HomeMy WebLinkAbout150-SL Connections EducationPHONE: 717-783-1610
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In Re: Connections Education,
Respondent
STATE ETHICS; COMMISSION
FINANCE BULDING
FAQCSIMILE: 717-787-0806
WEBSITE: www,eth[cs.Da.aov
File Docket: 21-005-L
X-ref. Order No. 150-SL
Date Decided: 6/23/21
Date Mailed: 6/30/21
Before: Nicholas A. Colafella, Chair
Mark R. Corrigan, Vice Chair
Roger Nick
Melanie DePalma
Michael A. Schwartz
Shelley Y. Simms
This is a final adjudication of the State Ethics Commission as to the alleged delinquency
and/or deficiency of expense report(s) required to be filed pursuant to Pennsylvania's lobbying
disclosure law, 65 Pa.C.S. § 13AOI et seq., hereinafter referred to as the "Lobbying Disclosure
Law."
The Investigative Division initiated these proceedings by filing with the State Ethics
Commission and serving upon Respondent Connections Education (hereinafter also referred to as
"Respondent") a Notice of Alleged Noncompliance. Respondent did not file an Answer, Appeal,
or other Request for Hearing. A Stipulation of Findings and a Consent Agreement were
subsequently submitted by the parties to the Commission for consideration. The Stipulated
Findings are set forth as the Findings in this Order. The Consent Agreement has been approved.
Effective January 1, 2017, the Pennsylvania Department of State ("Department of
State"') increased the thresholds under 65 Pa.C.S. § 13AO6 for registration under 65 Pa.C.S.
§ 13AO4 and the threshold for reporting under 65 Pa.C.S. § 13AO5(d) from $2,500.00 to
$3,000.00.
In 2018 the Lobbying Disclosure Law was amended by Act 2 of 2018, and as of April
16, 2018, the Department of State will not accept paper registrations or expense reports.
1. ALLEGED NONCOMPLIANCE:
That Respondent, in its capacity as a principal registered with the Department of State
pursuant to the Lobbying Disclosure Law (65 Pa.C.S, § 13AO I et M.), failed to timely file
quarterly expense reports pursuant to 65 Pa.C.S. § I 3A05 for the first (I") and second (2 d)
quarters of 2020.
Connections Education, 21-005-L
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11. FINDINGS:
l . Respondent is Connections Education ("Respondent") and is a registered principal as that
term is defined by the Pennsylvania Lobbying Disclosure Law ("Lobbying Disclosure
Law") Act 134 of 2006, 65 Pa.C.S. § 13A01 et sue.
a. Respondent initially registered as a principal with the Department of State on April
29, 2007, for the registration period January 1, 2007, through December 31, 2008.
b. Respondent's registration statement indicates that lobbying commenced on January
1, 2007.
2. Respondent filed a principal registration statement with the Pennsylvania Department of
State for the registration period January 1, 2019, through December 31, 2020.
a. By registering with the Department of State, Respondent consented to receive
service of notices, other official mailings, or process at the address listed on the
registration statement.
b. Respondent was assigned the principal registration number "P03252."
C. In filing its principal registration, Respondent identified its registered mailing
address as:
110 Abbeywood Drive, 0
Nashville, TN 37215
3. The Lobbying Disclosure Law, specifically 65 Pa.C.S. § 13A04, states the following
regarding the registration of an entity as a principal:
§ 13AO4. Registration
a. General rule. -Unless excluded under section 13A06
(relating to exemption from registration and reporting), a
lobbyist, lobbying firm or a principal must register with the
department electronically using the computerized filing
system developed by the department that is consistent with
the purposes of this chapter within ten days of acting in any
capacity as a lobbyist, lobbying firm or principal.
Registration shall be biennial and shall begin January 1,
2007.
Connections Education, 2I-005-L
Page 3
b. Principals and lobbying firms.--
1. A principal or lobbying firm required to register
under subsection (a) shall file a single registration
statement setting forth the following information
with the department:
i. Name of the business.
ii. Permanent address.
iii. Daytime telephone number.
iv. E-mail address of the authorized
representative employee or agent, if
available.
