Compliance & Filing Assistance

Introduction

The Board of Ethics is pleased to highlight new milestones and ongoing initiatives that reflect its commitment to transparency, fiscal responsibility, and community well-being.

In Fiscal Year 2025, the Board of Ethics made a significant investment in the City’s ethical infrastructure by formalizing a dedicated compliance function in the office. The Board promoted longtime staff member Bryan McHale to serve as the inaugural Director of Compliance and Administration, bringing deep institutional knowledge and experience to this new leadership role. Under Bryan’s direction, the Board expanded its capacity by hiring two Investigative Analysts, Alexander Kramer and Diana Gavrykh, to form the foundation of a robust compliance team.

This newly created team will lead the Board’s efforts to proactively support and strengthen the City’s compliance efforts in lobbying, financial disclosure, campaign finance, and general ethics laws. We look forward to continuing to build a comprehensive compliance program that upholds transparency, accountability, and public trust.

Financial Disclosure

Annual financial disclosure requirements help ensure good government by requiring public officials to disclose sources of income, creditors, gifts, and certain business or real estate interests. Members of the public can use this information to assess what interests may affect an official’s decision making. The City's Ethics Code requires an annual statement of financial interest from elected officials and other high-ranking City officers and employees. Additionally, the State Ethics Act requires a statement from any City officers or employees with supervisory or discretionary responsibilities. While the two forms have some differences, both capture information related to sources of income, business interests, directorships, gifts, and other financial interests.

For both forms, the deadline for most filers is usually May 1. While not required, the overwhelming majority of filers file their financial disclosure forms via the Board’s Financial Disclosure filing system discussed further below.

Board’s Financial Disclosure Filing System

Every year, the Board updates and prepares its electronic Financial Disclosure System to be utilized during the year’s “financial disclosure season” (i.e., the months leading up to the May 1 deadline). This is the system most filers use to submit and file the financial disclosure forms. Preparing and updating the system every year requires significant effort by the Board and takes place months before the May 1 deadline.

The Board’s Filing-Related Assistance

The Board’s compliance-related work regarding its administration of the Financial Disclosure Rules primarily involves notifying the regulated community of their filing obligations under the rules, educating them about how to file their reports and what information must be included in them, and then individually assisting members of the community to satisfy these obligations. This is no small undertaking as it involves thousands of City officers and employees operating in dozens of different City offices, departments, agencies, boards, commissions, etc. It also involves keeping track of the constant flow of City officers and employees entering and leaving City service. This work is discussed in the Training and Advice sections of this Annual Report.

As part of its regular tasks regarding financial disclosure, every year the Board provides a series of educational and information documents for filers to utilize and reference during the “filing season”. For example, in FY2025 the Board provided the following documents: (a) a Frequently Asked Questions document regarding the City’s Financial Disclosure Rules; (b) a “Who Files What” document explaining which City officers and employees need to file which financial disclosure forms; (c) a set of Instructions for filing the City Form; and (d) a series of “Questions of Note” that address common or prominent questions received from filers regarding all subject matters administered by the Board, including financial disclosure. All these documents can be found on the Board’s website.

Lobbying

The City’s Lobbying Law ensures public disclosure of who is spending money to influence City governmental action. It requires those who pay people to lobby City officials to file regular reports detailing their expenditures. The City’s Lobbying Law is found at City Code Chapter 20-1200; Board Regulation No. 9 (Lobbying) provides a detailed interpretation of Chapter 20-1200.

The Philadelphia Lobbying Information System

Lobbyists, lobbying firms, and principals mandated to file by the Lobbying Law do so through the online Philadelphia Lobbying Information System (PLIS). Registration and reporting, as well as technical support, have been a web-based electronic process through PLIS since 2014.

PLIS is also the portal through which the public may search for information concerning lobbying activity in the City. This is discussed below in the “Using City Lobbying Data” section.

Disclosure Requirements of the City’s Lobbying Law

As explained below, the City’s Lobbying Law has two disclosure requirements.

Lobbying registrations

The first requirement is that principals who spend more than $2,500 on lobbying activity in a quarter must register with the Board. When they register, principals must provide basic information about themselves as well as list any lobbyists or lobbying firms they are using. Lobbying firms and lobbyists must also register if they receive more than $2,500 for lobbying activity in a quarter, although if a lobbyist is an employee of a principal, they only need to register if they also spent 20 hours or more on lobbying activity in the quarter.

Below are several charts that provide information on the lobbying registrations filed with the Board in recent years.

*2025 includes data through June 30, 2025

Lobbying expense reports

The second disclosure requirement in the City’s Lobbying Law regards lobbying expense reports. These reports are filed by the principal and capture the details of the principal’s lobbying activity in that quarter. This includes the amount of expenditures, the detail of communications, and any gifts, hospitality, or transportation provided to City officials and employees.

