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Questions of note

The Board of Ethics offers informal advice on ethics in response to City employees, officers, and other stakeholders. This page contains a selection of responses to questions about complying with public integrity laws.

Learn more about how to ask the Board of Ethics for advice.

Campaign finance

Are the City’s contribution limits based on the election or the year?

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May an individual contribute $3,100 to a candidate for City office on December 30, 2021 and make another $3,100 contribution to the same candidate three days later?

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May a candidate for City elected office use a political committee they previously used in a different race to support their candidacy for a different City elective office?

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If a candidate for City office has a political committee in addition to their designated candidate committee, may that other committee make a contribution to the candidate’s candidate committee?

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May a candidate for City elected office, who also has a federal political action committee, transfer funds from the federal PAC to their local candidate political committee?

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May a political action committee accept corporate contributions?

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Are the campaigns of candidates for City election allowed to use credit cards in spending money?

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May two candidates, running for elected office as a slate, split expenses on their Campaign Finance Reports?

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For purposes of the City’s Campaign Finance Rules, when does an individual become a candidate for City elected office?

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If an individual registers a political committee with the Department of State and authorizes that committee to accept contributions on their behalf, is that person a “candidate” under the City’s Campaign Finance Law?

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What are the contribution limits for partnerships under the City’s Campaign Finance Law and does it matter if the partnership is doing work for the City?

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Does a candidate’s campaign for City office that is carrying debt need to file campaign finance reports even if the relevant election the candidate ran for is over?

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What is the corporate status of a political committee after filing a Political Committee Registration Statement with either the City Commissioners or Department of State?

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How would someone set up a political committee, what type of entity would that political committee be, and where and how must such a committee file campaign finance reports?

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May the candidate committee of a candidate for City office use contributions received to make a contribution to a candidate for a judicial office?

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Do the City’s Campaign Finance contribution limits apply to contributions to the political committee of a ward?

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What is the proper procedure for a campaign that has inadvertently accepted a prohibited contribution from a corporation?

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Must a registered Political Action Committee amend its City campaign finance report if it discovers a previously undisclosed contribution from a non-City candidate regarding a non-City election?

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If a PAC or an individual hosts a fundraiser for a candidate, are contributions from third-party attendees attributable to the host?

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What steps are required if a registered political committee wants to change its name?

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May a campaign use excess pre-candidacy contributions to pay for polling or research that will be used to decide whether a candidate should run for office?

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If a group endorses a candidate, does that automatically make all of their political expenditures coordinated with that candidate?

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Conflict of interest

May a City employee take official action that would affect the financial interests of a person who was a client of theirs prior to joining the City?

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May a City employee use their City title in providing an unpaid endorsement of a company that provided services to a non-profit of which the employee is an unpaid officer?

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May a City employee provide free consulting services to their church regarding a project involving the church and the employee’s City department?

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May a City employee who, as part of their job, awarded a contract to a consulting firm retire from their City job and work under that same contract?

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If a member of a City advisory board is also an employee of a local governmental authority, would the City’s Conflict of Interest Rule prohibit them from taking official action via their role on the advisory board if that action would affect the financial interest of clients of the local governmental authority?

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May a City employee serve as a paid arbitrator in the Philadelphia Court of Common Pleas/ Mandatory Arbitration Program?

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Can a City Council staffer continue to serve as unpaid executive director of a community non-profit?

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Financial disclosure

Must an elected City officer submit both the City and State Statement of Financial Interest Forms?

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How must a City employee, who files the City’s Statement of Financial Interest, report rental income from multiple tenants?

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When disclosing rental income on the City’s Statement of Financial Interest, must a filer disclose the actual rent received or such rent minus mortgage and other property expenses related to the rental property?

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If a City Form filer experiences a net loss from a business, but their gross earnings from that business were more than $500, must they still list the business in the “Sources of Income” section of their City Statement of Financial Interest?

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How must a filer report spousal support, alimony, and child support on both their City and State Statements of Financial Interest?

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Does Section 20-610 require a City form filer to disclose gifts received during the reporting year, but after they left City service?

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If an employee leaves employment in January of 2021, what financial disclosure forms must they file?