V. Nature of business.
vi. Name, registration number and acronym of
any affiliated political action committees.
vii. Name and permanent business address of
each individual who will for economic
consideration engage in lobbying on behalf
of the principal or lobbying firm.
viii. Registration number when available.
ix. Name of the authorized representative,
employee or agent.
d. Amendments.--
1. If there is a change of information required for the
registration statement under subsection (b)(1) or (2)
or (c), an amended registration statement shall be
filed with the department electronically using the
computerized filing system developed by the
department that is consistent with the purpose of this
chapter within 14 days after the change occurs.
2. When there is a change in information required for
the registration statement under subsection (b)(3), an
amended registration statement shall be filed with the
department electronically using the computerized
filing system developed by the department that is
consistent with the purpose of this chapter within 14
days of the end of the year in which the change
occurs.
65 Pa.C.S. § 13AO4(a), (b)(1), (d).
Connections Education, 21-005-L
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4. In addition to the Lobbying Disclosure Law, the duly promulgated Regulations provide
further information in relation to registration periods and reporting periods:
§ 51.3. Registration periods and reporting periods.
a. Registration under section 13A04 of the act (relating to
registration) shall be biennial. The first registration period
which commenced January 1, 2007, continues through
December 31, 2008. Subsequent registrations shall
commence on January 1 of each odd numbered year.
51 Pa. Code § 51.3(a).
5. Section 13A05 of the Lobbying Disclosure Law sets forth, in part, the following
requirements for the contents of quarterly reporting forms filed by principals:
§ BA05. Reporting
(a) General rule.-- A registered principal shall, subject to the
penalties under 18 Pa.C.S. § 4904 (relating to unsworn
falsification to authorities), file quarterly expense reports
with the department electronically using the computerized
filing system developed by the department that is consistent
with the purpose of this chapter no later than 30 days after
the last day of the quarter.
(b) Content.--
(1) Each expense report must list the names and
registration numbers when available of all lobbyists
by whom lobbying is conducted on behalf of the
principal and the general subject matter or issue
being lobbied.
(2) Each expense report shall include the total costs of
all lobbying for the period. The total shall include all
office expenses, personnel expenses, expenditures
related to gifts, hospitality, transportation and
lodging to State officials or employees, and any other
lobbying costs. The total amount reported under this
paragraph shall be allocated in its entirety among the
following categories:
Connections Education, 21-005-L
Page 5
(i) The costs for gifts, hospitality, transportation
and lodging given to or provided to State
officials or employees or their immediate
families.
(ii) The costs for direct communication.
(iii) The costs for indirect communication.
(iv) Expenses required to be reported under this
subsection shall be allocated to one of the
three categories listed under this section and
shall not be included in more than one
category.
65 Pa.C.S. § 13A05(a), (b)(1)-(2).
6. In addition to the Lobbying Disclosure Law, the duly promulgated Regulations provide
further instructions in relation to registration periods and reporting periods:
§ 51.3. Registration periods and reporting periods.
(b) Reporting under section 13A05 of the act (relating to
reporting) shall be quarterly within each calendar year: for
January through March; April through June; July through
September; and October through December. Quarterly
expense reports shall be filed on or before the 30th day after
the quarterly reporting period ends.
51 Pa. Code § 51.3(b).
7. [As a registered principal, Respondent is required to electronically file with the Department
of State either a quarterly expense report or a statement of failure to meet the reporting
threshold for each quarter it has been registered as a principal, by no later than the 301h day
after each quarterly reporting period has ended. 65 Pa.C.S. § 13A05(a), (d); 51 Pa. Code
§ 55.1(d)].
