Employees Ethics Act, (Act 9 of 1989), when a firm With `which he is associated, Molnar Service Company, contracted with Springdale Borough without an open and public processi 'and when he voted to make payments to Molnar Service Company: Section 3. Restricted Activities. (a) No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65. P.S. 403(a). (f) No public Official or public employee or spouse or child or any business in which the person or his spouse or child is associated shall enter into any contract valued at $500.00 or more with the governmental body with which the public official or public employee is associated or any subcontract valued at $500.00 or more with any person who has been awarded a contract With the governmental body with which the public official or public employee is associated, unless the contract has been awarded through an open and pudic process, including prior publ -id notice and subsequent public disci -osire of all proposals considered and contracts awarded. In such a case, the public official- or public employee shall ,riot have any supervisory or overall responsibility for the implementation or administration• of the contract piny contract or subcontract made in violation of this subsection -shall be voidable by a court of competent jurrsdiction if the is comtnerced within ninety days of` the' making of the Contract or subcontra°ci. 65. P . - S . 4O-3 (f) . That John R. Molnar- -, as a Springdale Borough- Cou failed to-file a Stater ent. of Financial Interest by Ma ' 1:., 1590, for calendar year 1989, iii violation' of the following provision of Act 9 of 1-98.9: Section 4 ..State3nent' of. f .naric aj - in'teres s required toy he - filed (•a) Each public official ° of= 4 Commonwealth shall file a statemeff at Molnar, 92-012-C2 Page 3 financial interests for the preceding calendar year with the commission no later than May 1 of each year that he holds such a positiow and of the year after he leaves such a position. Each public employee and public official of the Commonwealth shall file a statement of'' financial interests for the preceding calendar year with the department, agency, body or bureau in which he is employed or to which he is appointed or elected no later than May 1 of each year that he holds such a position and of the year after he leaves such a position. Any other public employee or public official shall file a statement of financial interests with the governing authority of the political subdivision by which he is employed or within which he is appointed or elected no later than May 1 of each year that he holds such a position and of the year after he leaves such a position. Persons who are full -time or part -time solicitors for political subdivisions are required to file under this section. 65 P.S. §404(a). II. FINDINGS: 1. John R. Molnar serves as a member of Springdale Borough Council. a. Molnar was appointed to council on December 30, 1988. b. Molnar previously served on council during the 1970's and early 1980's. c. Molnar has been appointed Council President annually since January, 1989. 2. Molnar Service Company is in the heating and air - conditioning business. - L a. The business address is 944 Lincoln Avenue ", Springdale, PA. b. The company services both residential and commercial customers. c. Council Member John Molnar, Sr., operated Molnar Service Co. until 1979. d. Molnart s son, Jahn R . ,Mt 1na .Jr-.`- reformed Molnar Service Co .: _. in :l .a-pproximate1y . /981 utilizing . - a . :separate tax Molnar, 92-012-C2 Page 4 identification number. e. Around 1987, Council Member John Molnar Went . tc work for his soh i John R. Molnar, Jr. at Mblnar SerVice Company. 3. Article of Incorporation, on file with the Penns Department of State, indicate the followin4 fibr the Molnar Service Company. a, Date of incorporation: June 25, 192. b. Incorporators: 500 shares common Stock eaCh; John R. Molnar 426 James Street Springdale, PA 15144 John R, Molnar, Jr. 411 North Street Springdille, PA 15144 SedretarY=Treasurdi President c. BUSin@ss address: 944 Linodln kienUe, Springdale, PA 15144, d. The corporation has never filed a cdrpbrate tax return or had any corporate meetings. 4. Allegheny County Deed Registry and tax recofds indidate,that Council Member John R. Molnar and his Wife; Donna, L. Molnar, own the building and property at 944 Lincoln Avenue, the location of Molnar SerVide Company. 