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During FY2025, Board Staff responded to over 600 requests for advice across all of our program areas. Our General Counsel and Compliance teams work collaboratively to respond to requests for both advice and filing support.
Formal Advice
Formal Advice
Formal, written opinions issued by the Board or the General Counsel provide detailed analysis of the application of the Ethics Laws to the specific facts provided by a requestor. Board Regulation No. 4 has more detail about formal opinions. A searchable library of formal opinions is available at ethics.pub/opinions.
Three formal opinions ⎼ all General Counsel opinions ⎼ were issued in FY2025. Electronic copies of each opinion are available by using the links in the menus below.
Legal Authority
Legal Authority
Home Rule Charter Section 4-1100 and City Code Chapter 20-600 authorize the Board to render advisory opinions concerning a City officer or employee’s proposed future conduct. Board Regulation No. 4 describes the procedures related to advisory opinions, including for requesting reconsideration or appeal of an advisory opinion issued by the General Counsel.
Home Rule Charter Section 4-1100 also gives the Board “concurrent authority” with the Law Department to advise City officials on the application of State law. Our advice on State law, however, does not provide protection from possible enforcement by the State Ethics Commission. For guidance on the State Ethics Act that would provide such protection, contact either the State Ethics Commission or the Law Department.
Home Rule Charter Section 4-1100 also gives the Board “concurrent authority” with the Law Department to advise City officials on the application of State law. Our advice on State law, however, does not provide protection from possible enforcement by the State Ethics Commission. For guidance on the State Ethics Act that would provide such protection, contact either the State Ethics Commission or the Law Department.
Board Opinions
Board Opinions
Board opinions generally address questions that require the application of the Ethics Laws to situations that have not yet been definitively addressed by legislation, regulation, or prior Board opinions.
General Counsel Opinions
General Counsel Opinions
The Board's General Counsel issues opinions applying and explaining the ethics laws in situations where the result is clear from the law or regulation, or where the Board has already provided a relevant interpretation. The Board does not deliberate on or approve General Counsel opinions, although a requestor may appeal a General Counsel opinion to the Board.
Formal Opinion Topics
Formal Opinion Topics
The number of opinions issued and topics covered are driven by requestor needs. Post-employment was the most popular topic addressed in formal opinions this fiscal year.
Note that opinions often cover multiple topics.
Informal Guidance
Informal Guidance
Informal guidance makes up the majority of Board Staff's advice work. In FY2025, we responded to over 600 requests for informal guidance. That total, however, only tells part of the story. Advice requests range from complex legal analyses to straightforward password reset requests, and everything in between. Since FY2020, Board Staff has worked to identify and interpret trends in informal advice requests.
These are not performance measures ⎼ Staff cannot control how many requests they receive ⎼ but are part of larger planning efforts for training, educational documents, and workload allocation.
Year-at-a-Glance
Year-at-a-Glance
Overview
Overview
Total informal guidance responses give a high-level snapshot. Compared to FY2024, there was a decrease in the total number of requests resolved. This reflects a significant reduction in Financial Disclosure questions and a continued decrease in Campaign Finance advice requests. Ethics advice requests remained stable, while Lobbying requests increased slightly. The dropoff in Financial Disclosure advice as compared to FY2024 appears to be attributable to having fewer new hires in FY2025 than we saw after the mayoral and council election.
*Because multiple topics may be associated with each request, the breakdown of requests by topics is approximate and reflects the proportion of total topics addressed adjusted for the total number of requests resolved.
Topics Covered
Topics Covered
Board Staff tracks guidance responses by both topic and type. Accordingly, the total topics covered in the accompanying visualizations exceed the total responses. This approach better reflects both the complexity of our work and more accurately depicts which topics are "hot."
A similar visual summary, separated by filing and advice, is included in the monthly General Counsel Report to give the Board a snapshot of advice work for the preceding month as compared to the calendar year.
Month-by-Month
Month-by-Month
Plotting FY2025 guidance requests by general topic on a monthly basis gives an overview of the year's events. We see our largest spike centered on the Financial Disclosure filing deadline in May. Lobbying questions peaked in January as the 2024 filing season concluded and new principals for 2025 began to register. Ethics requests peaked in the fall of 2024 in the run-up to the 2024 presidential election.
Response Times: Overview
Response Times: Overview
Since February 2020, Board Staff has tracked the time to respond to informal guidance requests. In FY2025, Staff resolved nearly 80% within three business days.
Response Times by Topic
Response Times by Topic
When broken down by topic, the response times consistently show that ethics questions (Conflicts, Contracts, Gifts, Political Activity, Post-Employment, & Representation) take longer to resolve than questions related to the disclosure programs.
Year-to-date reporting on response times by topic is provided to the Board on a quarterly basis in the General Counsel Report.
Ethics Informal Guidance
Ethics Informal Guidance
Ethics Overview
Ethics Overview
Starting in FY2021, General Counsel Staff expanded its efforts to understand which topics are being covered in responses to advice requests. We now have five fiscal years of such data for comparison.
Note that the total topics necessarily exceed the total responses.
Month-by-Month
Month-by-Month
FY2025 monthly data suggests that other than higher numbers of Political Activity questions in the fall months, shifts by month continue to be generally proportionate among topics.
Campaign Finance Informal Guidance
Campaign Finance Informal Guidance
FY2024 vs. FY2025
FY2024 vs. FY2025
Campaign Finance guidance requests continued on a downward trend, though with a less significant decrease from FY2024 to FY2025 than that seen from FY2023 to FY2024.
Month-by-Month
Month-by-Month
Campaign Finance guidance shows fairly predictable spikes around pre- and post-election filing deadlines, with a significant increase leading up to the Municipal Primary in May 2025.
Financial Disclosure Informal Guidance
Financial Disclosure Informal Guidance
FY2024 vs. FY2025
FY2024 vs. FY2025
Financial Disclosure questions decreased significantly in FY2025 after a sharp increase in FY2024. This was an expected shift attributable to fewer new hires this fiscal year as compared to the start of the new administration in FY2024.
Month-by-Month
Month-by-Month
Financial Disclosure guidance shows a predictable spike around the May 1 filing deadline.
Lobbying Informal Guidance
Lobbying Informal Guidance
FY2024 vs. FY2025
FY2024 vs. FY2025
Lobbying advice requests continued to increase in FY2025. This year’s guidance skewed significantly toward filing assistance. For a deeper dive into who is lobbying and how much they are spending, see the Compliance section of this report.
Month-by-Month
Month-by-Month
Lobbying guidance requests predictably peak around the filing deadlines. We typically see the largest jump in requests around the annual reporting deadline in January.
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