The contribution limits are annual.

Yes. The City’s Campaign Finance Law limits individual contributions to a candidate to $3,100 per calendar year. As such, the contributions the requestor asked about are permissible even though they are only three days apart because they are made in different calendar years.

Yes.  And, unused funds from the prior election may be used for the new election.  For example, a current City Councilmember may use the candidate political committee that they previously used to run for City Council to now run for Mayor and, in doing so, they may utilize unused funds from the previous councilmember election in their new campaign for Mayor.  As with any candidate, however, they must take care to comply with the rules set forth in Board Regulation No. 1 regarding excess pre-candidacy contributions.

Yes, subject to the annual contribution limit of $12,600.  Aside from exceptions specifically provided for in the Campaign Finance Law, the candidate could not use the other committee to make expenditures related to the City election in which they are participating.

Yes, but that transfer would be subject to the City’s annual contribution limit of $12,600.

No, unless the committee is registered as an Independent Expenditure Committee.  A political action committee that makes contributions to candidates may not accept corporate contributions.

Yes, but on the applicable campaign finance reports, the campaign must itemize each purchase made with the credit card, and not merely list a lump sum payment from the campaign to the credit card company.

Generally, yes.  Such split expenditures, however, would be in-kind contributions from each candidate to the other and those transactions would be subject to the contribution limits.  They would also need to be reported as in-kind contributions by each recipient candidate.  Each candidate would also need to disclose their share of the expenses in the expenditures section of the report and would need to accurately describe those expenditures.

Under the City Campaign Finance Rules, an individual becomes a candidate when they either: (i) file nomination papers or petitions for City elective office, or (ii) publicly announce their candidacy for City elective office.  The Board has previously advised that an individual does not “publicly announce their candidacy” unless they make an explicit, public statement that the individual is seeking elective office.  Public statements that an individual is considering or exploring a run for office do not constitute a public announcement.

No.  Under the City’s Campaign Finance Law, a person does not become a “candidate” unless they publicly announce their candidacy for a City office or they file papers to be placed on the ballot.  Authorizing a political committee to accept contributions on their behalf would make a person a “candidate” under State Law, but not under the City’s Campaign Finance Law.

Under the City’s Campaign Finance Law, the limit for a contribution from a partnership to a candidate is $12,600 per calendar year.  This is the limit regardless of whether the partnership does business with the City.  Importantly, however, if the partnership seeks, or holds contracts with the City, it is subject to additional disclosure requirements and attribution rules as set by Philadelphia Code Chapter 17-1400.

Yes.  So long as a former candidate’s candidate committee is carrying debt from a City election, it must file campaign finance reports with the Board.

After filing the Registration Statement, the political committee becomes an unincorporated association under State Law.

Anyone who wishes to set up a political committee may do so by filing a Political Committee Registration Statement with either the City Commissioners or Department of State.  By doing so, the Committee will be established as an unincorporated association.  A political committee must file with the Board for any reporting cycle in which it makes expenditures to influence a City election.  A political committee must file with the City Commissioners for any reporting cycle in which it makes expenditures related solely to City races and with the Department of State for any cycle in which it makes expenditures related to a State election.  All filings with the Board must be submitted electronically via the City’s filing system.  Filings with the Commissioners may be submitted either electronically via the City’s filing system or on paper.  Filings with the Department of State may be submitted either electronically via the State filing system or on paper.

Yes.  A contribution to a candidate for judicial office is a permissible use of campaign funds.

No.  The City’s contribution limits only apply to contributions to City candidates.  They do not apply to contributions to ward committees.  Importantly, however, if a donor passes a campaign contribution to a City candidate through a ward committee, the amount given to the candidate will count towards the limits for both the ward committee and the original donor.

The funds need to be immediately returned.  For purposes of Campaign Finance Reports, the prohibited funds should be listed as “contributions” reporting the date they were received.  Then, upon returning the funds, the funds should be listed as “expenditures” reporting the date they were returned and a note that the funds are a refund of the prohibited corporate contributions.

Yes.  If a PAC is required to file a campaign finance report with the Board, it must accurately disclose all required transactions for the applicable time period.  As such, if after filing the report the PAC discovers an error, it should file an amended report to ensure accurate reporting.

No.  For purposes of the City’s Campaign Finance Law, if an individual makes a contribution directly to the candidate, it is attributable to that individual even if the contribution is made at an event hosted by a different person or entity.  Importantly, a different result may occur under Code Section 17-1400 regarding Non-Competitively Bid Contracts.

