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In Re: Eli Silberman,
Respondent
t ti ��r ti
STATE ETHICS COMMISSION
FINANCE BUILDING
613 NORTH STREET, ROOM 309
HARRISBURG, PA 17120 -0400
File Docket:
X -ref:
Date Decided
Date Mailed:
FACSIMILE: 717 -737 -0806
WEBSITE: www.ethirs.pa.gov
18 --032
Order No. 1753
516119
5113119
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 seg., 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." 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.
I. ALLEGATIONS:
That Eli Silberman, a public officiallpublic employee in his capacity as a Member of
the Council of Trustees of West Chester Universityy of the Pennsylvania State System of
Higher Education, violated Sections 1104(a) and 1105(a) of the State Ethics Act (Act 93 of
1998) when he failed to timely file Statement of Financial Interests forms for the 2013,
2015, 2016, and 2017 calendar years; and when he subsequently filed backdated
Statement of Financial Interests forms for calendar years 2013, 2015, 2016, and 2017 to
give the impression that forms for those calendar years were timely filed.
II. FINDINGS:
1. Eli Silberman ( "Silberman ") has served as a Member of the West Chester University
Council of Trustees since June 5, 2007.
2. West Chester University is part of the Pennsylvania State System of Higher
Education ( "PASSHE ").
a. PASSHE was established by statute on July 1, 1983.
b. PASSHE is comprised of fourteen Pennsylvania universities.
Silberman, 18 -032
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C. PASSHE serves approximately 105,000 students and is the largest provider
of higher education in the state of Pennsylvania.
3. The West Chester University Council of Trustees is comprised of eleven Members.
a. Council of Trustees Members are appointed by the Governor.
b. The Council of Trustees convenes on a quarterly basis (every three months).
C. Council of Trustees Members are not compensated for their service.
d. The Council of Trustees is responsible for strategic planning and oversight of
the West Chester University President.
4. In addition to serving as a Member of the West Chester University Council of
Trustees, Silberman has served as a Member of the Chester County Agricultural
Land Preservation Board since January 2003.
a. As a Member of the Chester County Agricultural Land Preservation Board,
Silberman files Statement of Financial Interests forms directly with the
Chester County Commissioners Office.
5. Statement of Financial Interests forms are required to be filed annually by all
elected and appointed public officials of the Commonwealth.
a. The forms are required to be filed by no later than May 18t of each year that a
public official holds public office.
b. The Statement of Financial Interests form requires filers to report specified
financial information pertaining to the preceding calendar year.
6. The State Ethics Commission annually contracts for the printing of blank Statement
of Financial Interests forms.
a. Orders for forms are generally placed with the printing company in December
of each year.
b. The ordered forms are received by the Administrative Division of the State
Ethics Commission in December, prior to January 1 st of the filing year.
C. Forms are then bulk mailed to municipalities, boards, and state agencies
within the Commonwealth of Pennsylvania.
7. Pursuant to the procedure outlined above, Statement of Financial Interests forms
were mailed annually to West Chester University.
8. Statement of Financial Interests forms were mailed to West Chester University
between 2013 and the present as follows:
a. For filing year 2013, SEC -1, REV. 01114 forms were mailed to PASSHE
universities, including West Chester University, on or around December 26,
2013.
The SEC -1, REV. 01114 forms were to be used in reporting financial
interests for the 2013 calendar year.
Silberman, 18 -032
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b. For filing year 2014, SEC -1, REV. 01115 forms were mailed to PASSHE
universities, including West Chester University, on or around January 6,
2015.
1. The SECA REV. 01115 forms were to be used in reporting financial
interests for the 2014 calendar year.
C. For filingg year 2015, SEC -1, REV. 01116 forms were mailed to PASSHE
universifies, including West Chester University, on or around December 30,
2015.
1. The SEC -1, REV. 01116 forms were to be used in reporting financial
interests for the 2015 calendar year.
d. For filing year 2016, SECA, REV. 01117 forms were mailed to PASSHE
universities, including West Chester University, on or around December 28,
2016.
