On behalf of the members of the Board of Ethics, I am proud to submit this report of the Board’s Fiscal Year 2024 accomplishments. FY2024 was an extraordinary year for the Board. The energy and enthusiasm of the Board and its small staff enabled the Board to tackle its challenging mandate to administer and enforce the City’s Public Integrity Laws. This Report describes our accomplishments in detail, but I wish to highlight several developments of which the Board is especially proud.

Our work in FY2024 built on the efforts of FY2023. The Board’s work related to the 2023 municipal election cycle did not end at the close of the fiscal year. As I noted last year in the FY2023 Annual Report, the number of City offices and candidates vying for those positions created a “perfect storm” for the Board, tasked with administering the City’s Campaign Finance Law. The election cycle spanned FY2023 and FY2024 and involved thousands of political donors (including political action committees) and millions of dollars in campaign-related contributions and expenditures. 

The Board’s advice, compliance, and enforcement efforts related to the 2023 election cycle continued well into FY2024. This included enforcement litigation brought by the Board in the Philadelphia Court of Common Pleas that continued into FY2024, as well as advice and compliance support for both winning and losing candidates and their committees after the Primary and General Elections.  

After the General Election, the Board took the opportunity to amend Regulation No. 1 (Campaign Finance) (effective May 5, 2024) to reflect the experiences of Board Staff and the regulated community during the 2023 municipal election cycle.  These regulatory updates are an important part of the Board’s commitment to continuing its improvement of the Campaign Finance landscape even without a City election on the immediate horizon.

After the November 2023 General Election, Board Staff was faced with a new – but anticipated – challenge of high turnover in the City workforce that often accompanies a new Mayoral administration. FY2024 brought both the departure of longtime City officials and the onboarding of new City leaders. The Board and staff prepared for this shift with extensive work on training and regulations. For those leaving the City, Board Staff provided extra training through confidential webinars on City and State post-employment rules. For newcomers, Board Staff worked with the Office of Human Resources and the Chief Integrity Office to provide the required introductory ethics training to those joining the new Mayor’s leadership team.   

In support of these training efforts, the Board repealed and replaced Regulation No. 7 (Required Ethics Training) in October 2023. The new Regulation No. 7 clarified the requirements for annual training for elected and other high-level officials, while adding a critical component to the Board’s training requirement – recurring ethics training for all City employees at least every five years. This new requirement involves a significant undertaking by the Board to expand its training offerings, demonstrating the Board’s commitment to using education as a primary tool to achieve compliance.

In January 2024, the Board issued Regulation No. 5 (Conflicts of Interest). This was the Board’s first regulation addressing Conflicts of Interest and serves as a comprehensive guide to the substantive and procedural aspects of the conflicts rules in the City Code. This new regulation represents a major milestone in the Board’s development.

In summary, the Board’s work in FY2024 continued to be shaped by the municipal elections. From direct work on campaign finance and political activity to a focus on training and regulations, the pre-election and post-election landscape had a profound impact on our workload and priorities.

While the work of FY2025 will inevitably have a different flavor, we look forward to providing the residents of the City with the same quality of service, dedication, and enthusiasm.

I cannot conclude this message without noting the sudden and unexpected passing of Board member JoAnne Epps on September 19, 2023. Her passing left a hole not only on our Board, but in our hearts and in this City. I was honored to present a memorial statement for JoAnne which was read at the Board’s September 27, 2023 meeting. She was a beloved and revered colleague and she is deeply missed by all of her colleagues on the Board and its staff.

Michael H. Reed, Esq., Chair

City of Philadelphia Board of Ethics

Fiscal Year 2024 was a year of multi-tasking for the Ethics Board and its staff. First, as Chair Michael H. Reed noted, we were faced with administering the 2023 Municipal Elections, where there was an open seat for Mayor, all 17 City Council seats, all three City Commissioners, and Sheriff up for election. This was only the third open seat Mayoral election the Board has administered since 2007, and several City Council members resigned to run for that office, leaving an unusually high number of City Council seats open.

Campaigns and political committees needed advice and guidance on how to comply with filing requirements and other rules which are enforced by the Board. In addition to facilitating compliance, Board Enforcement Staff was engaged in litigation in the Philadelphia Court of Common Pleas for most of 2023. Related litigation continues in 2024. During that period, the Board had an active year promulgating and amending regulations.

By passing regulations, the Board can interpret and expand on the City’s Public Integrity Laws that it administers, and the regulations passed by the Board have the force of law. Clear and concise regulations facilitate compliance and tend to reduce the need for rendering advice and pursuing enforcement. Drafting and amending regulations is a time-consuming activity for Board Staff and is a public process that enables the regulated community to provide comments that the Board must respond to. As Chair Reed explains in his Message, in FY2024, the Board amended two of its regulations (Regulation No. 7 (Required Ethics Training) and Regulation No. 1 (Campaign Finance)) and wrote one new regulation from scratch (Regulation No. 5 (Conflicts of Interest)).

Board Staff were also busy with advising and training people on the application of the Public Integrity Laws. General Counsel Staff were particularly busy advising officials leaving and entering City service with the change in Administrations.

In the past few years, we have built a team that became more seasoned with the experience of the 2023 Municipal Elections. In the coming year, we hope to build on that team, and I remain extremely proud of the work that we do in building public confidence in the integrity of City government.

J. Shane Creamer, Jr., Executive Director

City of Philadelphia Board of Ethics