Open Session Minutes of the May 11, 2026 Board Meeting

Board of Ethics

Board of Ethics Meeting

Open Session Minutes

May 11, 2026, Monday-2:09 p.m.

740 North Sedgwick, Suite 500

Board Members Present

Ryan Cortazar, Vice Chair

Paul Berks

Hon. Bernetta Bush (Ret.)

Bob Glaves

Cindy L. Medina-Cervantes

ABSENT

Sarah Jin

Esther Nieves

Staff Present

Steven I. Berlin, Executive Director

Lauren Maniatis, Deputy Director

Paully Casillas, Staff Assistant

Guest Attending

Bradley Snyder, Office of Inspector General

The meeting was convened and conducted in person and through the use of the Zoom remote video and audio meeting platform.

• Approval of Minutes

The Board VOTED 5-0 (Sarah Jin and Esther Nieves, absent) to approve the Open Session Minutes of the April 13, 2026 Board meeting.

• Vice Chair's Report

None

• Members' Reports

None

• Executive Director's Report

• Staff Hires

The attorney who had accepted our offer to be Legal Counsel on March 5, withdrew her acceptance on March 24, a few days before she was scheduled to start with us on March 30. We are re-posting the position.

• Amended Personnel Rules

The Board continues to work with the Department of Human Resources to revise Personnel Rule XXIX, entitled "Conflict of Interest." The current version dates from 2014 and contains obsolete references that the Board has recommended be removed. We submitted updates to that Rule that coincide with the various provisions of the Governmental Ethics Ordinance to which the Personnel Rules refer.

• Amended Chicago Police Department Rules of Conduct

The Board has been consulting with the Police Board to revise the CPD Rule that covers political activity by CPD members.

• Amendments to the City's Ethics Laws

On January 24, 2024, more than two (2) years ago, the Board's proposals were submitted to the full City Council through the Chair of the City Council's Committee on Ethics and Government Oversight, 47th Ward Ald. Matt Martin. They were designated O2024-0007359, and are posted on the City Clerk's website here: https://occprodstoragev1.blob.core.usgovcloudapi.net/matter attachmentspublic/78f11f46-552f-4b49-b357-cdb7b2f130ec.pdf. We are informed by Ald. Martin's staff that there are no current plans to hold a committee hearing on these proposed amendments. We are unsure of the reasons. This is most disappointing; we believe these amendments are timely and important. We will continue to work toward their passage, and garner support among City Council members and the Administration. If enacted, they would: i) impose tighter regulations with respect to City Council independent contractors; ii) address the use of City property (such as Chicago Police or Fire Department insignia, badges, personnel uniforms, or equipment) in electioneering communications, and, among other things, subject political fundraising committees to the Ordinance's restrictions, thereby granting the Board and Inspector General ("IG") jurisdiction over such committees in this respect; iii) address electioneering communications sent to City employees or officials, and imposed a "stand by your ad" requirement such that candidates for City office must certify that they have reviewed all electioneering communications disseminated by their authorized political fundraising committees; iv) clarify the political activity prohibitions; and v) close a gap in the City's campaign contribution limitations law that allows officers, directors, shareholders, and employees of a person subject to the Ordinance's $1,500 annual contribution limit to elected officials and candidates to contribute on top of contributions made by the person unless they are reimbursed for that contribution. Our peer cities, New York and Los Angeles, have already closed an analogous gap in their political contribution laws. Please note that we made this same recommendation to the City Council in June 2019, just after Mayor Lightfoot took office.

Note that the Better Government Association drafted a bill closely based on our proposed amendments, which were introduced to the General Assembly on February 13, H.B. 5450. The bill is sponsored by Rep. Maurice West II and was referred to the Rules Committee last month. To read its full text, please see: https://ilga.gov/Legislation/BillStatus/FullText?GAID=18&Doc Num=5450&DocTypeID=HB&LegId=167327&SessionID=114. We are grateful to the BGA for spearheading this effort.

• Statements of Financial Interests

The deadline to file 2026 Statements of Financial Interests was before May 2, 2026. There are 55 employees and officials (including two (2) alderpersons) who have not yet filed, and 26 employees and officials (including three (3) alderpersons) who did file, but after May 1, and are thus not subject to fines. Probable cause notices will be sent to all late and non-filers. If they fail to file by the c.o.b. seven (7) business days after the letter's date, they will be fined $250 per day. Lists of all violators and their fines will be posted on our website when the final list of violators is compiled.