1. The SEC -1, REV. 01117 forms were to be utilized in reporting financial
interests for the 2016 calendar year.
e. For filing year 2017, SEC -1, REV. 01118 forms were mailed to PASSHE
universities, including West Chester University, on or around December 27,
2017.
1. The SEC -1, REV. 01118 forms were to be utilized in reporting financial
interests for the 2017 calendar year.
9. Each year that forms are printed, a revision number is listed in the upper left -hand
comer of the form.
a. Forms printed in 2014 contained an identification number of SEC -1, REV.
01115, while forms printed in 2015, 2016, and 2017 contained identification
numbers of SEC -1, REV. 01116; SEC-1, REV. 01117; and SEC -1, REV.
01118, respectively.
10. Former West Chester University Executive Associate to the President, Rebecca
Hook ( "Hook "), was responsible for distributing Statement of Financial Interests
forms to West Chester University Council of Trustees Members, including
Silberman.
a. Hook would distribute Statement of Financial Interests forms in March of
each year electronically via email to Council Members.
b. After receiving the Statement of Financial Interests form, it was each
individual Council Member's responsibility,to.accurately, complete the form
and file same with the State Ethics Commission.
1. Statement of Financial Interests forms can be mailed or filed
electronically online at www.ethics.pa.gov.
C, Additionally, copies of Statements of Financial Interests filed by each Council
Member were to be maintained at West Chester University.
11. Silberman, in his capacity as a West Chester University Council of Trustees
Member, is annually required to file a Statement of Financial Interests form by May
1st reporting information pertaining to the prior calendar year.
Silberman, 18 -032
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12. Silberman, as a West Chester University Council of Trustees Member, has been
provided with blank Statement of Financial Interests forms for completion.
a. West Chester University provided Silberman with forms to be completed in
calendar years 2013 through 2017.
13. State Ethics Commission records include a Statement of Financial Interests form
that Silberman filed for calendar year 2014, with a signature date of June 18, 2015
(0611812015).
a. This filing confirms Silberman's knowledge concerning his requirement to file
a Statement of Financial Interests form as a public official.
14. As a Member of the Chester County Agricultural Land Preservation Board,
Silberman filed Statement of Financial Interests forms for calendar years 2013,
2015, and 2017.
a. Silberman's 2013 calendar year filing was dated January 28, 2014
(0112812014).
b. Silberman's 2015 calendar year filing was dated March 7, 2016 (0310712016).
1. Silberman listed the wrong calendar year of "2016" on his 2015
calendar year filing.
C. Silberman's 2017 calendar year filing included a signature date of February
28, 2017 (02/2812017).
d. Silberman failed to list his position as a West Chester University ouncil of
Trustees Member on his Statements of Financial Interests for calendar years
2013, 2015, and 2017.
e. By filing with the Chester County Commissioners Office, Silberman
acknowledged that he is required to file a Statement of Financial Interests
form as a public official.
15. On June 4, 2018, the State Ethics Commission conducted a Statement of Financial
Interests compliance review for West Chester University Council of Trustees
Members.
16. On June 19, 2018, PASSHE representatives were provided with a list b the State
Ethics Commission of individual Council of Trustees Members o? PASSHE
universities who had failed to file Statement of Financial Interests forms.
a. The purpose of notifying PASSHE was to gain compliance from individual
Council Members who had failed to file Statements of Financial Interests for
listed years.
17. Silberman was identified as having failed to file Statements of Financial Interests for
calendar years 2013, 2015, 2016, and 2017 as a West Chester University Council
of Trustees Member.
18. PASSHE University Legal Counsel, Kathleen McCormack ( "McCormack "),
contacted West Chester University in an effort to gain compliance from Silberman.
19. McCormack, via email, contacted Lisa Montgomery of West Chester University on
June 21, 2018, and informed her that Silberman had failed to file Statements of
Silberman, 18 -032
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Financial Interests for calendar years 2013, 2015, 2016, and 2017 as a Member of
the West Chester University Council of Trustees.
20. Following McCormack's June 215t email, West Chester University Vice President for
University Affairs, John Villella ( "Villella "), notified Silberman via email on June 26,
2018, that he had failed to file Statements of Financial Interests for calendar years
2013, 2015, 2016, and 2017.
