HomeMy WebLinkAbout152-SL, Free Library of Philadelphia FoundationPHONE: 717-783-1610 STATE ETHICS COMMISSION FACSIMILE: 717-787-0806
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HARRIBURG, PA 17120-0400
In Re: Free Library of Philadelphia Foundation, File Docket: 22-001-L
Respondent Order No. 152-SL
Date Decided: 6/28/22
Date Mailed: 6/29/22
Before: Mark R. Corrigan, Acting Chair
Roger Nick
Melanie DePalma
Shelley Y. Simms
Rhonda Hill Wilson
Paul Parsells
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. § 13A0I 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 Free Library of Philadelphia Foundation (hereinafter
also referred to as "Respondent") a Notice of Alleged Noncompliance, 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. § 13A06 for registration under 65 P,a.C.S,.
§ 13A04 and the threshold for reporting under 65 Pa.C.S. § 13A05(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.
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 seq.), failed to timely file
quarterly expense reports pursuant to 65 Pa.C.S. § 13AO5 for the third (3 d ) quarter of 2 02 1.
11. FINDINGS:
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Respondent is Free Library of Philadelphia Foundation ("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 N.
a. Respondent initially registered as a principal with the Department of State on
January 25, 2007, for the registration period January 1, 2007, through December
31, 2008.
b. Respondent's registration statement indicates that lobbying commenced on June 1,
2015.
2. Respondent filed a principal registration statement with the Pennsylvania Department of
State for the registration period January 1, 2021, through December 31, 2022.
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 "P01056."
In filing its principal registration, Respondent identified its registered mailing
address as:
1901 Vine Street
Philadelphia, PA 19103
The Lobbying Disclosure Law, specifically 65 Pa.C.S. § 13A04, states the following
regarding the registration of an entity as a principal:
§ 13A04. 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.
b. Principals and lobbying firms.--
Free Library of Philadelphia Foundation, 22-001-L
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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
fling 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).
4. In addition to the Lobbying Disclosure Law, the duly promulgated Regulations provide
Free Library of Philadelphia Foundation, 22-001-L
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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:
§ 13A05. 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:
(i) The costs for gifts, hospitality, transportation
and lodging given to or provided to State
Free Library of Philadelphia Foundation, 22-001-L
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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 .tune; 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)].
S. 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
expenses for lobbying exceed [$3,000] for a registered
principal in a reporting period. In a reporting period in which
Free Library of Philadelphia Foundation, 22-001-L
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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.
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
Free UbrM of Philadelphia Foundation, 22-001-L
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for each quarter it has been registered as a principal, by no later than the 30" 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 second (2") quarter of 2021 on
July 21, 2021.
b. Respondent did not file a third (3`d) quarter 2021 expense report by October 30,
2021.
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).
12. [In relation] to the filing requirements of quarterly expense reports, the Regulations read,
in part:
§ 55.1. Quarterly expense reports.
Free Library of Philadelphia Foundation, 22-001-L
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(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 13A06 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:
(A) The costs for gifts, hospitality,
transportation and lodging given to or
provided to State officials or
Free Library of Philadelphia Foundation, 22-001-L
Page 9
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 November 10, 2021, 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 a quarterly expense report for the third (Y") quarter 2021 [with the Department of
State].
a. Said Warning Notice was mailed to:
Sara Moran
Free Library of Philadelphia Foundation
1901 Vine Street
Philadelphia, PA 19103
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. (See, 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 a quarterly expense report for the time period covering the third (P) quarter of 2021
with the Department of State within thirty (30) days from the mailing date of the Warning
Notice letter.
16. The Chief of the Bureau of Campaign Finance and Civic Engagement for the
Commonwealth of Pennsylvania - Department of State conducted a search of the
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Department of State's records, and, as of February 9, 2022, no third (3`d) quarter of 2021
expense report was found to have been filed with the Department of State for Free Library
of Philadelphia Foundation.
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`h
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).
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 expense report was a total of one hundred (100) days delinquent.
a. The third quarter expense report period closed September 30, 2021. See, 65 Pa.C.S. §
13A03 Definitions — "Reporting period."
b. Expense reports were to be filed within thirty (30) days of September 30, 2021, that
date being October 30, 2021.
The first day in which Respondent's third (3rd) quarter 2021 expense report was
delinquent was November 2, 2021.
d. Respondent filed its third quarter 2021 expense report on March 8, 2022.
Free Librgy of Philadel hia Foundation, 22-001-L
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• Respondent's failure to file its third quarter 2021 expense report was not
intentional, and therefore deemed negligent.
19. Respondent properly filed its fourth quarter 2021 expense report.
111. DISCUSSION:
In 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 a quarterly expense report pursuant to 65 Pa.C. S. §
13A05 for the third quarter of 2021.
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 January 25,
2007, for the registration period January 1, 2007, through December 31, 2008. Respondent's
registration statement indicated that lobbying commenced on June 1, 2015. Respondent was
assigned the principal registration number "PO 1056."