All candidates for elected City office in the 2027 Consolidated Municipal Election must also file Statements of Financial Interests. Incumbents' forms are posted here: https://webapps1.chica go.gov/efis/search.

Forms filed by candidates who are not required to file because of a City position are posted here: https://www.chicago.gov/city/en/depts/ethics/supp_info/statements-of-financial-interests-of -2027-candidates-for-city-of/statements-of-financial-interests-of-2027-candidates-for-city-of.h tml.

All forms filed in 2019 and after are posted and viewable here, where they stay for seven (7) years after they are filed: https://webapps1.chicago.gov/efis/search.

• Education

Mandatory Online Training

The lobbyist training went live on March 30; to date, 240 have completed it. The training for all employees and officials went live on May 6. To date, 239 have completed it. The training for appointed officials will go live the week of May 18.

Mandatory In-person Classes and other presentations

To date, 3,948 employees and officials have attended. We conducted classes here on April 16 and 23 and will conduct classes on May 14 and 21 and June 11 as well.

• Advisory Opinions

Since the Board's December meeting, we have issued 269 informal advisory opinions. The leading categories for informal opinions were, in descending order: Travel; Statements of Financial Interests; Gifts; City property; Lobbying; Prohibited conduct/reverse revolving door; Financial Interest in City business; and Post-employment.

The leading City departments from which requesters came in this period were, in descending order: Chicago Police Department/Civilian Office of Police Accountability (COPA)/Community Commission for Public Safety and Accountability (CCPSA); Mayor's Office; City Council; Department of Cultural Affairs + Special Events; Department of Public Health; Department of Transportation; Department of Law; Office of Inspector General; and Department of Technology and Innovation.

78% of all inquiries came from City employees or elected officials; the remainder came from lobbyists, attorneys, vendors, or potential lobbyists.

Please note also that we continue to receive complaints from members of the public: since the last Board meeting, we have received ten (10). These are all referred to the appropriate agency: typically, the IG, or a sister agency's IG.

Informal opinions are confidential and not made public, but are logged, kept, and used for training and future advisory purposes. This same practice occurs with our colleagues at the New York City Conflicts of Interest Board, who issue roughly the same number of informal opinions. They form the basis for much of our annual and periodic educational programs. Formal opinions are made public, in full text, with names and other identifying information redacted out.

In the past five (5) years, the Board has issued 70 formal opinions. There is one (1) formal opinion request on today's agenda to be considered by the Board.

• Summary Index of Formal Advisory Opinions/Text of all Formal Advisory Opinions

The full text of every formal Board opinion issued since 1986 is posted on the Board's website (more than 926), redacted in accordance with the Ordinance's confidentiality provisions, here:

https://www.chicago.gov/city/en/depts/ethics/auto_generated/reg_archives.html.

Redacted formal opinions are posted once issued or approved by the Board. Summaries and keywords for each of these opinions-and a link to each opinion's text--are available on the Board's searchable index of opinions, here: https://www.chicago.gov/content/dam/city/depts /ethics/general/Publications/AOindex.docx. A few other ethics agencies have comparable research tools. We are unaware of jurisdictions that make their informal opinions public - though, like us, others issue them confidentially and enable requesters to rely on them in the event of an investigation or enforcement.

• Lobbyists Filings

There are 711 lobbyists registered with our office, and we had collected $303,755 in 2026 registration fees. The deadline for filing 4th Quarter activity and re-registering or terminating was before January 21. We found 12 lobbyists in violation of the law and fined them accordingly, and posted their names and fines on our website, as required by law: https://www.chicago.gov /city/en/depts/ethics/provdrs/reg/news/2026/march/board-finds-14-lobbyists-in-violation-of-law-for-failing-to-re-r.html. There were no lobbyists who were late in filing Q1 Activity Reports, but four (4) individuals still have not paid their 2026 registration fees, and one lobbyist has not paid the $75 fee for adding a client. Notices of Probable Cause were sent to them.

We posted a current list of all lobbyists and their clients on May 7, here: https://www.chicago.gov /content/dam/city/depts/ethics/general/LobbyistStuff/LISTS/lobbyistlist.xls.

Lobbyists' filings dating back to 2014 can be examined here: https://webapps1.chicago.gov/ elf/public_search.html

Note that the Ordinance provides fines of $250 per day for late filings, and these are capped at $20,000. By contrast, fines are $1,000 per day for any individual who has reached either the quarterly hourly or compensation/expenditure threshold that triggers the requirement to register as a lobbyist but then fails to register as required within five (5) City business days of reaching that threshold. These fines begin on the sixth City business day until the person registers. These fines are not capped.