5. Molnar Service Company performed heating and-air conditioning repair and services for Springdale Borough. 6. Springdale Borough had three building fOf which it is responsible: A municipal Complex., a borough garage and the water plant. a. •The municipal complek consists of a gymnadiliff, borough offices, police station- and comMunity center. b. Maintenance and upkeep is handled by the Proper Chairman, Alvin Shodp di in his absence ihe B�i Secretary. 7. Heating and air conditioning repairs and SerVice lime; tYltitneti without bids. a. Other services including' pluMbin4, electrical, 4e.A#AI contracting and automobile repair services are Obtained Molnar, 92- 012 -C2 Page 5 without bids by borough employees. 8. Springdale Borough Council meeting minutes do not reflect any official action taken by Council to hire a heating and air conditioning company for borough repair work. a. Borough council minutes do not action taken for the hiring of any of the services outlined in 7(a). 9. Molnar Service Company maintains two accounts at Southwest National Bank: Business account #46- 070362 and payroll account 46- 083243. a.. Signatories on these accounts were John R. Molnar, Jr., and Donna L. Molnar from September 16, 1983, through September 26, 1991. b. Signatories on these accounts were changed to John R. Molnar Jr., and Michelle A. Smajda on September 26, 1991. ( 1 Michelle A. Smajda is the daughter of John R. Molnar, Sr. c. Regular payments were made from 070362, into payroll account #46- 10. Council Member John R. Molnar, Sr., is the Molnar Service Company, receiving account #46- 083243. a. Weekly net payments totalled: YEAR 1988 1989 1990 1/91 -7/91 8/91 9/91 -1/92 1/92 -6/92 WEEKLY $459.74 $460.34 $460.50 $460.50 $483.57 $474.75 $477.27 business account #46- 083243. a salaried employee of regular payments from ANNUAL $ 2,298.70 $ 23,477.34 $ 23,024.84 $ 24,755.28 $ 12,406.50 b. Forty -two payroll checks payable to Council Member John R. Molnar, Sr. were deposited in and credited to Pittsburgh National Bank account #02697032; Molnar Rental & Leasing Company. c. The remaining payroll checks issued to Molnar,. Sr., were cashed or deposited by John Molnar or Michelle Molnar (SiTrajda). Molnar, 92- 012 -C2 Page 6 11. Three loan re- payments were made to Council Member John R. Molnar, Sr., from Molnar Service Company business account .,(46- 070362) as follows: Check # Date A1Pr 7790 9/14/90 $1,800.00 8988 8/12/91 $1,500.00 9555 1/13/92 $5,400.00 a. The reverse side of check #9555 was deposited into Molnar Rental & Leasing account #02697032 (Pittsburgh National) . (Refer to Finding #13). 12. Molnar Rental & Leasing Company is a partnership between John R. Molnar, Sr., and his wife Donna L. Molnar. a. Molnar Rental & Leasing operates the property located at 944 Lincoln Avenue, Springdale, PA. • b. This is the property that houses Molnar Service Company. 13. Molnar Rental & Leasing Company received monthly or bi- monthly rental payments from Molnar Service Company account #46- 070362 for the use of 944 Lincoln Avenue as follows: a. YEAR AMOUNT 1988 $ 2,250.00 (From November) 1989 $ 20,250.00 1990 $ 25,705.38 1991 $ 29,700.00 1992 $ 11,742.00 (To May) b. A signed lease was in effect for the rental of this property. 14. All payments from Molnar Service Company were deposited in and credited to Pittsburgh National. Bank account #026970321 Molnar Rental & Leasing Company. a. The checks issued from Molnar Service Company to Molnar Rental. & Leasing Company (for rent) were disbursed from the same account into which the Borough funds were deposited. 15. Between February~ 17 , 1589, and. October- 1, 1992, Molnar Service Company was utilized by the Borough 110 times for repairo, Breakdown by year: 1989 17 Molnar, 92- 012 -C2 Page 7 1990 45 1991 39 As of 10/1/92. 9 16. Borough financial records include disbursements to the Molnar Service Company for service repairs on faulty equipment. a. All of the checks contain the facsimile signature of John R. Molnar as council president. The checks were stamped by the borough secretary. b. The back side contains the deposit stamp of the Molnar Service Company with the following: Pay to the order of Southwest National Bank of PA For Deposit Only Molnar Service Co. 043303887 46 070362 c. 46070362 is Molnar Service Company's business account. 