21. Silberman replied to Villella on June 26, 2018, via email and stated:
Hi John:
On year in prison is not a very appealing prospect. I
believe I turned in all those years but if memory serves me am
negligent regarding this year.
I am also on the Chester County Agricultural Land
Preservation Board and the state has all my financial interest
documents for that board, which is exactly the same form that
WCU requires. That being said, I will complete the form and
return. Also, will call tomorrow.
All my best,
22. On June 27, 2018, Villella replied to Silberman via email and stated:
Eli,
Just left you a phone message. I did find the files we
had on hand for previous years and unfortunately did not have
a copy of your 2013, 2015, or 2016 form on hand. Please
complete the 4 forms and get to me and I will get them to
Harrisburg ASAP.
Thank you,
John
23. Silberman, on or around June 28, 2018, responded to the West Chester University
President's office and met with Villella concerning his Statements of Financial
Interests.
a. Villella advised Silberman to backdate the Statement of Financial Interests
forms to reflect that he had filed for the 2013, 2015, 2016, and 2017 calendar
years.
24. On or around June 28, 2018, Silberman completed Statement of Financial Interests
forms for calendar years 2013, 2015, 2016, and 2017 and provided them to West
Chester University Senior Associate to the President, Rachel Shearer ( "Shearer ").
a. Shearer emailed Silberman's completed Statement of Financial Interests
forms to McCormack on June 29, 2018.
25. McCormack submitted Silberman's Statement of Financial Interests forms for
calendar years 2013, 2015, 2016, and 2017 to the State Ethics Commission via
email on June 29, 2018.
Silberman, 18 -032
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26. A review by State Ethics Commission staff of the Statements of Financial Interests
for calendar years 2013, 2015, and 2016 provided on or about June 28, 2018, as
filed by Silberman in his capacity as a West Chester University Council of Trustees
Member, confirmed that Silberman's forms were backdated as evidenced below:
Calendar Year Purported Date of Completion SEC Form Used
2013 04/03/2014 SEC -1, REV. 01118
2015 04/03/2015 SEC -1, REV. 01118
2016 04/03/2017 SEC -1, REV. 01118
a. Silberman's Statement of Financial Interests forms for calendar years 2013,
2015, and 2016 contained dates of execution /completion which were
factuallyy impossible, as SEC -1, REV. 01118 forms were not
printedldistributed until December 15, 2017.
b. It was impossible for Silberman to have completed these forms on the dates
purported (as signed) as the forms had not yet then been printed and
distributed.
27. Silberman's calendar year 2017 Statement of Financial Interests was also
backdated.
a. Silberman acknowledged in an email to VilleI[a on June 26, 2018, that he did
not file a Statement of Financial Interests for the 2017 calendar year.
b. The form was dated April 3, 2018, to give the appearance thatthe Statement
of Financial Interests had been filed by the May 1, 2018 deadline.
G. Silberman submitted his calendar year 2017 Statement of Financial Interests
on June 28, 2018, the same date that he completed his backdated
Statements of Financial Interests for the 2013, 2015, and 2016 calendar
years.
28. Silberman provided a sworn statement to a State Ethics Commission Investigator on
August 23, 2018.
a. Silberman confirmed that he was provided with a Statement of Financial
Interests form from West Chester University each year to file with the State
Ethics Commission.
b. Silberman was aware of the process for filing a Statement of Financial
Interests each year as a Member of the West Chester University Council of
Trustees.
C. As a Member of the Chester County Agricultural Land Preservation Board,
Silberman filed Statement of Financial Interests forms for calendar years
2013, 2015, and 2017.
d. Silberman filed the Statement of Financial Interests forms for the Chester
County Agricultural Land Preservation Board by turning the forms over to that
board for filing with the State Ethics Commission.
e. Silberman had no intent to conceal information from the public because his
financial interests are on file with the State Ethics Commission through the
filings he made for the Chester County Agricultural Land Preservation Board.