8. Section 13A05 of the Lobbying Disclosure Law additionally sets forth the threshold with
regard to reporting expenditures:
(d) Thresholds for reporting.-- An expense report required
under this section shall be filed electronically using the
computerized filing system developed by the department
that is consistent with the purpose of this chapter when total
Connections Education, 21-005-L
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expenses for lobbying exceed [$3,000] for a registered
principal in a reporting period. In a reporting period in which
total expenses are [$3,000] or less, a statement to that effect
shall be filed electronically using the computerized filing
system developed by the department that is consistent with
the purpose of this chapter.
65 Pa.C.S. § 13A05(d).
9. Section 13A03 of the Lobbying Disclosure Law defines the following terms:
"Lobbying." An effort to influence legislative action or
administrative action in this Commonwealth. The term includes:
(1) direct or indirect communication;
(2) office expenses; and
(3) providing any gift, hospitality, transportation or lodging to a
State official or employee for the purpose of advancing the
interest of the lobbyist or principal.
"Legislative action." An action taken by a State official or
employee involving the preparation, research, drafting,
introduction, consideration, modification, amendment, approval,
passage, enactment, tabling, postponement, defeat or rejection of.
(1) legislation;
(2) legislative motions;
(3) a veto by the Governor; or
(4) confirmation of appointments by the Governor or
appointments to public boards or commissions by a member
of the General Assembly.
"Legislation." Bills, resolutions, amendments and nominations
pending or proposed in either the Senate or the House of
Representatives. The term includes any other matter which may
become the subject of action by either chamber of the General
Assembly.
"Direct communication." An effort, whether written, oral or by
any other medium, made by a lobbyist or principal, directed to a
State official or employee, the purpose or foreseeable effect of
which is to influence legislative action or administrative action. The
term may include personnel expenses and office expenses.
65 Pa.C.S. § 13A03.
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10. [As a registered principal, Respondent is required to electronically file with the Department of
State either a quarterly expense report or a statement of failure to meet the reporting threshold
for each quarter it has been registered as a principal, by no later than the 30'h day after each
quarterly reporting period has ended. 65 Pa.C.S. § 13A05(a), (d); 51 Pa. Code § 55,1(d)].
a. Respondent filed a quarterly expense report for the fourth (0) quarter of 2019.
b. Respondent did not file a first (15t) quarter 2020 expense report by July 30, 2020.'
C. Respondent did not file a second (2" d) quarter 2020 expense report by July 30, 2020.
11. The Regulations promulgated under the Lobbying Disclosure Law specifically provide the
following in relation to a delinquent filing:
§ 51.4. Delinquency.
(a) A registration statement or report required to be filed under section
13A04 or 13A05 of the act (relating to registration; and reporting) is
delinquent if not received by the Department on the date due as follows:
(1) Hard copy filings must be received by 5 p.m. in the
office. For quarterly expense reports, from 5 p.m.
until 12 a.m. midnight, a hard copy filing may be
filed with the Department's designee. The filing
location and the Department's designee will be on
the Department's web site.
i. Hard copy filings are no longer allowed
pursuant to Act 2018-2 (H.B.1175), § 2,
approved February 14, 2018, eff. April [15],
2018.
(2) Electronic filings may be filed until 12 a.m.
midnight.
(b) A failure to timely file a registration statement, a quarterly
expense report, a separate expense report, a notice of
termination or an amendment to one of these filings constitutes
a failure to register or report as required by the act; delinquency
continues until the filing is received by the Department in
proper form.
51 Pa. Code § 51.4(a)-(b).
'Due to the COVID-19 pandemic, the Department of State issued an extended deadline to fife first (111) quarter2020 expense reports from April
30, 2020 to July 30, 2020.
Connections Education, 21-005-L
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12. [In relation] to the filing requirements of quarterly expense reports, the Regulations read,
in part:
§ 55.1. Quarterly expense reports.
(a) A quarterly expense report is required to be filed as set forth
in this section when the total lobbying expenses of a
registered principal, registered lobbying firm or registered
lobbyist lobbying on the principal's behalf, together, exceed
[$3,000] in a quarterly reporting period. The threshold of
[$3,000] includes any economic consideration paid by a
principal to a lobbying firm or lobbyist for lobbying.