If a political committee wants to change its name, it should file an amended political committee registration statement with the City Commissioners.

Yes, but the campaign may not later use polls or research paid for with such funds after the person becomes a candidate.

No.  A political endorsement – on its own – does not render all subsequent expenditures by the endorsing entity coordinated with the endorsed candidate.

As per Board Regulation No.1, Paragraph 1.35, an expenditure will not be considered a coordinated expenditure merely because the entity making that expenditure has invited the candidate to make an appearance before the entity’s members, employees, or shareholders or has endorsed the candidate.

Coordination would arise however, if at any time, including during the event, the entity tells the candidate what its spending plans are, or asks the candidate what kind of spending would be helpful, or engages in similar discussions.

Under Regulation 1.33(d), if a campaign solicits funds for or directs funds to a person who them makes an expenditure supporting that campaign, that expenditure is considered coordinated if the solicitation or direction occurred within the 12 months before the election that the expenditure seeks to influence.

The loan must be disclosed (1) as an expenditure by the candidate and (2) as both a contribution received and an unpaid debt by the candidate committee.  The committee must continue to disclose the outstanding amount as unpaid debt until fully repaid (or forgiven). If the loan was received during the 24-Hour reporting period, the committee must also disclose it as a contribution received on a 24-Hour report.  Note that so long as the loan was made by the candidate to their own candidate committee using their personal financial resources, it would not be subject to the contribution limits.

No. PACs generally only file with the Board if they make expenditures to influence a City election. The PAC may, however, be required to file with the Department of State or City Commissioners.

Prior to an announcement of candidacy, the committee may use its cash on hand to purchase whatever it likes.  If, however, the committee uses excess pre-candidacy contributions for pre-payments, that will affect the amount of money the committee will have to exclude from its checking account once an announcement of candidacy occurs. A pre-payment is a payment for anything used or to be used by a committee/campaign once the announcement of candidacy has occurred.

The precise of amount of money that a campaign will need to exclude from its checking account will depend on a full accounting. As a practical matter, if a committee/campaign wants to use something post-announcement, it should not use excess pre-candidacy contributions to pay for it.

Neither the City’s Campaign Finance law nor the State Election Code restricts contributions based on the location of the donor. The same contribution limits and reporting requirements apply to City candidate committees regardless of the location of the donor. It is our understanding, however, that federal law prohibits contributions from foreign nationals, but permits contributions from U.S. citizens living abroad.

No. The State Election Code prohibits contributions from corporations and unincorporated associations. This includes not only for-profit entities, but also nonprofit organizations such as 501(c)(3) and 501(c)(4) nonprofits.

An out-of-state PAC that contributes to a City campaign (or makes any other expenditure to influence a covered election) must file campaign finance reports with the Board of Ethics and the City Commissioners.  Those reports must include all campaign finance activity, not just activity related to City elections, though the State Election Code allows non-Pennsylvania expenditures to be reported as a lump sum.

No.  Expenditures for republication of communications or materials prepared by a campaign, including video footage, are in-kind contributions. Such expenditures are a contribution received by the campaign if the communications or materials are obtained from or with the consent of the campaign. Unless an exception in Board Regulation No. 1, Paragraph 1.34(c) applies, republishing video footage obtained either from the campaign or from a third party authorized by the campaign to distribute that footage would be an in-kind contribution. This would still be the case even if the committee paid market rate for the footage.

Yes.  For campaign finance purposes, however, the expenditures the political committee makes regarding this activity (e.g. costs for printing recruiting pamphlets or paying staff to attend recruitment events) would constitute in-kind contributions to the campaign and are subject to both contribution limits and disclosure requirements.

Yes, so long as each LLC meets the requirements of both City and State law to make political contributions.  Under Board Regulation No. 1, an LLC is only eligible for the higher contribution limit for political committees and other organizations ($12,600 or $25,200 if doubled) if the LLC is taxed as a partnership and the finances of the LLC are distinct and segregated from the personal finances of its proprietors or partners. Under State Law, an LLC making a contribution to a campaign must affirm to the recipient that: (1) the LLC is a partnership for federal tax purposes; and (2) the contribution does not contain any corporate funds (such as from a partner or member that is a corporation). So long as the two LLCs meet these requirements, each may contribute up to $12,600 ($25,200 if doubled) to a City candidate committee. The owner of the LLCs cannot, however, move money from his personal account into the LLCs or shift money among these LLCs or other businesses for the purpose of making such contributions.

