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 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, the State Ethics Commission, the Board of Ethics, and the Mayor’s Office extended their deadlines for 2020 filings to June 1, 2021.

Amendments to the City ‘s Annual Financial Disclosure Law and Related Regulation

In March of 2021, City Council amended the Ethics Code to update the requirements related to the City's Statement of Financial Interest (the “City Form”). The most notable changes made by the amendment, are summarized in this document. Following the amendment of the Ethics Code, the Board issued Regulation No. 3 interpreting the new law and specifying which City officers are required to file it. The Regulation became effective in April of 2021.

Interactions with the Regulated Community Regarding Financial Disclosure Requirements

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.

In regards of outreach, Board Staff made tremendous strides in FY2021. First, Board Staff began using a new software program (which was utilized in areas besides financial disclosure) to better target email communications, allowing Staff to send different messages to different groups of filers. Board Staff were also able to use the program to send reminders close to the deadline to any City employees who had not yet filed. Second, Board Staff developed “Financial Disclosure 101” information sessions to provide basic information to filers and to give them the opportunity to ask questions. These sessions were presented via Zoom which allowed participants to attend from anywhere they had phone or internet access. Board Staff believes these sessions would not have been as well attended if they were provided solely as in-person events. As such, Board Staff expects to continue to use such virtual informational sessions in the future even when City offices reopen.

Board’s Financial Disclosure Filing System

In June 2020, the Board implemented a new Financial Disclosure System (FDS) that replaced the previous, 13 year-old system.

No significant changes were made to the system in FY2021, but Board Staff note that it has been invaluable during the COVID pandemic when City offices have been closed, allowing the Board to carry out its duties and obligations regarding financial disclosure almost seamlessly in FY2021. Board Staff credits much of this to its new Financial Disclosure System and all the hard work it took in previous years to make it viable.

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 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 have 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. 2020 saw the first decrease in registrations with just 296 (a -18% decrease). Currently, only 255 entities have registered in 2021 suggesting the trend of relatively fewer registrations (seen in 2020) will continue.

*2021 includes data through June 30, 2021

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.

*2021 includes data through June 30, 2021

Using City Lobbying Data

The City Lobbying Law is a disclosure law and helps ensure transparency in City government. Its purpose is to provide the 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, 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.

Lobbying Training and Educational Documents

As in previous years, in FY2021, the Board offered trainings covering the basic requirements of the City's Lobbying Law for lobbyists, lobbying firms, and principals. Such trainings provided technical guidance regarding registering and filing expense reports with the Board of Ethics in Philadelphia's Lobbying Information System (PLIS). Due to the COVID-related, City Offices Shutdown, these trainings were conducted virtually which proved to be very successful as it appears such virtual trainings allowed more attendees to attend. Further details regarding these lobbying trainings (and other trainings offered by the Board in FY2021) are discussed in the Training section of this Annual Report.

In April 2021, Board Staff also published a new guide to the City’s Lobbying Rules. This guide assists principals, lobbyists, and lobbying firms navigating the core concepts and disclosure requirements of the City's Lobbying Law.

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 2021 Municipal Elections, filers were able to use the revamped system that launched in the Spring of 2019. 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.

Campaign Finance Trainings and Educational Documents

With regard to the 2021 Municipal Elections, the Board offered its usual program of Campaign Finance training and support services. In light of the COVID pandemic, Board Staff sought to enhance the Board's virtual and web-based offerings. Board Staff offered campaign finance training via Zoom and, in addition to basic training, offered sessions focused on specific topics. For example, Board Staff presented a training that took a deep dive into rules and issues related to campaign contributions. Staff also presented a training titled “Campaign Finance Best Practices” and one specifically developed for Ward Committees. These offerings were well received and Board Staff plan to present such sessions in the future even when City offices reopen.

Further details regarding these campaign finance trainings (and other trainings offered by the Board in FY2021) are discussed in the Training section of this Annual Report.

In addition to trainings, the Board launched a Campaign Finance Resource Center website (March 2021), a revamped Campaign Finance Guide (March 2021), and updated Campaign Finance FAQs (October 2020). These resources provide a wealth of useful information regarding the City Campaign Law and technical issues regarding Campaign Finance filings. These documents serve as the initial, “go-to” resources for anyone with questions regarding the City’s Campaign Finance Rules.

Related to the Campaign Finance Resource Center website, the Board was proud to introduce its first set of training videos. An example can be found here. These videos have proven to be popular and the Board plans to develop more of them in the future (including videos regarding topics other than Campaign Finance).

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