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Does an elected official need to disclose on their annual City Statement of Financial Interest free tickets received for an event if the official gives the tickets to constituents?

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Gifts and gratuities

May a City employee accept a meal offered as part of a business meeting organized by someone who is seeking official action from them?

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May a City employee donate to a toy drive organized by a business that interacts with the employee and their City department?

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Does the exception for City employees to accept free attendance at events that benefit the City and are related to their official duties permit an employee to accept more than one ticket so that they may bring a guest?

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May City employees and their families participate in a COVID vaccination program that rewards participants with gift cards, where the source of the gift cards is a private company that has a contract with the City?

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May City employees participate in a COVID vaccine sweepstakes that is sponsored and funded by private parties and promoted by the City?

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May a City employee accept a “gift” or “honorarium” in exchange for professional services, other than the services that they provide as a City employee, they provide to a third party?

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May a City employee re-direct an honorarium that is prohibited by the State Ethics Act to a third-party?

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May a City Officer solicit a gift to a non-profit from someone who is seeking official action from that City Officer?

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Interest in City contracts – 10-102

Lobbying

May an individual who has not yet registered with the Board as a lobbyist lobby City officers and employees?

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If a lobbyist works with a freelance reporter to draft an opinion piece by that reporter about a matter promoted by the lobbyist’s principal, does the time spent by the lobbyist count towards the City’s lobbying reporting thresholds?

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Should a company that provides social media services to a lobbying firm register as a lobbyist?

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Other

What are the Ethics rules and requirements for a member of the Philadelphia Board of Ethics?

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Are employees of the Defender’s Association of Philadelphia subject to the City’s Ethics Rules?

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Would the City’s ethics rules prohibit a person who provided services to the City as an independent contractor from becoming a full-time City employee?

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Political activity

May a City employee serve as a committeeperson?

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May a City Council employee serve as a committeeperson?

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May an executive branch City employee on a leave of absence participate in a campaign for local elective office?

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May a City employee who is on leave of absence to serve as a board member of a City employee union also serve as a ward leader for a political party?

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May a City employee speak about their employment duties and responsibilities at an event hosted by the local chapter of a partisan political group?

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May a City advisory commission host an open forum for judicial candidates?

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Do the City’s Political Activity Rules apply to an election for a position on an advisory board of a non-profit or community organization?

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May a City employee’s spouse engage in political fundraising?

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May an employee of the Law Department volunteer for a candidate for District Attorney?

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May a City Council employee assist a PAC in filing campaign finance reports in exchange for payment?

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Does a City employee who wishes to run for Judge of Elections need to resign from their City position?

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May a City employee circulate nomination petitions for judicial candidates?

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May a member of a City board that exercises significant powers of government serve as an officer of a partisan political group?

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May a political party reserve a City firehall for a political event?

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May an employee of the City’s District Attorney’s Office attend a political event for a candidate running for District Attorney?

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May a City Council employee appear in a political campaign commercial?

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May someone who serves on a City Board that exercises significant powers of government run for judicial office?

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May a member of a City Board that exercises significant powers of government serve as the chair of a local political party’s finance committee?

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May a member of a City Board that exercises significant powers of government serve as a member of a host committee for a candidate running for U.S. Senate?

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Do the City’s political activity restrictions apply to City contract employees?

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May a City employee attend a political fundraising event in their official capacity?

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Post-employment

May a City employee continue to assist the City in hiring the person who will fill their former City position after they leave their City office?

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Does the post-employment restriction found at Code Section 20-603 permit a former City employee to present their personal opinions at a hearing held by their former City Department on a matter in which the former employee participated while working for the City?

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Is a City intern subject to the State’s One-Year post-employment rule? (prohibiting them from being paid to represent someone before their former governmental body for 1 year)

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Representation

May a City employee volunteer as an attorney, on a pro bono basis, for a non-profit, legal service?

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May a City employee represent criminal defendants in Philadelphia’s Court of Common Pleas and Municipal Court?

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May a former member of a City board represent clients before that board?

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May a City employee seek payment of fees owed to them by the City for work done by the employee before they joined the City?

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May a City employee respond to a City-issued survey regarding the City budget and express their opinion on where City funds should be prioritized?

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