Silberman, 18 -032
age
f. Silberman confirmed that he responded to West Chester University after
Villella notified him that he was missing Statement of Financial Interests
forms for calendar years 2013, 2015, 2016, and 2017.
g. Silberman advised the State Ethics Commission Investigator that Silberman
believed he had provided the Statement of Financial Interests forms for
calendar years 2013, 2015, 2016, and 2017 to West Chester University for
forwarding to the State Ethics Commission, similar to the process he had
followed for the Chester County Agricultural Land Preservation Board, but
upon review of West Chester University's and Silberman's records, the forms
could not be found.
h. Silberman acknowledged that he backdated his Statements of Financial
Interests for the 2013, 2015, 2016, and 2017 calendar years, having received
erroneous instructions that backdated filings would be acceptable if
Silberman believed the original forms had been provided by him for filing.
III. DISCUSSION:
As a Member of the Council of Trustees of West Chester University of the
Pennsylvania State System of Higher Education since June 5, 2007, Respondent Eli
Silberman, also referred to herein as Respondent, Respondent Silberman, and
"Silberman," 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 sgtq.
The allegations are that Silberman violated Sections 1104(a) and 1105(a) of the
Ethics Act when he failed to timely file Statement of Financial Interests forms for the 2013,
2015, 2016, and 2017 calendar years, and when he subsequently filed backdated
Statement of Financial Interests forms for calendar years 2013, 2015, 2016, and 2017 to
give the impression that forms for those calendar years were timely filed.
Section 1104(a) of the Ethics Act provides that each public official /public employee
must file a Statement of Financial Interests for the preceding calendar year, each year that
he holds the position and the year after he leaves it.
Section 1105(a) of the Ethics Act provides that the Statement of Financial Interests
shall be filed on the form prescribed by this Commission; that all information requested on
the form shall be provided to the best of the knowledge, information and belief of the filer;
and that the form shall be signed under oath or equivalent affirmation.
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.
Silberman has served as a Member of the Council of Trustees of West Chester
University since June 5, 2007. West Chester University is part of the Pennsylvania State
System of Higher Education ( "PASSHE" ), As a Member of the West Chester University
Council of Trustees, Silberman is required to annually file a Statement of Financial
Interests by May 1.
Each year this Commission contracts for the printing of blank Statement of Financial
Interests forms. Each year the printed forms bear a revision number that enables this
Commission to determine when the forms were printed. Each year the Administrative
Division of this Commission receives the printed forms from the printer in December, prior
to January 1 of the filing year. Forms are then bulk mailed to municipalities, boards, and
state agencies within the Commonwealth of Pennsylvania.
Silberman, 18 -032
Page
Statement of Financial Interests forms were mailed to West Chester University for
each filing year from 2013 through 2017. Rebecca Hook, as the West Chester University
Executive Associate to the President, distributed the Statement of Financial Interests forms
to the Members of the West Chester University Council of Trustees, including Silberman,
via email. Each Member of the West Chester University Council of Trustees was
responsible for accurately completing the Statement of Financial Interests form and filing it
with this Commission.
On June 4, 2018, this Commission conducted a compliance review of Statements of
Financial Interests forms for Members of the West Chester University Council of Trustees.
The records of this Commission included a Statement of Financial Interests filed by
Silberman for calendar year 2014.
On June 19, 2018, this Commission provided PASSHE with a list of individuals who
had failed to file Statement of Financial Interests forms as Members of the Council of
Trustees of a PASSHE university. The list provided to PASSHE identified Silberman as
having failed to file Statements of Financial Interests for calendar years 2013, 2015, 2016,
and 2017 as a Member of the West Chester University Council of Trustees.
On June 21, 2018, legal counsel for PASSHE contacted Lisa Montgomery of West
Chester University and informed her that Silberman had failed to file Statements of
Financial Interests for calendar years 2013, 2015, 2016, and 2017. On June 26, 2018,
John Villella ("Villella "), as the West Chester University Vice President far University Affairs,
notified Silberman via email that he had failed to file Statements of Financial Interests for
calendar years 2013, 2015, 2016, and 2017. Silberman replied to Villella via email,
expressing his belief that he had turned in Statement of Financial Interests forms for the
2013, 2015, and 2016 calendar years but had been negligent with regard to his Statement
of Financial Interests form for the 2017 calendar year. Silberman stated that he would
complete and return the forms. Villella subsequently replied to Silberman via email, stating
that the files on hand for previous years did not contain copies of Silberman's Statements
of Financial Interests for calendar years 2013, 2015, and 2016. Villella requested that
Silberman complete Statements of Financial Interests for the 2013, 2015, 2016, and 2017
calendar years and provide them to Villella to send them to this Commission.