17. Springdale Borough records include repair invoices from the Molnar Service Company, 944 Lincoln Avenue, Springdale, PA. 15144. Invoices breakdown charges by parts and labor. Individual invoices o'er $500.00 include: .. Invoice Date Parts Labor Total 10/24/89 11/20/89 12/01/$9 12/29/89 01/31/90 9,5114/90 03/05/91 03/11/91 43/12/91 03/15/91 11/20 Totals: a. 1909 . $ 9,847.11 $ 2.8.92 $ 239.0.0. $ 537.92 2,585.28 203.60 2,788.28 2,553.62 96.00 2,649.62 5 64.00 578.00 2,304.00 128.40 2,432.00 2 368.00 2,733.74 420.97 586.25 1,007.22 619.30 437.50 1,056.80 335.65 218.75 554.40 432.73 148.75 581.48 503.43 87.50 590.93 $12,933.64 $2,576.75 $15,510.39 18. Springdale Borough records include 1099 miscellaneous income statements issued to Molnar Service Company, 944 Lincoln Avenue, Springdale, PA 15144. These include all repairs performed (both over and under $500): Molnar, 92- 012 -C2 1?'e 8 b. 1990 $1,0,105.26 c. 1.99 $ 8,154.33 19. Borough payments to the Molnar Service Companr went kilto Molnar Service Company business account #46- 071162.. a. John Molnar, Sr., received 'loam, rental, and reimbursement payments from this account. ( Refeer to Finding #12, 14). b. This account was used to fund Molnar Service Company's payroll account #46- 083243 which Molnar, Sr., drew a salary from. (Refer to Finding #10). 20. Bills payable are compiled into the borough's monthly treasurer's report. a. Treasurer's reports are voted on in their entirety. b. Roll call votes were not taken to approve treasurer reports. c. Bills are paid prior to the approval of the treasurer's report. This has been a borough practice since approximately 1974. 21. Council meeting minutes do not include any recorded abstentions on the part of Molnar regarding the treasurer's report. a. Molnar did not vote on the treasurer's report. 22. Molnar states that he does not participate in council voting action unless a roll call vote is taken. a. Molnar denies participating in the approval o treasurer's reports. Molnar contends that he keeps quiet when the voice vote is taken. b. 23.. Treasurer reports are included in borough. council members monthly' meeting packets. a, • Council members generally receive their meeting packets several days prior to the meeting but have reined_ packets the day prior to or the day of the. meeting. 24. Council members,. Mark. Stanton, Robert Gneiting and Rudolph: Kubecka, informally questioned the relationship between Molnar, 92- 012 -C2 Page 9 council President Molnar and the Molnar Service Company. a. Meeting minutes do not include any recorded discussion on the matter. 25. Borough Solicitor C. Vidra rendered a written opinion on April 2, 1991 to council president John Molnar. a. The opinion was in response to an inquiry by Molnar concerning his position as an employee of the Molnar Service Company. b. Vidra based his opinion in part on his understanding that the Molnar Service Company does some "sporadic" or "occasional" work, rather than routine maintenance for the borough; and that Molnar's maintenance charges did not exceed $500.00. c. Vidra advises Molnar that the provisions of the Ethics Law apply to him because of his employment and the definition of immediate family. d. Vidra recommended bids be sought for a monthly maintenance contract. e. Regarding voting, Vidra paraphrased the State Ethics Act, "The employee or official in question may vote on the contract only if the vote is needed to break the tie or if his vote is needed to make a majority-or other required vote attainable ". In these situations, the person involved must publicly disclose his interest and may not have any supervisory or overall responsibility for the implementation or administration of the contract. 26. Solicitor Vidra was unaware of the volume of business that was being done with the Molnar Service Company when he issued Molnar, Sr., the opinion. 27. No action was taken on any of Solicitor Vidra's recommendations. a. No maintenance contract was put out for bid. 28. Molnar Service Company continued to service Springdale Borough. a. Molnar, Sr., continued to draw a salary from the business. Findings 29 -31 relate to the second allegation. Findings #1 -- -through 2t are incorporated by reference. Molnar, 9..012 -C2 Page 10 2,, 8gr9ugh records do not include any Statements of Financial Interest filed by May 1, 1990, . for calendar year 1989. 