Per the Department of State's website, on April 21, 2021, Respondent renewed its
registration as a principal with the Department of State for registration period January 1, 2021,
through December 31, 2022.
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 April 21, 2021, for the registration period January 1, 2021, through
December 31, 2022, Respondent was required to file either a quarterly expense report or a
statement of failure to meet the reporting threshold for the third quarter of 2021. 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).
Free Librn of Philadel hia Foundation, 22-001-L
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By Warning Notice letter dated November 10, 2021, 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
filing a quarterly expense report for the third quarter of 2021 with the Department of State within
thirty (30) days of the mailing date of the Warning Notice letter.
As of February 9, 2022, no third quarter 2021 expense report was found to have been filed
with the Department of State for Free Library of Philadelphia Foundation.
Per the Department of State's website, on March 8, 2022, Respondent submitted a quarterly
expense report for the third quarter of 2021.
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. §
13A09(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. § 13A01 et seq.), failed to timely
file a Quarterly Expense Report pursuant to 65
Pa.C.S. § 13A05, for the third (3`d) quarter of 2021;
b. That the transgressions of the Lobbying Disclosure
Law outlined in paragraph (a) above are deemed to
be negligent in nature;
C. For the purposes of this Consent Agreement,
Respondent was deficient in filing its third (3")
quarter of 2021 Expense Report.
Free Library of Philadelphia Foundation, 22-001-L
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On November 10, 2021, a Warning Notice
regarding the delinquent quarterly expense
report was sent to Respondent via First Class
United States Mail;
ii. Respondent did not file the outstanding
Quarterly Expense Report for the third (3rd)
quarter 2021 within the stated cure period;
and
Respondent has properly filed all outstanding
Expense Reports.
4. Respondent agrees to pay the sum of $9,000.00 in settlement of this
matter to be paid as follows:
a. In regard to Respondent's failure to file a timely third
(3rd) quarter 2021 expense report, and pursuant to
Section 13A09 (c)(1) of the Lobbying Disclosure
Law, 65 Pa.C.S. § 13A09(c)(1), Respondent agrees
to pay a total amount of $9,000.00, to be due no later
than six (6) months from today's date & which may
be made in two (2) installments, which shall be made
payable to the Commonwealth of Pennsylvania and
forwarded to the Pennsylvania State Ethics
Commission within 30 days of the 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 third quarter of 2021 as required by Section 13A05 of the Lobbying
Disclosure Law.
Free LibraU of Philadelphia Foundation, 22-001-L
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Accordingly, we hold that Respondent, as a registered principal, failed to timely file
quarterly expense reports with the Department of State for the third quarter of 2021 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 $9,000.00 payable to the Commonwealth of Pennsylvania and forwarded to
this Commission within six (6) months of the final adjudication in this matter and which may be
paid in two (2) installments.
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 Free
Library of Philadelphia Foundation in the total amount of $9,000.00 for its delinquent quarterly
expense report for the third quarter of 2021.
To the extent it has not already done so, Respondent Free Library of Philadelphia
Foundation is directed to pay the aforesaid administrative penalty in the total amount of $9,000.00
to be made payable to the Commonwealth of Pennsylvania and forwarded to this Commission by
no later than six (6) months 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 "P01056," Free Library of Philadelphia
Foundation 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. Free Library of Philadelphia Foundation, in its capacity as a principal registered with the
Department of State under principal registration number "P01056," failed to timely file
quarterly expense reports with the Department of State for the third quarter of 2021 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.
Free Library of Philadelphia Foundation, 22-001-L
Page 15
4. The prerequisite service of a warning notice in accordance with Section 63.4(1) of the
Lobbying Disclosure Regulations, 51 Pa. Code § 63.4(l), was satisfied.
Based upon the totality of the circumstances in this case, the imposition of an
administrative penalty in the total amount of $9,000.00 is warranted.
In Re: Free Library of Philadelphia Foundation, File Docket: 22-001-L
Respondent Date Decided: 6/28/22
Date Mailed: 6/29/22
ORDER NO. 152-SL
Free Library of Philadelphia Foundation, in its capacity as a principal registered with the
Pennsylvania Department of State ("Department of State") under principal registration
number "P01056," failed to timely file quarterly expense reports with the Department of
State for the third quarter of 2021 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.
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 Free Library of Philadelphia Foundation in the total amount
of $9,000,00 for its delinquent third quarter 2021 expense reports.
4. To the extent it has not already done so, Free Library of Philadelphia Foundation is ordered
to pay the aforesaid administrative penalty in the total amount of $9,000.00 to be made
payable to the Commonwealth of Pennsylvania and forwarded to the Pennsylvania State
Ethics Commission by no later than six (6) months after the mailing date of this Order.
Noncompliance with Paragraph 4 of this Order will result in the Commission initiating
appropriate enforcement action(s).
BY THE COMMISSION,
Mark R. Corrijan, Acting Chair