On or around June 28, 2018, Silberman met with Villella concerning Silberman's
Statements of Financial Interests. Villella advised Silberman to backdate the Statement of
Financial Interests forms to reflect that he had filed forms for the 2013, 2015, 2016, and
2017 calendar years. Silberman then completed Statement of Financial Interests forms for
calendar years 2013, 2015, 2016, and 2017, and on June 29, 2018, legal counsel for
PASSHE submitted the forms to this Commission via email.
Silberman's Statements of Financial Interests for calendar years 2013, 2015, and
2016 were signed with purported dates of completion of 04103120'14, 04/0312015, and
04103/2017, respectively. The Statements of Financial Interests for calendar years 2013,
2015, and 2016 were completed using forms with the revision number of SEC -1, REV.
01118. It was impossible for Silberman to have completed the Statement of Financial
Interests forms for calendar years 2013, 2015, and 2016 on the dates purported because
the SEC -1, REV. 01/18 form was not printed and distributed until December 15, 2017.
Silberman's Statement of Financial Interests form for calendar year 2017 was backdated
April 3, 2018. Silberman backdated his Statements of Financial Interests for the 2013,
2015, 2016, and 2017 calendar years, having received erroneous instructions that
backdated filings would be acceptable if he believed the original forms had been provided
by him for filing.
Having highlighted the Stipulated Findin .9s and issues before us, we shall now apply
the Ethics Act to determine the proper disposition of this case.
Silberman, 18 -032
agP e�
The parties' Consent Agreement sets forth a proposed resolution of the allegations
as follows:
The Investigative Division will recommend the following in
relation to the above allegations:
That a technical violation of Section 1104(a) of
the Public Official and Employee Ethics Act, 65
Pa.C.S. § 1104(a)), occurred when Silberman
failed to timely file Statement of Financial
Interests forms for the 2013, 2015, 2016, and
2017 calendar years.
That a technical violation of Section 1105(a) of
the Public Official and Employee Ethics Act, 65
Pa.C.S. § 1105(a i occurred when Silberman
failed to timely file Statement of Financial
Interests forms for the 2013, 2015, 2016, and
2017 calendar years and subsequently
submitted backdated filings, having received
erroneous instructions from a University official
that backdated filings would be acceptable if
Silberman believed the original forms had been
provided by him for filing.
Silberman agrees to make payment in the amount of $500.00
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 he has not already done so, Silberman agrees to
file complete and accurate amended Statements of Financial
Interests with the Pennsylvania State System of Higher
Education, through the Pennsylvania State Ethics
Commission, for calendar years 2013, 2015, 2016, and 2017
within thirty (30) days of the issuance of the final adjudication
in this matter.
6. Silberman agrees to not accept an reimbursement,
compensation or other payment from the I ennsylvania State
System of Higher Education 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 apppropriate
enforcement actions in the event of Respondent's failure to
comply with this agreement or the Commission's order or
cooperating with any other authority who may so choose to
review this matter further.
Consent Agreement, at 1 -2.
In considerin the Consent Agreement, we accept the parties' recommendations,
and we hold, that: (1� a technical violation of Section 1104(a) of the Ethics Act, 65 Pa.C.S.
Silberman, 18032
Page `10
P1104(a), occurred when Silberman failed to timely file Statement of Financial Interests
orms for the 2013, 2015, 2016, and 2017 calendar ears; and (2) a technical violation of
Section 1105(a) of the Ethics Act, 65 Pa.C.S. 1105((a), occurred when Silberman failed to
timely file Statement of Financial Interests Dorms for the 2013, 2015, 2016, and 2017
calendar years and subsequently backdated those filings, having received erroneous
instructions from a West Chester University official that backdated filings would be
acceptable if Silberman believed the original forms had been provided by him for filing.