30. fitatements .ot Financial Interest on file with Springdale Borough include the following filings for John R. Molnar: a. Calendar year: 1988 Filed: 3/30/89 on SEC Form 1/29 Position: Councilman Occupation: H.V.A.C. Service Engineer Creditors: South West National Bank, Tarentum, PA 11.5% Direct /Indirect Income: Molnar Lincoln, Springdale, PA; Molnar Lincoln, Springdale, PA Financial Interest in any Busin Leasing All other financial interest: None b. Calendar year: 1989 No forms filed Service Company, 944 Rental & Leasing, 944 ess: Molnar Rental & c. Calendar year: 1990 Filed: 3/25/91 on SEC Form 1/90 Position: Council member Profession: Steamfitter Creditors: PNB, Pittsburgh, 12.75% Direct /Indirect Income: Molnar Service Company, 944 Lincoln Avenue, Springdale, PA; Molnar Rental & Leasing, 944 Lincoln Avenue, Springdale, PA Office /Directorship or Employment in any Bu ineSS: Molnar Rental & Leasing, partner Financial Interest in any business: Molnar Rental & Leasing, partner, 944 Lincoln Avenue, Springdale, P c, Calendar Year: 1991 Filed: 3/10/92 on SEC Form 1/92 Position: Councilman Occupation: H.V.A.C. Service Engineer Real Estate Interest: 944 Lincoln Avenue, Springdale, 426 James St. Springdale Creditors: PNB 8.5 %, Prime + 1 112 %, 10.5% Direct /Indirect. Income: Molnar Service Co., • Molnar Rental & Leasing Qf /Directorship or Employment in any BuainesS: Molnar Rental & Leasing, Partners Financial Interest in any business:. Molnar Rental & Leasing, Partner All other Financial Interest:. None 31. Council. Member John R. Molnar is am employee and corporate Molnar, 92- 012 -C2 Page 11 officer, as secretary- treasurer, for Molnar Service Company. a. Council Member John R. Molnar owns the building that Molnar Service Company rents. III. DISCUSSION: As a Springdale Borough Council Member, John R. Molnar, hereinafter Molnar, is a public official as that term is defined under Act 9 of 1989. 65 P.S. 5402. As such, his conduct is subject to the provisions of the Ethics Law and the restrictions therein are applicable to him. Initially, it is noted that Section 9 of Act 9 of June 26, 1989 provides, in part, as follows: This amendatory act shall not apply to violations committed prior to the effective date of this act, and causes of action initiated for such violations shall be governed by the prior law, which is continued in effect for that purpose as if this act were not in force. For the purposes of this section, a violation was committed prior to the effective date of this act if any elements of the violation occurred prior thereto. Since the occurrences in this case transpired' after the effective date of Act 9 (June 26, 1989), we must' apply the provisions of Act 9 to determine whether the Ethics Act was violated. Under Section 3(a) of Act 9 of 1989 quoted above, a public official /employee shall not engage in conduct that constitutes a conflict of interest. The term "conflict of interest" is defined under Act 9 of 1989 as follows: Section 2. 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. "Conflict" or "conflict of interest" does not include an action having ¥ci:nar., 92- 012 -C2 Page 22 a de minimis economic impact or which affects to the same8gree a class consisting of . the general public or a subclass cohsisting of an industry, occupation or other group which includes the . pUb1 - ic official or public employee, a member or his immediate family or a business with which he or a member of his immediate family is associated. 