Yes, those offices which had doubled limits for the Primary Election will continue to have doubled limits for the General Election. This is true even if the candidate who initiated the doubled limits is not running in the General Election.

A candidate committee (or any other political committee) must file at least a Cycle 7 Annual Report each year until the committee is terminated. Under state law, a committee cannot be terminated so long as it has funds or is carrying debt.  It can zero out its account by resolving its debts, spending leftover funds on other elections or returning such residual funds to contributors. If the committee makes expenditures to influence an election, the committee is also required to file a campaign finance report to the appropriate offices for any cycle in which it made such expenditures. Once a committee no longer has any remaining funds or debts, the committee may file its next campaign finance report as a termination report.

No. Under the City’s Campaign Finance Law, donors must give to a specific campaign, and the recipient campaign must deposit that money into a single account. Once the money is in a campaign’s checking account, any transfer they make to another campaign is subject to the contribution limits. For example, if Campaign A collected the money for the fundraiser, Campaign A could only contribute up to $12,600 of the proceeds to Campaign B. Any transfer of funds from A to B beyond that would be excess contributions. If donors want to contribute to both Campaign A and Campaign B, they should do so with separate checks or other separate payments.

Yes.  The City and State Conflict of Interest restrictions only apply to current financial relationships.  So long as the present financial relationship does not exist, a conflict of interest will not arise.  As such, a City employee is not prohibited from taking official action that would affect a former client.

No.  Because the City employee is not compensated by the non-profit or the company the City’s Ethics Code would not prohibit them from doing so.  The State Ethics Act, however, would prohibit the employee from using their City title for such an endorsement.

Yes, subject to some limitations.  So long as the City employee is not compensated by the church and is not an officer or director, there would not be a conflict of interest under either City or State law.  The City employee cannot, however, represent the church in any interactions with the City, such as attending non-public meetings or testifying on behalf of the church at a hearing.  Additionally, the City employee cannot share confidential information obtained through their City work with the church.

No, at least not until two years have passed after their retirement.  Philadelphia Code Section 20-607(3), provides that a City employee may not acquire a financial interest in any official action they take while working for the City for two years after separation from City service.  Being paid out of a contract the employee had awarded would constitute acquiring a financial interest in prior official action.

No.  The City’s conflict of interest rule does not apply to action that affects a governmental entity.  In addition, the clients of the governmental entity do not affect the financial interest of an employee of the governmental entity, unlike if the employee was a partner in a law firm.

Yes.  The City employee, however, may not serve on an arbitration panel where the City is a party or the matter concerns a transaction involving the City.  In addition, the employee would be prohibited from taking any official action in their City job that would affect the financial interest of any of the parties in an arbitration they work on.  Lastly, a City employee could only serve on an arbitration panel during their off-duty hours and could not use any City resources for that purpose.

Yes, so long as the Council staffer abides by the applicable conflicts of interest, representation, and interest in City contract restrictions found in the City Code and Charter and the State Ethics Act.

Yes.  The City’s Ethics Code requires all City elected officers (the Mayor, City Councilmembers, the City Controller, the District Attorney, City Commissioners, and the Sheriff) to file an annual Statement of Financial Interests.  The State Ethics Act requires those same City elected officers to file a similar, but different, annual Statement of Financial Interests.

The filer has two options.  The first is to separately list each tenant from who the filer received more than $500 in rent.  The filer would also need to list the amount paid by each tenant who paid more than $5,000 in rent.  The second option is to list in the “person” field “five rental properties” and list the total combined amount from all five income sources in the previous year.

A filer must disclose the full rent.  As with other forms of income, filers must disclose the gross, not the net, amount.

Yes.  Filers are required to disclose any person who is the source of more than $500 in gross income.  It does not matter if the filer’s net income for the business was below $500.

Spousal support, alimony, and child support a filer receives are considered income for the purposes of City and State Statements of Financial Interest and therefore must be reported if the amount received exceeds the reporting thresholds.  That said, the filer would not need to disclose any payments that are court ordered as the State Ethics Commission would consider them to be within a statutory exception for “governmentally-mandated payments or benefits.”

Yes. Filers must disclose the source, value, and circumstances of any gift over $200 in value received during the reporting year.  This applies to the entire reporting year, even if the gift was received after the filer was no longer a City officer or employee.

An employee who is required to file a statement of financial interest pursuant to the State Ethics Act or the City Ethics Code must, in 2021, file a statement for 2020 and in 2022 file a statement for 2021.

