On behalf of the Board of Ethics, I welcome this opportunity to report on the Board’s activities and accomplishments in Fiscal Year 2025. This Report describes the Board’s efforts to fulfill its Charter-mandated responsibility to administer and enforce “all provisions of . . . [the] Charter and ordinances pertaining to ethical matters.” These ethical matters, collectively known as the City’s Public Integrity Laws, include the Campaign Finance, Ethics, Lobbying, and Financial Disclosure Laws and the Charter’s political activity restrictions.

In FY2025, the Board and its staff continued, with tremendous energy and diligence, to uphold the Board’s extensive mandate to administer and enforce the City’s Public Integrity Laws. In its various sections, this Report describes our many accomplishments, but in this introductory statement I wish to highlight several developments of which the Board is especially proud or which we deem to be especially noteworthy.

FY2025 has been a pivotal year for the Board’s compliance arm.  The Board is tasked with supporting compliance with three disclosure programs: financial disclosure; lobbying; and campaign finance. Under these disclosure laws, members of the regulated community must submit formal disclosure filings to the Board. These disclosures are posted electronically to inform the public and to promote the goals of transparency and good government.  Ensuring timely and adequate disclosures is one of the Board’s most important obligations.

It is also, however, one of the Board’s most time- and resource-intensive endeavors. Determining and monitoring who needs to file what, when and where – especially when the regulated community includes thousands of individuals and entities – has always been one of the Board’s most daunting challenges.

To promote compliance with these public disclosure requirements, the Board created a new Compliance Team by promoting Bryan McHale, a long-serving employee, to the new position of Director of Compliance and Administration. Bryan’s compliance mission is supported by two new Investigative Analysts hired by the Board in FY2025. This new Compliance Team has already made a significant impact on the City’s public disclosure process.  

For example, in FY2025 the Board implemented new protocols to administratively assess penalties for late-filed lobbying and campaign finance disclosures. These protocols will streamline the Board’s process to address late filings while also freeing up resources for other matters.  More information about the Board’s Compliance work and the new protocols can be found in the Compliance section of this report. 

I am also pleased to report on the Board’s FY2025 training activities.  Educating the regulated community about the Public Integrity Laws is one of the Board’s key obligations. In FY2024, the Board repealed and replaced Regulation No. 7 (Required Ethics Training). A key aspect of the new regulation was to require recurring ethics training for all City employees at least every five years. In FY2025, Board Staff offered ethics training in a variety of formats and locations to make it easier for City employees to access training sessions.  These efforts are discussed in detail in the Training section of this report. I do want to highlight here that Board Staff trained 3,100 people in FY2025 – the most since at least 2019.

I would be remiss if I didn’t mention certain recent changes to the composition of the Board. In FY2025, we said farewell to Board Members Brian McCormick and Sanjuanita Gonzalez, who each served on the Board for over 11 years. I note that I also had the honor of serving with the late Judge Phyllis Beck (Ret.), a former judge of the Pennsylvania Superior Court and the former Vice Chair of the Board, and the late JoAnne Epps, a former President of Temple University. We also recently welcomed three new members – Dr. Valerie Harrison, Judge Nelson Diaz (Ret.), and James Engler – all of whom are serving the Board with zeal and distinction. Since the retirement of Brian McCormick, Ellen Mattleman Kaplan has ably served as Vice-Chair of the Board. 

Finally, and on the topic of change, I note that, barring extenuating circumstances, FY2026 will represent my last year as a member of the Board with my final term ending on November 16, 2025. As such, this will probably be my last “Annual Message” statement. I would like to take this opportunity to express my sincere gratitude to Mayors Michael A. Nutter and James F. Kenney for appointing and reappointing me to the Board, and to City Council for confirming my appointments. I believe that the Board plays an important role under the Home Rule Charter in helping the City of Philadelphia maintain the high standards of ethics in municipal governance for which it is now known. To continue to fulfill this important role, the Board will need the support of the Administration and City Counsel through adequate funding. 

Michael H. Reed, Esq., Chair

City of Philadelphia Board of Ethics

We saw significant changes to the Board and staff in FY2025.

In his Annual Message, Chair Reed highlighted our new Compliance Team, led by the Board’s new Director of Compliance and Administration, long-serving staff member Bryan McHale, who is supported by two new Investigative Analysts, Diana Gavrykh and Alex Kramer. Together, this new Team leads the effort to help people comply with the three public disclosure systems that the Board administers and enforces.

The Compliance Team’s goal is to maximize those public disclosures in the most efficient manner so that citizens have access to the best and most complete information about how money is raised by City candidates and used to influence City elections (campaign finance), how money is used to influence City actions (lobbying) and on financial information about City officials (financial disclosure).

Before the Compliance Team was formed, it was largely up to the Enforcement Team to ensure that people and groups were making the right public disclosures. Now, the Compliance Team will assist with information about the various filing requirements, including who needs to file, when they need to file and what they need to disclose to the public using a much more efficient process.

As Chair Reed explained, the Compliance Team has developed protocols for late filers that dispose of most matters without the need to have the Enforcement Team spend its limited time investigating every case. Only those filers who ignore the Compliance Team’s efforts will be referred to the Enforcement Team. We believe that the new Compliance Team is the best use of limited staff to maximize accurate disclosures in all three categories.   

While the Compliance Team represents the biggest change with staff, there have been changes to Board composition, as described by Chair Reed. I should note that Chair Reed is serving in his 14th year on the Board and is the longest-serving Board member. Unfortunately, as he explains, 2025 is the last year of Chair Reed’s second and final term on the Board and Mayor Cherelle Parker may appoint his successor by the end of 2025.

After a fair degree of Board member turnover in the first 4-5 years, the Board had a very stable ten-year period (from 2012 to 2022), when it had the same five members, led by Chair Reed. Since then, we have had two new Board members in 2023 and two new members in 2024. It is possible that we will have an additional two new Board members by the end of 2025, including Chair Reed’s successor.

Chair Reed is the last remaining Board member who connects the Board to its early years, and the Board may be composed of relatively all new members by the end of 2025. Our task as an agency is to maintain continuity during this transition and plans for that are underway. I remain extremely proud of the work that we do in building public confidence in the integrity of City government, through training, advice, compliance and enforcement of the City’s Public Integrity Laws and I am confident that the Board will carry on its excellent work into the future.

J. Shane Creamer, Jr., Executive Director

City of Philadelphia Board of Ethics