65 P.S. 4402. In addition, Section 3(f) of Act 9 of 1989 s:pecifica .ly provides in p part that no public official /employee or spouse Or child or business with which he or the spouse or child is associated may enter intt a contract with his governmental body valued at five hundred dollars or more or any subcontract valued at five hundred dollars or more with any person who has been awarded a contract with the governmental body with which the public official /employee is associated unless the contract is awarded through an open and public process. Section 4(a) of the Ethics Law quoted above requires that each public official /employe must file a Statement of Financial Interests (FIS) for the preceding calendar year that he hdlds such position and for the year after he leaves such position. The issues before us are whether Molnar Violated tither Section 3(a) or Section 3(f) of Act 9 of 1989 as to services which were performed by Molnar Service Company for the Borough without an open and public processes and secondly whether Molnar violated Section 4 as to the failure to file an FIS for the calendar year 1989. The findings reflect that Molnar has been a Member _9f Springdale Borough Council since his appointment in Decern er, 1918: In a private capacity, Molnar is associated with the Molnar Servr Company, a heating' and air conditioning business operated by Moln until 1979. In 1981, a new tax identification innitber for Mo'lntr Service was obtained for Mal=nar's Son, John R. Molnar Jr.; 1987, Molnar went to work for his son at that company. Molrt' Service- Company was incorporated in June, On with Main designated as the Secretary /Treasu -rer and 944 Avenue; Springdale,. Pennsylvania as the business address. The business' location fox Molnar Service Company is at a property owned 1 Molnar- and his wife. The, work, that Molnar Service Company performed for Springdal* Borough' was done without bidd=ing . However • vailotts Boro services including plumbing electrical , general= cotitra�i:"ng, . automobile repair services are obtained wi.itiout• bids' throu *ly contacts made by Borough= employees. A review: of the Borough Council meeting minutes reflect no official action- b ' Council' to hire any heating and air conditioning cbiapariy for Bt tough repair Molnar, 92- 012 -C2 Page 13 work. Borough financial records reflect disbursements to Molnar Service Company for service and repairs of Borough equipment. The disbursement checks contain the facsimile signature of Molnar as Council President. As to the bill payment process, invoices are compiled on a monthly basis by the Borough Treasurer in a report which is voted on in its entirety. Roll call votes are not taken to approve the Treasurer's reports in that bills are paid prior to the approval of said report. As to bill approvals, the Council meeting minutes do not include any recorded abstentions on the part of Molnar regarding the Treasurer's report even though Molnar did not vote. On one occasion several other Council Members questioned Molnar regarding his relationship with Molnar Service Company. The Borough Solicitor rendered Molnar a written opinion on April 2, 1991 about his position as an employee of Molnar Company; however, the Solicitor's opinion was based, upon his that the facts were such. that Molnar Service Company was only Sporadically used- for routine maintenance with ... charges not exceeding $:SAO. The Solicitor was unaware of. the volume of business which was done by Molnar Service. Company nevertheless recommended tiat.such monthly maintenance contracts be put out for bid. Finally=,. as to the relationship between Molnar and Molnar Service Company from 1988 forward, it does appear that Molnar was a salaried employee of the company. Further, Molnar and his wife ran a partnership under the name of Molnar Rental and Leasing Company which received a monthly rental for Molnar Service Company for the use of 944 Lincoln Avenue. Various Borough checks in payment to Molnar Service Company were deposited in Pittsburgh National Bank account from which disbursements from Molnar Service Company were paid to Molnar Rental and Leasing Company as rental payments. As to the FIS's which Molnar filed, a review of the Borough records reflects filings of FIS's for the calendar years 1988, 1990 and 1991 but not for the calendar year 1989. In applying the provisions of the Ethics_ Law to the above findings, we do not find a violation . of Section: 3(a) of Act 9 of 1989. In order to sustain a violation, the findings must establish a use of authority of office to obtain.a private pecuniary benefit for Molnar, a member of his immediate family, or a business with which he or a member of his immediate family is associated. The terms "immediate family" and "business with which associated" are defined as follows: Section 2. Defin.itions ggigm., 92-012-C2 Pte 14 sguainess with which he i associated." Affy bUsiftess ins wh&th the