No, so long as they give such tickets to constituents (but not to a family member or a member of their campaign staff), the elected official does not need to disclose them in the gifts section of the Statement of Financial Interest.

No. While loans forgiven by private lenders must be reported as income on the City and State Statements of Financial Interest, neither City nor State law treats loan forgiveness under a government-mandated program (e.g. Public Service Loan Forgiveness) as income.

Yes. Filers must disclose all sources of income above the reporting threshold for the preceding calendar year regardless of whether the filer worked for the City during some, all, or none of that year. This means that new City employees filing for 2022 would list any previous employers as sources of income for that year if it crossed the reporting thresholds.

Yes.  City Code Section 20-604(3)(f) permits City employees to accept food and beverages provided in the ordinary course of a meeting as long as they are provided on-site and are offered to all participants.

Yes. The City’s Ethics Code restricts gifts to a City officer or employee. Here, the City employee is giving, rather than receiving, a gift. As a result, even if the business in question is a restricted source for the employee, that restriction does not extend to gifts from the employee to the business.

Generally, no.  The exception in Code Section 20-604(3)(k) applies to gifts that “benefit the City and [are] reasonably related to the officer’s or employee’s official duties or expertise.”  A City employee may accept a ticket under this exception if (1) their attendance as a City representative benefits the City and (2) they receive prior approval.  It would not permit them to accept a second ticket since, absent an unusual situation, the attendance of a guest would not carry a benefit for the City.

Yes, although a City officer or employee, who interacts with the company as part of their City job would not be permitted to accept a gift card.  The Ethics Code would not, however, prevent family members of such a City officer or employee from accepting the gift cards.

Yes, unless the City employee interacts with the funders of the sweepstakes as part of their City duties.  But, the Mayor’s Executive Order on gifts would likely prohibit the employee from accepting a prize from a sweepstakes unless they received a waiver from the Chief Integrity Officer.

Yes.  Any payment that a City employee receives in exchange for independent professional services they provide is not a “gift” or “honorarium” even if it is so designated by the parties.  As such, the employee may accept them as compensation for the independent services they provide.  Notably, in these situations, the City employee is still subject to other ethics rules such as the Conflicts on Interest Restrictions, Representation Restriction, and rules regarding outside employment.

No.  Pursuant to Section 1103(d) of the State Ethics Act, a public employee may neither accept an honorarium to a third-party, even if that third-party is a non-profit or charitable organization.

Yes, under the City’s Ethics Code, so long as the City Officer would not receive any personal benefit from the gift.

Yes. In general, so long as City employees do not keep any of the donations for personal use, they can collect items for donation to a nonprofit without violating the ethics rules. A conflict of interest could arise, however, if the City employee(s) organizing the collection, or their close relatives, are affiliated with the nonprofit, such as by being employees or board members.

Yes.  Individuals are not required to register with the Board until they have earned more than $2,500 for lobbying services in a quarter of a calendar year.

Yes.  The opinion piece is an indirect communication and the time the lobbyist spends working on it constitutes reportable lobbying activity.

No.  Generally speaking, a vendor for a lobbying firm would not be required to register with the Board.  That said, the principal that retains the lobbying firm would need to disclose on its quarterly expense report any monies paid to a social media company for services it provides to the lobbying firm related to lobbying efforts on the principal’s behalf.

Members of the Board of Ethics are subject to the general Ethics rules and requirements that
apply to all members of a City board or commission that exercises significant powers of
government, such as the restrictions on conflict of interest rules and political activities.  The
Charter imposes additional rules on members of the Ethics Board, however, such as the
requirement that they must be residents of or have their primary place of business in the City and be registered to vote.  In addition, Board members may not hold another public office (other than a purely advisory position) and they may not make contributions to any candidate for City office or to any incumbent City elected official.  Lastly, they may not seek elective City office for two years after serving as a member of the Board of Ethics.

No.  The Defender’s Association is not part of City government and therefore its employees are not subject to the City’s Ethics Rules.

No, the ethics rules would not prohibit the individual from transitioning from an independent contractor role to full-time City employee.

No. The City’s Ethics rules do not apply to the employees of authorities created pursuant to State Law – even if the authorities are somehow based in or related to the City of Philadelphia.  Thus, for example, employees of the Philadelphia Redevelopment Authority, the Philadelphia Energy Authority, and the Philadelphia Authority for Industrial Development are not subject to the City’s Ethics rules.  Such employees may be subject to the State Ethics Act, however.