Individuals exempt under section 13AO6 of the act (relating
to exemption from registration and reporting) need not
register or report.
(b) For a quarterly reporting period in which the total lobbying
expenses of a registered principal, registered lobbying firm
or registered lobbyist lobbying on the principal's behalf,
together, are [$3,000] or less, a statement to that effect shall
be filed with the Department by checking the appropriate
block on the quarterly expense report form.
(d) The principal shall file a quarterly expense report or
statement of failure to meet the reporting threshold on or
before the 30th day after the quarterly reporting period ends.
(g) A quarterly expense report of a principal required to be
registered under the act must include at least the following
information:
(3) The total costs of all lobbying for the period. The
total must include all office expenses, personnel
expenses, expenditures related to gifts, hospitality,
transportation and lodging to State officials or
employees, and any other lobbying costs.
(i) The total amount reported under this
paragraph shall be allocated in its entirety
among the following categories:
Connections Education, 21-005-L
Page 9
(A) The costs for gifts, hospitality,
transportation and lodging given to or
provided to State officials or
employees or their immediate
families.
(B) The costs for direct communication.
(C) The costs for indirect communication.
(ii) Registrants shall use a good faith effort to
allocate expenses required to be reported
under this subsection to one of the three
categories listed herein. A given expense may
not be included in more than one category.. .
51 Pa. Code § 55.1(a), (b), (d), (g)(3)(i)-(ii).
13. By Warning Notice letter dated August 27, 2020, Respondent was served with notice in
accordance with Section 13A09 of the Lobbying Disclosure Law and Section 63.4(1) of
the Lobbying Disclosure Regulations of the specific allegations that Respondent failed to
file quarterly expense reports for the first (Ist) and second (2nd) quarters of 2020 [with the
Department of State].
a. Said Warning Notice was mailed to:
Rob Kremer
Connections Education
110 Abbeywood Drive, 0
Nashville, TN 37215
b. This is the same address as listed on Respondent's principal registration statement.
C. By submitting the principal registration statement, Respondent consented to receipt
of service of notices, other official mailings or process, at the address listed on the
registration statement. (Sec, Paragraph 2(a) above).
14. Said Warning Notice letter set forth the nature of the alleged noncompliance and the
administrative and criminal penalties for failing to file.
15. Said Warning Notice letter provided Respondent an opportunity to cure the alleged
noncompliance and avoid the institution of these proceedings as to alleged noncompliance by
filing quarterly expense reports for the time period covering the first (I") and second (2°d)
quarters of 2020 with the Department of State within thirty (30) days from the mailing date of
the Warning Notice letter.
Connections Education, 21-005-L
Page 10
16. The Chief of the Division of Campaign Finance and Lobbying Disclosure for the
Commonwealth of Pennsylvania - Department of State conducted a search of the
Department of State's records, and, as of March 31, 2021, no first (0) or second (2"d)
quarter of 2020 expense reports were found to have been filed with the Department of State
for P03252.
17. The Lobbying Disclosure Law provides for civil penalties for failing to comply with the
registration statement filing and quarterly expense reporting requirements thereof. In
pertinent part, the Lobbying Disclosure Law provides that:
a. Negligent failure to register or report as required by this chapter is
punishable by an administrative penalty not exceeding the
following:
(i) For the first ten late days, $50 for each late day.
(ii) For each late day after the first ten late days through the 20"
late day, $100 for each late day.
(iii) For each late day after the first 20 late days, $200 for each
late day.