As part of the Consent Agreement, Silberman has agreed to make payment in the
amount of $500.00 payable to the Commonwealth of Pennsylvania, with such payment
forwarded to this Commission within thirty (30) days of the issuance of the final
adjudication in this matter.
Silberman has agreed to not accept any reimbursement, compensation or other
payment from PASSHE representing a full or partial reimbursement of the amount paid in
settlement of this matter.
To the extent he has not already done so, Silberman has agreed to file complete
and accurate amended Statements of Financial Interests with PASSHE, through this
Commission, for calendar years 2013, 2015, 2016, and 2017 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.
Per the Consent Agreement of the parties, Silberman is directed to make payment
in the amount of $500.00 payable to the Commonwealth of Pennsylvania, with such
payment forwarded to this Commission by no later than the thirtieth (30th) day after the
mailing date of this adjudication and Order.
Per the Consent Agreement of the parties, Silberman is further directed to not
accept anV reimbursement, compensation or other payment from PASSHE representing a
full or partial reimbursement of the amount paid in settlement of this matter.
To the extent he has not already done so, Silberman is directed to file complete and
accurate amended Statements of Financial Interests for calendar years 2013, 2015, 2016,
and 2017 with PASSHE, 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:
As a Member of the Council of Trustees of West Chester University of the
Pennsylvania State System of Higher Education since June 5, 2007, Respondent Eli
Silberman ( "Silberman ") 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 sue.
2. Silberman technically violated Section 1104(a) of the Ethics Act, 65 Pa.C.S. §
1104 a), when he failed to timely file Statement of Financial Interests forms for the
2013 2015, 2016, and 2017 calendar years.
3. A technical violation of Section 1105(a) of the Ethics Act, 65 Pa.C.S. § 1105 (a),
occurred when Silberman failed to timely file Statement of Financial Interests forms
for the 2013, 2015, 2016, and 2017 calendar years and subsequently backdated
Silberman, 18 -032
Page `1
those filings, having received erroneous instructions from a West Chester University
official that backdated filings would be acceptable if Silberman believed the original
forms had been provided by him for filing.
In Re: Eli Silberman, File Docket: 18 -032
Respondent Date Decided: 516119
Date Mailed: 5113119
ORDER NO. 1753
1. As a Member of the Council of Trustees of West Chester University of the
Pennsylvania State System of Higher Education, Eli Silberman ( "Silberman ")
technically violated Section 1104(a ) of the Public Official and Employee Ethics Act
( "Ethics Act), 65 Pa.C.S. § 1104(a), when he failed to timely file Statement of
Financial Interests forms for the 2013, 2015, 2016, and 2017 calendar years.
2. A technical violation of Section 1105(a) of the Ethics Act, 65 Pa.C.S. § 1105(a),
occurred when Silberman failed to timely file Statement of Financial Interests forms
for the 2013, 2015, 2016, and 2017 calendar years and subsequently backdated
those filings, having received erroneous instructions from a West Chester University
official that backdated filings would be acceptable if Silberman believed the original
forms had been provided by him for filing.
3. Per the Consent Agreement of the parties, Silberman is directed to make payment
in the amount of $500.00 payable to the Commonwealth of Pennsylvania, with such
payment forwarded to the Pennsylvania State Ethics Commission by no later than
the thirtieth (30th) day after the mailing date of this Order.
4. Per the Consent Agreement of the parties, Silberman is further directed to not
accept any reimbursement, compensation or other payment from the Pennsylvania
State System of Higher Education representing a full or partial reimbursement of the
amount paid in settlement of this matter.
5. To the extent he has not already done so, Silberman is directed to file complete and
accurate amended Statements of Financial Interests for calendar years 2013, 2015,
2016, and 2017 with the Pennsylvania State System of Higher Education, through
this Commission, by no later than the thirtieth (30th) day after the mailing date of this
Order.
6. Compliance with paragraphs 3, 4, and 5 of this Order will result in the closing of this
case with no further action by this Commission.
Non - compliance will result in the institution of an order enforcement action.
BY THE COMMISSION,
t