No.  Section 10-107(4) of the Home Rule Charter prohibits most City employees from serving as a committeeperson.  City Council employees, however, are exempted from that prohibition.

Yes.  A City Council employee is permitted to be a committeeperson, to run for that office, and to circulate nominating petitions.  However, all such activities must be conducted off-duty and without using City resources or the employee’s City title.  In addition, the Home Rule Charter would prohibit the employee from engaging in any fundraising related to these activities.

No.  Employees on leaves of absence are subject to the City’s political activity restrictions, unless they are on unpaid leave to be a full-time elected officer or appointed member of a City employee union.

Yes.  While the City’s political activity restrictions generally prohibit most City employees from serving as ward leaders, Paragraph 8.1(h) of Board Regulation No. 8 provides that these restrictions do not apply to City employees “on unpaid leave to be a full-time elected officer or appointed staff representative of a City employee union.”

No.  Section 10-107(4) of the Charter prohibits City appointed officers and employees from taking “any part in the management or affairs of any political party, partisan political group or political campaign.”  This would include speaking at an event hosted by a partisan political group, even if the employee does not intend the content of their speech to support or oppose that group’s political aims.  City employees are also prohibited from engaging in political activity while on duty, using City resources, or using their City title or position.  Where a City employee is asked to speak about their City position and responsibilities, they would necessarily be appearing in their official capacity and would be using their City title and status.

No.  Members of advisory boards and commissions are prohibited from engaging in political activity while using their City title, City resources, or the authority of their City position.  An event at which candidates will promote their campaigns is political activity.  As such, a City officer could not participate in such an event in their official capacity and could not use City resources to promote or organize the event.

No.  The City’s Political Activity Rules only apply to elections to public office.  As such, a City employee may participate in an election for a position on an advisory board of a non-profit or community organization.

Yes.  A City employee’s spouse may participate in political fundraising activities, but the City employee must ensure that they play no role whatsoever is such activities.  For example, the City employee must ensure that their name does not appear on any correspondence or promotional materials related to the spouse’s political fundraising.

No.  An employee of the Law Department may only volunteer on campaigns for non-local elections (for example: Pennsylvania Governor or U.S. President).  The election for Philadelphia District Attorney is a local election.

Yes.  The political activity restrictions found in the City’s Home Rule Charter would permit a City Council employee to assist a PAC in preparing a campaign finance report.  But, Section 20-602 of the Ethics Code would prohibit the employee from submitting the report to the Board of Ethics or City Commissioners on behalf of the committee as such interaction with those offices would constitute prohibited representation of another person in a transaction involving the City.

Yes.  Pursuant to Charter Section 10-107(5), a City employee must resign from their position to run for this public, elected position.

It depends.  Charter Section 10-107(4) prohibits all City employees, except for employees of City Council, from circulating nomination petitions for a candidate for local office.  This includes the Philadelphia Court of Common Pleas and Municipal Court.  City employees may, however, circulate nomination petitions for a candidate for non-local office (such as Commonwealth Court or PA Supreme Court), but not if they are employees of the Police Department, the Board of Ethics, or the Office of the City Commissioners, Sheriff, or District Attorney.  Even when circulation of petitions is permissible, a City employee may never conduct such activity while on City duty, using City resources, or while on City property.

No.  The City’s Home Rule Charter prohibits members of boards that exercise significant powers of government from being an officer of a partisan political group and also from being involved in the management of such partisan political groups.

Yes, if the firehall is a publicly available meeting venue that any entity or organization may utilize for similar events.

Yes.  The District Attorney employee, however, may only attend the event as a spectator.  Such an employee may not, for example, be involved in organizing or managing the event.

Yes, so long as the City Council employee is not on duty and does not use their City title or any City resources during their appearance in the commercial.  The City Council employee may not, however, appear in a commercial soliciting contributions for a campaign or political party.

No.  Home Rule Charter Section 10-107(5) requires such City officers to resign before seeking public elective office, which includes an election for a judicial office.  In addition, Charter Section 10-107(4) prohibits such City officers from participating in such elections as a candidate.

No.  A member of a City Board that exercises significant powers of government is prohibited from being an officer of a political party and may not take any part in the management of a political party.  Additionally, such a City officer is prohibited from being involved in political fundraising.

No.  A member of a City Board that exercises significant powers of government is prohibited from being an officer of a political party and may not take any part in the management of a political campaign.  This prohibition applies to these board members even if the political campaign regards a federal, non-local election.  Additionally, such a City officer is prohibited from being involved in political fundraising.