65 Pa.C.S. § 13A09(c)(1).
b. The total amount of the administrative penalty that may be levied
after hearing by a majority vote of all of the Commission Members
shall not be limited by any other provision of law. 65 Pa.C.S. §
13A09(c)(2).
c. Any person that fails to comply with the requirements of the
Lobbying Disclosure Law, after notice of noncompliance and after
a hearing if one is requested, may be prohibited from lobbying for
economic consideration for up to five (5) years [in accordance with
65 Pa.C.S. § 13A09(e)(4)]. 65 Pa.C.S. §§ 13A09(d), (e)(4).
18. Respondent's first (I") quarter 2020 expense report was 271 days delinquent (July 31,
2020 — April 23, 2021).
a. The first quarter expense report period closed March 31, 2020. See, 65 Pa.C.S. § 13A03
Definitions — "Reporting period."
b. Due to the [COVID-19] pandemic, the Department of State issued [an extended]
deadline to file the first (1 S') quarter 2020 expense report to July 30, 2020.
c. The first day in which Respondent's first (1") quarter 2020 expense report was
delinquent was July 31, 2020.
Connections Education, 21-005-L
Page 11
d. Respondent filed its first (1") quarter 2020 expense report on April 23, 2021,
19. Respondent's second (2°d) quarter 2020 expense report was 271 days delinquent (July 31,
2020 — April 23, 2021).
a. The second quarter expense report period closed June 30, 2020. See, 65 Pa.C.S. §
13A03 Definitions — "Reporting period."
b. Expense reports were to be filed within thirty (30) days of July 1, 2020, that date being
July 30, 2020. See, 65 Pa.C.S. § 13A05(a).
c. The first day in which Respondent's second (2nd) quarter 2020 expense report was
delinquent was July 31, 2020.
d. Respondent filed its second (2"d) quarter 2020 expense report on April 23, 2021.
20. Respondent's failure to file its 2020 expense reports is negligent in nature.
a. Respondent ended its contract with its lobbyist on December 31, 2019, which was
accurately reflected in the lobbying database.
b. Respondent did not understand that it was responsible for affirmatively filing a
termination report and completing expense reports for the remaining quarters that it
was registered principal.
c. In February 2021, Respondent's authorized representative had contact with the
Department of State and Investigative Division of the State Ethics Commission
regarding the delinquent expense reports.
d. At the time, Respondent's authorized representative directed Respondent's personnel
to file the delinquent reports, however, there was confusion among Respondent's staff
because at the time there was a new principal registration by Respondent's parent
company, Pearson Education, Inc. and the expense reports were not filed. Pearson
Education, Inc. was at the time separately registered and was, and has been, timely
filing expense reports.
e. After receiving the Notice of Noncompliance in this matter, Respondent has properly
filed its expense reports and terminated the registration for Connections Education.
Respondent has additionally initiated internal process and operations improvements to
avoid miscommunication, negligence or inadvertent failure to file expense reports in
the future.
Connections Education, 21-005-L
Page 12
III. DISCUSSION:
1n the instant matter, the alleged noncompliance is that Respondent, as a principal
registered with the Pennsylvania Department of State ("Department of State") pursuant to the
Lobbying Disclosure Law, failed to timely file quarterly expense reports pursuant to 65 Pa.C.S. §
13A05 for the first and second quarters of 2020.
As noted above, the parties have submitted a Consent Agreement and Stipulation of
Findings. The parties' Stipulated Findings are set forth above as the Findings of this Commission.
We shall now summarize the relevant facts as contained therein.
Respondent initially registered as a principal with the Department of State on April 29,
2007, for the registration period January 1, 2007, through December 31, 2008. Respondent's
registration statement indicated that lobbying commenced on January 1, 2007. Respondent was
assigned the principal registration number "P03252."
Per the Department of State's website, on July 30, 2019, Respondent renewed its
registration as a principal with the Department of State for registration period January 1, 2019
through December 31, 2020.