• Waivers

Since July 1, 2013, the Board has had authority to grant waivers from certain provisions in the Ethics Ordinance. The Board has granted 14 and denied four (4) waiver requests. In accordance with the law, all granted waivers are posted here: https://www.chicago.gov/city/en /depts/ethics/supp_info/Waivers.html . There is one (1) waiver request on today's agenda, from the Ordinance's prohibition on City employees having a financial interest in City contracts or business: §2-156-110.

• Summary Index of Board-Initiated Regulatory Actions/Adjudications/pre-2013 Investigations

We post a summary index of all investigations, enforcement and regulatory actions undertaken by the Board since its inception in 1986 (other than those for violations of filing or training requirements or campaign financing matters). It includes an ongoing summary of all regulatory actions the Board undertook without an IG investigation, based on probable cause findings the Board makes as a result of its review of publicly available information, where no factual investigation by the IG is necessary. See https://www.chicago.gov/content/dam/city/depts /ethics/general/EnforcementMatters/Invest-Index.pdf.

The Board makes public the names of all violators and penalties it assesses when authorized by law to do so. But only in those that occurred after July 1, 2013, can the Board release the names of those found to have violated the Ordinance. Since July 1, 2013, there have been 92 such matters.

• Summary Index of Ongoing/Past IG/LIG Investigations/Adjudications

There are currently six (6) completed IG ethics investigations in various stages of the adjudicative process. More information on these cases is posted here: https://www.chicago.gov/city /en/depts/ethics/provdrs/reg/svcs/ongoing-summary-of-enforcement-matters.html.

In the first, 23045.IG, a confidential hearing concluded last year, and Administrative Law Judge ("ALJ") Frank Lombardo issued his Confidential Final Report and Recommendations to the Board on May 15, 2025. The Board issued its final opinion on June 17, 2025 dismissing the matter. Then, on July 9, 2025, Respondent filed a Request for Attorney's Fees, pursuant to §2-156-392(c). That section provides:

"Upon a final determination by the board that the respondent did not commit a violation of this chapter, the respondent may submit a request to the board seeking reimbursement of reasonable legal expenses and costs incurred in defending the alleged violation. The request for reimbursement shall be granted if the board determines, using established legal principles, that the statement of charges was submitted and pursued in bad faith. If the board determines that the statement of charges was submitted and pursued in bad faith as provided in this section, such finding shall be made publicly available."

The Board voted at its July 2025 meeting to give the City until September 12, to respond to the Fee Request. Upon the City's motion, however, the Board voted at the September 15 meeting to stay any consideration and determination with respect to the Fee Request until it resolves Case No. 25014.C, filed on July 21, 2025. Resolution of that case will inform the Board's consideration and decision with respect to the Fee Request.

In the second, Case No. 25028.IG, the IG delivered a completed investigation to the Board on November 24, 2025, with a request that the Board find probable cause. It involves a now-former City employee who, the IG's investigation found, used their City title and authority to solicit a job opportunity for their son, with a City contractor, and allowed the contractor to perform unauthorized work for the City while their son worked for the vendor, and that the contractor violated the Ordinance by hiring the employee's son. The Board found probable and met with the City contractor and their counsel and the former employee at the April meeting. After that meeting, the Board voted to dismiss the matter with respect to the City contractor for a lack of sufficient evidence and to continue the matter to today's meeting with respect to the former employee. The former employee has submitted a further written response and asked to meet with the Board once more-that meeting is solely at the Board's discretion.

In the third, Case No. 25030.IG, the IG delivered a completed investigation to the Board on December 4, 2025, with a request that the Board find probable cause. It involves 12 political contributions from persons (or their affiliated companies) that were doing business with the City at the time of they made their contributions to the authorized candidate committee for an unsuccessful candidate for elected City office in the 2023 campaign. The IG's investigation found that one (1) contributor did not request a refund from the committee, and that the committee accepted these contributions in violation of the Ordinance. The Board found probable cause at its February meeting. The contributor met with the Board at its March meeting; after that meeting the Board fined the contributor $1,000. The committee's counsel submitted a written response to the Board and plans to meet with the Board at today's meeting to attempt to rebut the probable cause finding. The matter is on today's agenda.