persam or a member of the persOn's immediatel family is a dixfttor, offiCer, owner employee or has a filii.ancial interest. "Immediat* family." A parent, spouse, child, brdtheir ar ffister. P.S. §402. It is cleat that the payments made by the Borough to Molnar Service Company constitute a private pecuniary benefit. In additioh, the private pecuniary benefit inured to Molnar, a member cif his in%mediate, and a business with which he and a member of his liftediat es. family is associated.. However, there is no showing of feedOrd that there was a use Of authority of office by Molnar which i§ & techli§ite element for egtahlishing a violation. Therefore, we flAS A* Violation as to gection 3(a) of At 5 of 1999. A4 to Sedtion 3(f) of Act 9 of 1989, we find a technical Vidlatien in that Molnar Service Company, a business with which Mdlfiett &fid his ohildren, John, Jr, and Michelle, are associated, pefidfted contractual services for the Borough which were in excess df U and were it awarded through an open and public process. In his regard, other services for the Borough, such as plumbing, eiedttical, general contracting, and automotive repair services, Were also done without bids through contacts initiated by Borough eMpldyees. Under the totality of these circumstances, we find a technical violation. Our decision is consonant with Chermak, Order 887, whereih we found a technical violation of Section 3(f) of the Ethics under circumstances where the automotive repair business of a Mbnicipal official both prior to and during his tenure on council provided services to the borough without an open and public process where the practice of the borough had been to award such contracts without bidding. as tO the PIS allegation, the record reflects that Molnar did not file an EIS for the calendar year 1989. On that basis, we find a violation occurred when Molnar failed to file an FIS for the calendar year 1989 as required by Section 4 of the Ethics Law. Molnar is directed within thirty (30) days of issuance of this Order t� filo an PIS for the calendar year 1989. Cbmpliande with the foregoing will result in the closing of this case with no further aCtiOn. Failure to comply will result in a directive of this Commission to institute an order enforcement action. TV. CONCLUSIONS. OF_LAW: 1. John R. Molnar, as a Springdale Borough Council Member, is a Molnar, 92- 012 -C2 Page 15 public official subject to the provisions of Act 9 of 1989. 2. Molnar did not violate Section 3(a) of Act 9 of 1989 as to services performed for the Borough by Molnar Service Company, a business with which he and a member of his immediate family is associated, in that there was no use of authority of office. 3. A technical violation of Section 3(f) of Act 9 of 1989 occurred when Molnar Service Company, a business with which Molnar and his child are associated, contracted with Springdale Borough for services in excess of $500 without an open and public process. 4. A violation of Section 4 of Act 9 of 1989 occurred when Molnar did not file a Financial Interests Statement for the calendar year 1989. In Re: John R. Molnar File Docket: 92-4312-C2 Date Decided ;, urta 28. 19/3 Date Mailed,: June.. 30, 1993 ORDER NO. 888 1. John R. Molnar, as a Springdale Borough Council Member, did not violate Section 3(a) of Act 9 of 1989 to services performed for the Borough by Molnar Service Company, a business with which he and a member of his immediate family is associated,, in that there was no use of authority of office. 2. A technical violation of Section 3(f) of Act 9 of 1989 occurred when Molnar Service Company, a business with which Molnar and his child are associated, contracted with Springdale Borough for services in excess of $500 without an open and public process. 3. A violation of Section 4 of Act 9 of 1989 occurred when Molnar did not file a Financial Interests Statement for the calendar year 1989. 4. Molnar is directed within thirty (30) days of issuance of this Order to file a Statement of Financial Interests for the calendar year 1989. 5. Compliance with Paragraph 4 will result in the closing of this case with no further action. 6. Failure to comply with Paragraph 4 will result in a directive of this Commission to institute an order enforcement action. BY THE COMMISSION, JAMES M. HOWL . 2R