No.  Importantly, however, the underlying employment contracts might include terms related to political activity restrictions which the contract employees would be subject to.

No.  Attending a political fundraiser is political activity and under the City’s Political Activity Restrictions, City employees may not engage in political activity while on duty or using their City title or status.

In addition to the rules that normally apply based on the office where the individual typically works, an employee temporarily assigned to assist the City Commissioners may not volunteer for any candidate, campaign, political party, or partisan political group on (1) any calendar day before Election Day on which they performed election-related duties; (2) the ten calendar days from before Election Day; and (3) if the assignment extends past Election Day, all calendar days through the last day on which they performed election-related duties.

No. The political activity rules found in the Charter and explained in Regulation No.8 only restrict the political activity of City officers and employees. If a City employee’s spouse engages in political activity that would be prohibited for the employee – such as soliciting political contributions – the employee must ensure that they do not participate in the spouse’s efforts.

No. Under the City’s Political Activity Rules, City Council employees are allowed to work on campaigns for elective office and serve as officers of partisan political groups. They are, however, still prohibited under Charter Section 10-107(3) from having any role in soliciting, collecting, or receiving contributions intended for any political purpose. Thus, while in theory a City Council employee could have a role in deciding how to spend money raised by a SuperPAC, they cannot as a practical matter serve as a board member of a SuperPAC without having “any role” in political fundraising. It should be noted that the Board has previously held in Board Opinion 2020-001 that an elected official may serve on the advisory board of a federal PAC and engage in fundraising within certain limitations. This holding, however, would not extend to a City employee.

Yes.  Code Section 20-603 prohibits a former City employee from assisting another person in a matter they participated in during their City service.  But, so long as the assistance rendered by the former City employee is not on behalf of their new employer, they would be assisting the City, not “another person.”  Moreover, in Opinion 2022-005 (PDF), the Board held that the term “person” as used in Section 20-603 does not include a governmental entity.  As such, Code Section 20-603 would not apply.

Yes.  Code Section 20-603 only prohibits a former employee from assisting “another person” in a transaction involving the City, if the former City employee participated in that transaction during their City service or employment.  As such, so long as the former City employee is not providing assistance to any other person on the matter in question, they may appear at the hearing and speak on the matter even though it involved a transaction in which they participated whilst working for the City.

It depends on whether the intern is a “public employee” as defined under the State Ethics Act.  Such status is determined by examining objective sources establishing what the intern has the authority to do as a CIty intern.

Generally, yes, but the employee must abide by both applicable City and State Ethics Laws.  For example, under the City’s Representation Rule, the City employee could not represent a pro bono client in a transaction involving the City.

Not if the case is prosecuted by the Philadelphia District Attorney.  Code Section 20-602(1)(a) prohibits a City employee from representing another person as an attorney, whether paid or unpaid, in any transaction involving the City.  Transactions involving the City include any particular matters (1) that are or will be the subject of City action, (2) in which the City is a party, or (3) in which the City has a proprietary interest.  A criminal prosecution brought by the District Attorney is a matter that is the subject of City action, whether through the District Attorney’s Office, the Sheriff’s Office, the Department of Probation and Parole, and the Prison System.  It is also a matter in which the City has a proprietary interest.  As such, Code Section 20-602(1)(a) prohibits a City officer or employee from representing defendants in such cases.

The State Ethics Act would prohibit the former board member from representing anyone for pay before that board until one year has passed from when they stepped down.  Notably, the State Ethics Commission interprets “representation” to include not only personally appearing on behalf of a client, but also submitting letters or other documents bearing the former board member’s name, although the former board member could assist in the preparation of such documents.

In addition, the City’s Ethics Code would permanently prohibit the former board member from assisting another person in any specific matter that came before the board while they were a member.

Yes.  Pursuant to Code Section 20-602, a City employee may represent themselves in a transaction involving the City so long as the matter is not subject to their official responsibility and they did not previously participate in the matter as a City employee.  As such, so long as the employee is only representing themselves and not another person, such as a law firm, they could interact with the City is seeking payment of the money owed.

Yes.  A City employee may respond to such a survey even if their responses express opinions about the budget of their own City department or agency.

Yes, a city employee can be a Block Captain, but they must comply with the conflict of interest and representation rules of the Ethics Code. For example, a City employee serving as a Block Captain may collect signatures needed to submit a routine permit application because the employee is not interacting with any government entity or representing anyone as an attorney or agent. In contrast, appearing on behalf of block residents to appeal a permit denial would be prohibited representation.