In the fourth, Case No. 25032.IG, the IG delivered a completed investigation to the Board on December 30, 2025, with a request that the Board find probable cause. It involves a City employee who, the IG found, accepted a "cash gift" from an unlicensed "ride share hustler" at O'Hare. The Board found probable cause at the February meeting. The subject and their union counsel plan to meet with the Board at today's meeting to attempt to rebut the finding.

In the fifth, Case No. 26001.IG, the IG delivered a completed investigation to the Board on January 9, 2026, with a request that the Board find probable cause. It involves a former City employee who, the IG found, violated the Ordinance's post-employment restrictions, and prohibition on negotiating future employment with a person that had matters pending before them. The matter found probable cause at its February meeting. The subject has submitted a proposed settlement amount, which is on the agenda for the Board to consider at today's meeting.

In the sixth, Case No. 26005.IG, the IG delivered a completed investigation to the Board on February 5, 2026, with a request that the Board find probable cause. It involves a sitting elected official who, the IG found, had a City employee removed from their employment in apparent violation of the official's fiduciary duty. The Board found probable cause at its March meeting. The subject and their counsel intend to meet with the Board at today's meeting to attempt to rebut that finding.

Note that Case No. 25017.IG was settled by the Law Department for a $5,000 fine. In that matter, the IG found that a City employee used their City position, title, email account, and office equipment for their outside business and directly communicated with other City employees over City email to secure City permits, in violation of §§2-156-060 and -090(a) of the Ordinance. After the Board found probable cause and met with the subject's counsel, the Board determined that the subject committed 16 violations of the Ordinance and fined the subject $16,000. The matter was referred to the Law Department and Department of Administrative Hearings for proceedings to collect the fine. Now that the case has been settled, the matter is concluded. The Settlement Agreement is posted here: https://www.chicago.gov/content/dam/city/depts/ethics/general/ SettlementAgreements/Sonaike25017IG.pdf.

Note further that in Case No. 25021.IG, the IG found that a City employee failed to disclose income received from a business the employee owned on Statements of Financial Interests filed with the Board in 2022, 2023, and 2024. After the Board found probable cause and considered the subject's written response, the Board determined that the subject violated the Ordinance three (3) times and used a $6,000 fine. The matter was referred to the Law Department and Department of Administrative Hearings for proceedings to collect the fine, pursuant to §§2-156-385 and -392. The Law Department dismissed the Administrative Hearings matter in late April, instead opting to pursue termination of the employee. The employee has challenged the termination and matter will go to arbitration. The Board's Executive or Deputy Director will likely be called to testify before the arbitrator.

More complete summaries of these and all IG cases are available on our website, subject to the Ordinance's confidentiality requirements. We post on our website and continually update an ongoing investigative record showing the status of every completed investigation brought to the Board by both the IG since July 1, 2013, and the former Office of the Legislative Inspector General ("LIG"), since January 1, 2012, and the status of all 50 petitions to commence investigations presented to the Board by the LIG. We update this record as appropriate, consistent with the Ordinance's confidentiality provisions. See https://www.chicago.gov/city/en/depts/ethics/pr ovdrs/reg/svcs/ongoing-summary-of-enforcement-matters.html and https://www.chicago.gov /content/dam/city/depts/ethics/general/EnforcementMatters/PublicScorecard.pdf.

Whenever the IG presents the Board with a completed ethics investigation in which the IG believes there have been violations of the Governmental Ethics Ordinance, the procedure that follows is governed by §2-156-385 of the Ordinance: the Board reviews the IG's report, recommendations, and the entirety of the evidence submitted in its completed investigation, including a review to ensure that the IG conformed with the requirement that it complete ethics investigations within two (2) years of commencing them (unless there is evidence that the subject took affirmative action to conceal evidence or delay the investigation), and that the ethics investigation was commenced within five (5) years of the last alleged act of misconduct.

If the Board finds that the evidence presented warrants a finding of probable cause to believe the subject violated the Ordinance, it notifies the subject of the allegations and affords the subject the opportunity to present written submissions and meet with the Board, together with an attorney or other representative present. The Ordinance provides that this meeting is confidential and ex parte - no one from the City's Law Department or IG is present. Note that the Board may also request clarification from the IG as to any evidence found in its investigation before making a probable cause finding or refer the matter back to the IG for further investigation (and has done so). The Board cannot administer oaths at this meeting but can and does assess the subject's credibility and the validity and weight of any evidence the subject provides.

