Compliance & Filing Assistance

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 the 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. The State Ethics Act requires a statement from any City officers or employees with supervisory or discretionary responsibilities. Lastly, the Mayor requires a more detailed filing by certain high ranking administrative branch officials. While there are differences between the forms, all of them capture information related to the sources of income, business interests, directorships, gifts, and other financial interests.

For all three forms, the deadline for most filers is usually May 1. However, in response to the COVID-19 pandemic that began in early 2020, the State Ethics Commission, the Board of Ethics, and the Mayor’s Office took steps to extend the deadlines for 2019 filings to July 15, 2020.

The Board’s usual preparations for financial disclosure season are always extensive and begin months before the filing deadline. For example, the electronic filing system is prepared, employee data is reviewed and uploaded, and communication and outreach plans are developed.

New Financial Disclosure Filing System

FY2020, however, was an especially important year for Board and financial disclosure. During this time, the Board – with assistance from the City’s Office of Innovation and Technology (OIT), the Chief Integrity Office (CIO), and the City Record’s Department – implemented a new Financial Disclosure System (FDS) that replaced the previous, 13 year-old system. Implementing such a complicated and large-scale system was no small task – especially given the struggles regarding the COVID-19 pandemic – and Board Staff, in conjunction with members of OIT, CIO, and the Records Department, spent considerable portions of FY2020 creating, modifying and finalizing the new FDS.

The Board and Staff Members are very excited about this new system which will greatly increase the ease and efficiency in which the Board collects, processes, and maintains the submitted forms. The new system also corrects and rectifies many of the issues and problems associated with the previous, outdated system.

The new system was officially introduced on June 1, 2020 and the Board is happy to report that the new system has worked extremely well and was well received by our filing community.

Lobbying

The City’s Lobbying Law ensures public disclosure of who is spending money to influence City governmental action. It also 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 and Board Regulation No. 9, which provides a detailed interpretation of Chapter 20-1200. Lobbyists, lobbying firms, and principals mandated to file by the Lobbying Law do so through the online Philadelphia Lobbying Information System (PLIS). PLIS is also the portal through which the public may search for information concerning lobbying activity in the City.

Lobbying compliance has largely been unaffected by the pandemic. Registration and reporting as well as technical support has been a web-based electronic process through PLIS since 2014.

Lobbying Registration

The City’s Lobbying Law has two disclosure requirements. 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 listing 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 spent 20 hours or more on lobbying activity in the quarter.

From 2014 through 2016, the number of registrations filed (whether new or renewed) remained consistent at approximately 230. 2017 saw a 9% increase from the average of registrations filed to 250 and 2018 saw an increase of 34% over 2017 to 335. 2019 continued the upward trend with 361 registrations, an 8% increase over 2018. Fewer entities registered in the first two quarters of 2020 than in the past several years. Currently, only 267 entities have registered in 2020.

*2020 includes data through June 30, 2020

Lobbying Expense Reports

The second disclosure process in the City’s Lobbying Law is the Lobbying Expense Report. The expense report is filed by the principal and captures the detail of the 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. For instance, 2016 had the fewest number of registered entities recorded but the highest annual total of expenditures for communications, largely due to the focus on the soda tax. Information disclosed in quarterly expense reports filed by principals is available on the Board’s website in a searchable database.

*2020 includes data through June 30, 2020

Using City Lobbying Data

The City Lobbying Law is a disclosure law and helps ensure transparency in City government. Its purpose is not to prevent communication but to gather the information necessary for the public to be aware of who is spending money to advocate for 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, to identify City officials who were contacted by lobbyists and the subjects of those contacts, and to determine whether gifts were 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 Members 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.

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. One of the most important requirements is that these entities must file campaign finance reports 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. For the November 2019 General Election and the May 2020 Primary Election, filers were able to use the revamped system that launched in the Spring of 2019. A notable feature of the new system is that it allows simultaneous filing with both the Board and the City Commissioners. Additional information about the new system can be found in the Board’s FY2019 Annual Report.

With regard to the November 2019 General Election, the Board offered its usual program of Campaign Finance training and support services. In the first half of 2020, Board staff provided support to filers who were using the system to meet filing obligations related to non-City elections. This included assisting requestors with issues arising from the fact that the State moved the filing deadlines for the 2020 Primary Election due to COVID-19.

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