Pursuant to Section 13A05 of the Lobbying Disclosure Law, 65 Pa.C.S. § 13A05, and
Section 51.3 of the Lobbying Disclosure Regulations, 51 Pa. Code § 51.3, expense reports are filed
on a quarterly basis. When a registered principal's total expenses for lobbying exceed $3,000 for
a reporting period/quarter, the principal is required to file a quarterly expense report with the
Department of State by no later than 30 days after the last day of such quarter. For a reporting
period in which total expenses are $3,000 or less, a statement to that effect must be filed with the
Department of State by the principal by checking the appropriate block on the quarterly expense
report form. 51 Pa. Code § 55.1(b). Thus, a registered principal must file either a quarterly
expense report or a statement of failure to meet the reporting threshold by no later than the 30th
day after each quarterly reporting period ends. 51 Pa. Code § 55.1(d).
Having registered on July 30, 2019, for the registration period January 1, 2019, through
December 31, 2020, Respondent was required to file either quarterly expense reports or statements
of failure to meet the reporting threshold for the first and second quarters of 2020. Respondent
failed to file either.
Failure to timely meet the aforesaid filing requirement constitutes a failure to report as
required by the Lobbying Disclosure Law, and the delinquency continues until the filing is
received by the Department of State in proper form. 51 Pa. Code § 51.4(b).
By Warning Notice letter dated August 27, 2020, Respondent was served with notice of
the alleged noncompliance in accordance with Section 63.4(1) of the Lobbying Disclosure
Regulations, 51 Pa. Code § 63.4(1). The Warning Notice letter provided Respondent an
opportunity to cure the alleged noncompliance and avoid the institution of these proceedings by
Connections Education, 21-005-L
Page 13
filing quarterly expense reports for the first and second quarters of 2020 with the Department of
State within thirty (30) days of the mailing date of the Warning Notice letter.
As of March 31, 2021, no first or second quarter 2020 expense reports were found to have
been filed with the Department of State for Connections Education.
On April 23, 2021, Respondent submitted quarterly expense reports for the first and second
quarters of 2020.
Negligent failure to register or report as required by the Lobbying Disclosure Law is
punishable by an administrative penalty as follows: (1) for the first ten late days, $50.00 for each
late day; (2) for each late day after the first ten late days through the 20"' late day, $100 for each
late day; and (3) for each late day after the first 20 late days, $200 for each late day. 65 Pa.C.S. §
13AO9(c)(1).
Having highlighted the Stipulated Findings and issues before us, we shall now apply the
Lobbying Disclosure Law to determine the proper disposition of this case.
The parties' Consent Agreement sets forth a proposed resolution of the allegations as
follows:
3. The Investigative Division will recommend the following
conclusions in relation to the above deficiencies:
a. That Respondent, in its capacity as a Principal
registered with the Pennsylvania Department of State
pursuant to the Pennsylvania Lobbying Disclosure
Law (65 Pa.C.S. § 13AOI et sc .), failed to timely
file a Quarterly Expense Report pursuant to 65
Pa.C.S. § 13A05, for the first (I") and second (2" d)
quarters of 2020;
b. That the transgressions of the Lobbying Disclosure
Law outlined in paragraph (a) above are deemed
unintentional, and thus, merely negligent in nature;
4. Respondent agrees to pay the sum of $7,000.00 in settlement of this
matter to be paid as follows:
a. In regard to Respondent's negligent failure to timely
file first (1") and second (2"d) quarter 2020 expense
report, and pursuant to Section 13AO9(c)(1) of the
Lobbying Disclosure Law, 65 Pa.C.S. §
13AO9(c)(1), Respondent agrees to pay an
Connections Education, 21-005-L
Page 14
administrative penalty in the amount of $7,000.00
which shall be made payable to the Commonwealth
of Pennsylvania and forwarded to the Pennsylvania
State Ethics Commission within 30 days of the final
adjudication in this matter.
5. The Investigative Division will recommend that the Commission
take no further action in this matter, impose no further sanctions,
and make no specific recommendations to any law enforcement or
other authority to take action in this matter as to either Respondent,
or any individual or representative of Respondent. Such, however,
does not prohibit the Commission from 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 1-2.