If the subject doesn't rebut the probable cause finding, the Board may enter into a public settlement agreement - or find there was a violation and proceed to a hearing on the merits that is not open to the public. That hearing is held before an administrative law judge (ALJ) appointed by the Department of Administrative Hearings. The City would be represented by the Law Department (or a specially hired Assistant Corporation Counsel for that purpose), and the subject by their attorney. At the conclusion of that hearing, the ALJ submits findings of fact and law to the Board, which can accept or reject them, based solely on the written record of the hearing. The Board will then publicly issue an opinion in which it may find violations of the Ethics Ordinance and impose appropriate fines or find no violation and dismiss the matter. These processes are based on specific recommendations of then-Mayor Emanuel's Ethics Reform Task Force in Part II of its 2012 Report-the primary purposes being to: (i) guarantee due process for all those investigated by the IG; (ii) ensure that only the Board of Ethics could make determinations as to whether a person investigated by the IG violated the Ordinance, given the Board's extensive jurisprudence and unique expertise in ethics matters; and (iii) balance due process for those investigated by the IG with an accurate adjudication by the Board and the public's right to know of ethics violations.

On our website, we have a publication describing this process in detail: https://www.chicago.gov /content/dam/city/depts/ethics/general/Publications/EnforceProcedures.pdf.

Note: fines range from $500-$2,000 per violation for non-lobbying or non-campaign financing violations that occurred before September 29, 2019, and $1,000-$5,000 per violation for such violations occurring between September 29, 2019, and September 30, 2022. For violations occurring on or after October 1, 2022, the fine range is between $500 and $20,000 per violation, and the Board may also assess a fine equal to any ill-gotten financial gains as a result of any Ordinance violation. Fines for unregistered lobbying violations remain at $1,000 per day beginning on the fifth day after the individual first engaged in lobbying and continuing until the individual registers as a lobbyist.

Please note, finally, that, in all matters adjudicated or settled on or after July 1, 2013, the Board makes public the names of all violators and penalties assessed, or a complete copy of the settlement agreement. All settlement agreements are posted here: https://www.chicago.gov /city/en/depts/ethics/provdrs/reg/svcs/SettlementAgreements.html.

• Disclosures of Past Violations

July 2013 amendments to the Ordinance provide that, when a person seeks advice from the Board about past conduct and discloses to the Board facts leading it to conclude that they committed a past violation of the Ordinance, the Board must determine whether that violation was minor or non-minor. If it is minor, the Board, by law, sends the person a confidential letter of admonition. If it was non-minor, then, under current law, the person is advised that they may self-report to the IG or, if he or she fails to do so within two (2) weeks, the Board must make that report. In 13 matters, the Board has determined that minor violations occurred, and the Board sent confidential letters of admonition, as required by the Ordinance. These letters are posted on the Board's website, with confidential information redacted.

• Open Meetings Act/FOIA Challenges

The Board is currently involved in four (4) challenges filed with the Illinois Attorney General's Public Access Counselor ("PAC"). (Note: two (2) challenges were resolved by the PAC on January 2, 2026. As a result of these two (2) resolved challenges, the Board is making public parts of the Executive Session minutes from its September 11, 2023, and September 30, 2024 meetings and the audio recordings from those meetings upon request. They cover the following matters: (1) the Board's discussion in Executive Session of Case Nos. 20038.WB and 23051.C, each of which was a complaint against the City Treasurer (the first was a whistleblower complaint; the second was a complaint alleging improper use of City property and resources), which the Board had immediately referred to the Office of Inspector General; and (2) the Board's discussion in Executive Session of Case No. 24019.Q, at its September 30, 2024, meeting, which pertains to an advisory opinion the Board issued to a lobbyist regarding an event that constituted reasonable hosting, and advising the lobbyists how it should be reported on their quarterly activity reports.

The remaining challenges request:

(1) A review of the propriety of adjourning into executive session during the Board's August 14 and September 11, 2023, meetings under the OMA;

(2) A review of the Board not producing certain records pursuant to FOIA;

(3) A review of the propriety of the Board's method of taking final action at its April 15, 2024, and May 13, 2024, meetings; and

(4) A review of the Board's discussion in executive session of its advisory opinion in Case No. 25014.C at its November 17, 2025 meeting. A redacted copy of that opinion was posted on our website on November 18, 2025, here: https://www.chicago.gov/content/dam/city/depts/ethics /general/AO-Attorneys/25014.C.pdf.

The Board has worked with the Law Department and responded to each.