There are two types of lobbying communications reported each quarter: direct communications and indirect communications. Direct lobbying communications include, but are not limited to, written, in-person, telephone, and email contacts between a lobbying entity and a City official or employee to affect legislative action or administrative action. Indirect lobbying communications occur when a lobbying entity makes an effort to encourage others, including the general public, to take action that is intended to directly influence legislative action or administrative action. Examples of indirect lobbying methods include letter-writing campaigns, mailings, telephone banks, print and electronic media advertising, billboards, publications and educational campaigns on public issues. Total expenditures on communications can fluctuate from quarter to quarter and year to year depending upon the topics of interest to the public and the agendas of City Council and City agencies.

Information disclosed in quarterly expense reports filed by principals is available on the Board’s website and is accessible to the public as described in the “Using City Lobbying Data” section below.

Below are several charts that provide information on the lobbying expense reports that were filed with the Board in recent years.

*2025 includes data through June 30, 2025

Using and Accessing City Lobbying Data

As discussed above, the City Lobbying Law is a disclosure law and helps ensure transparency in City government. Its purpose is to provide information that members of the public can use to learn who is spending money to influence City policy.

Information disclosed by the filers in the lobbying community may be explored through the online lobbying system. Members of the public can use the database to search for, among other things, amounts spent on Philadelphia lobbying by principals, the identities of City officials who were contacted by lobbyists and the subjects of those contacts, and gifts given to elected and appointed City officials. The public can search through the individual registrations and expense reports or may use several pre-set options to generate reports from the database. Board Staff are always available by telephone, email or in-person to assist interested individuals who want to search and sort the information in the searchable PLIS database.

The Board’s Filing-Related Assistance

As part of its work in administering the City’s Lobbying Law, the Board interacts with the regulated community in many ways. This primarily involves notifying the regulated community of their obligations under the law (especially the filing requirements), educating them about these obligations, and then individually assisting members of the community to satisfy these obligations. This work is discussed in the Training and Advice sections of this Annual Report.

In FY2025, the Board continued to rely on a series of educational documents to help the regulated community comply with the requirements of the City’s Lobbying Law. These included: (a) a Frequently Asked Questions document regarding the City’s Lobbying Law; (b) a “City Lobbying Guide for Principals, Lobbyists and Lobbying Firms” explaining when and how individuals and entities must file lobbying registration and/or expense reports; and (c) a series of “Questions of Note” that address common or prominent questions received from members of the regulated community regarding all subject matters administered by the Board, including lobbying. All these documents can be found on the Board’s website.

Campaign Finance

City Code Chapter 20-1000 and Board Regulation No. 1 (Campaign Finance) establish the requirements that apply to candidates for City elective office, candidate political committees, and political committees.

The law has three main components:

Contribution limits

The City Law has specific rules regarding what is the maximum value of direct contributions a candidate running for City office may receive. Currently, an individual may contribute up to $3,700 to a candidate for City office per calendar year while a political committee may donate up to $14,800. If a candidate for City office makes total contributions of $250,000 or more of their personal resources to their own campaign, then the contribution limits for all candidates for that specific City office are doubled.

Required electronic filing of campaign finance reports

The City’s Campaign Finance Law has specific rules regarding when certain political contributions need to be reported in required campaign finance reports and what specific information regarding these contributions must be included in these reports.

One of the Law’s most important requirements is that these campaign finance reports must be filed electronically. As a result, contribution and expenditure information quickly becomes publicly available in a searchable online format. To accomplish electronic filing, the Board provides a free filing software program to all candidates and committees.

Rules about how candidates use political committees and bank accounts for their campaigns

Generally, and subject to just a few exceptions, under the City’s Campaign Finance Law candidates for City elective office must use a single checking account and political committee for all contributions received and all expenditures made for their campaign.

A candidate may also establish separate, special committees to either raise and spend money for the defense of litigation arising directly from their campaign, or raise and spend money for that candidate’s inauguration and transition to City office.

The Board’s Filing-Related Assistance

Every year the Board assists the regulated community regarding the City’s Campaign Finance Law. This primarily involves notifying the regulated community of their obligations under the law, educating them about these obligations, and then individually assisting members of the community to satisfy these obligations. This work is discussed in the Training and Advice sections of this Annual Report.

Alerts and reminders

The first, introductory task for the Board is to inform and remind the regulated community of the requirements under the City’s Campaign Finance Law - especially the requirements regarding filing campaign finance reports, which have specific, designated deadlines, and news about the doubling of contribution limits for certain races, which can occur at virtually any point up to an election.

As in most other election years, this process for the 2025 Primary Election began months ahead of the actual election. In this regard, in FY2025, the Board continued to use various means to reach out to the regulated community including social media, the Board’s website, and emails.

Educational documents

As part of its regular tasks regarding administering the City’s Campaign Finance Law, every year the Board provides a series of educational and informational documents to the regulated community to utilize and reference. For example, in FY2025, in preparation for the 2025 Primary Election, the Board provided the following documents: (a) a Frequently Asked Questions document regarding the City’s Campaign Finance Law; (b) a Philadelphia Campaign Finance Resource Guide providing general summaries of the City’s rules and practical examples on how the rules apply; (c) a series of “Questions of Note” that address common or prominent questions received from members of the regulated community regarding all subject matters administered by the Board, including campaign finance; and (d) the Board’s Regulation No. 1 (Campaign Finance). All these documents can be found on the Board’s website.

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