In considering the Consent Agreement and Stipulation of Findings, we agree with the
parties that Respondent as a registered principal failed to timely file quarterly expense reports with
the Department of State for the first and second quarters of 2020 as required by Section 13A05 of
the Lobbying Disclosure Law.
Accordingly, we hold that Respondent, as a registered principal, failed to timely file
quarterly expense reports with the Department of State for the first and second quarters of 2020 as
required by Section 13A05 of the Lobbying Disclosure Law. We accept the recommendation of
the parties for a determination that the transgression of the Lobbying Disclosure Law outlined
immediately above is deemed to be negligent in nature.
As part of the Consent Agreement, Respondent agreed to pay an administrative penalty in
the total amount of $7,000.00 payable to the Commonwealth of Pennsylvania and forwarded to
this Commission within thirty days 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, we approve the Consent Agreement that has been
submitted by the parties.
This Commission hereby levies one administrative penalty against Respondent
Connections Education in the total amount of $7,000.00 for its delinquent quarterly expense
reports for the first and second quarters of 2020.
To the extent it has not already done so, Respondent Connections Education is directed to
pay the aforesaid administrative penalty in the total amount of $7,000.00 to be made payable to
Connections Education, 21-005-L
Page 15
the Commonwealth of Pennsylvania and forwarded to this Commission by no later than the
thirtieth (30{h) day after the mailing date of this adjudication and Order.
Noncompliance will result in the institution of an order enforcement action.
IV. CONCLUSIONS OF LAW:
As a principal registered with the Pennsylvania Department of State ("Department of
State") under principal registration number "P03252," Connections Education has been
subject to the reporting requirements of Section 13A05 of Pennsylvania's Lobbying
Disclosure Law ("Lobbying Disclosure Law"), 65 Pa.C.S. § 13A05.
2. Connections Education, in its capacity as a principal registered with the Department of
State under principal registration number "P03252," failed to timely file quarterly expense
reports with the Department of State for the first and second quarters of 2020 as required
by Section 13A05 of the Lobbying Disclosure Law, 65 Pa.C.S. § 13A05.
3. The transgressions of the Lobbying Disclosure Law outlined in paragraph 2 immediately
above are deemed to be negligent in nature.
4. The prerequisite service of a warning notice in accordance with Section 63.4(l) of the
Lobbying Disclosure Regulations, 51 Pa. Code § 63.4(1), was satisfied.
5. Based upon the totality of the circumstances in this case, the imposition of an
administrative penalty in the total amount of $7,000.00 is warranted.
In Re: Connections Education,
Respondent
File Docket: 21-005-L
Date Decided: 6/23/21
Date Mailed: 6/30/21
ORDER NO. 150-SL
Connections Education, in its capacity as a principal registered with the Pennsylvania
Department of State ("Department of State") under principal registration number
"P03252," failed to timely file quarterly expense reports with the Department of State for
the first and second quarters of 2020 as required by Section 13A05 of Pennsylvania's
lobbying disclosure law ("Lobbying Disclosure Law"), 65 Pa.C.S. § 13A05.
2. The transgressions of the Lobbying Disclosure Law outlined in paragraph 1 immediately
above are deemed to be negligent in nature.
3. Pursuant to Section 13A09(c) of the Lobbying Disclosure Law, 65 Pa.C.S. § 13A09(c),
and the Consent Agreement of the parties, this Commission hereby levies one
administrative penalty against Connections Education in the total amount of $7,000.00 for
its delinquent first and second quarter 2020 expense reports.
4. To the extent it has not already done so, Connections Education is ordered to pay the
aforesaid administrative penalty in the total amount of $7,000.00 to be made payable to the
Commonwealth of Pennsylvania and forwarded to the Pennsylvania State Ethics
Commission by no later than the thirtieth (301h) day after the mailing date of this Order.
5. Noncompliance with Paragraph 4 of this Order will result in the Commission initiating
appropriate enforcement action(s).
BY THE COMMISSION,
A�" (��
Nicholas A. Colafella; Chair