• Freedom of Information Act

Since the April Board meeting, the Board has received two (2) FOIA requests:

The first was for all non-exempt records relating to any probable cause finding issue between January 1 and March 1, 2026 involving a former employee of the Mayor's Office connected to a contractor relationship involving disputes invoices of $9.6 million, as referenced in a 2026 Chicago OIG report. The Board denied this request in part per Sections 5 ILCS 140/7(1)(f), (m), and (n) of the Illinois FOIA Act, and gave the requestor the link to all non-exempt information about this matter.

The second was a request for leadership listing for plumbing inspectors. The Board responded that it was the wrong department and no responsive records.

• Public Comments

None

• Old Business

None

• New Business

None

• Prior Board Meeting's Executive Session Minutes

This matter shall be discussed in the Executive Session.

At 2:12 p.m., the Board VOTED 5-0 (Sarah Jin and Esther Nieves, absent) to adjourn into Executive Session under: (i) 5 ILCS 120/2(c)(1) to discuss the appointment, employment, compensation, discipline, performance, or dismissal of specific employees, specific individuals who serve as independent contractors in a park, recreational, or educational setting, or specific volunteers of the public body or legal counsel for the public body, including hearing testimony on a complaint lodged against an employee, a specific individual who serves as an independent contractor in a park, recreational, or educational setting, or a volunteer of the public body or against legal counsel for the public body to determine its validity. However, a meeting to consider an increase in compensation to a specific employee of a public body that is subject to the Local Government Wage Increase Transparency Act may not be closed and shall be open to the public and posted and held in accordance with this Act; (ii) 5 ILCS 120/2(c)(4) to hear and discuss evidence or testimony in closed hearing as specifically authorized pursuant to Governmental Ethics Ordinance Sections 2-156-385 and -392, and the Board's Rules and Regulations, as amended, effective January 5, 2017, presented to a quasi-adjudicative body, as defined in the Illinois Open Meetings Act, provided that the body prepares and makes available for public inspection a written decision setting forth its determinative reasoning; and (iii) 5 ILCS 120/2(c)(21) to discuss minutes of meetings lawfully closed under this Act, whether for purposes of approval by the body of the minutes or semi-annual review of the minutes as mandated by Section 2.06.

At 4:25 p.m. the Board VOTED 5-0 (Sarah Jin and Esther Nieves, absent) to reconvene in Open Session.

• Matters Considered by the Board in Executive Session
• • Approval of the Executive Session Minutes

The Board VOTED 5-0 (Sarah Jin and Esther Nieves, absent) to approve the Executive Session Minutes for the April 13, 2026 Board meeting.

None

None

Meeting with Subject Following Finding of Probable Cause, Pursuant to §2-156-385

1. Case No. 26005.IG, Fiduciary duty

After meeting with the subject and the subject's counsel, the Board VOTED 5-0 (Sarah Jin and Esther Nieves, absent) to determine that the subject did not violate the Ordinance's fiduciary duty provision, and that any potential violation of §1-4-120 of the Municipal Code falls under the jurisdiction of the Dept. of Law.

1. Case No. 25032.IG, Offering, receiving and soliciting of gifts or favors

After meeting with the subject and the subject's counsel, the Board VOTED 5-0 (Sarah Jin and Esther Nieves, absent) to determine that the subject committed one violation of §2-156-142 and to fine the subject $500.

1. Case No. 26001.IG, Prohibited conduct; Post-employment restrictions on assistance and representation

After considering the written materials presented by the subject, and meeting with the subject's counsel, the Board VOTED 5-0 (Sarah Jin and Esther Nieves, absent) to determine that the subject, a former City employee, committed one (1) violation of §2-156-100(b) and one violation of -111(c), and to and fine the subject a total of $5,000.

1. Case 25030.01.IG, Limitation of contributing to candidates and elected officials

After considering the written materials presented by the subject, the political fundraising committee of a candidate for City elected office in the 2023 election, and meeting with the subject's counsel, the Board VOTED 5-0 (Sarah Jin and Esther Nieves, absent) to: determine that the committee violated §2-156-445 of the Ordinance twelve times, by accepting contributions in excess of $1,500 in a calendar year from persons doing business with the City or those persons' affiliates, and by not responding to the requests by 11 of these contributors to issue refunds of the excess amounts or timely explaining to the OIG why it couldn't avail itself of the Ordinance's "safe harbor" provision, and to fine the subject political committee $214,000 - constituting $202,000 in excessive contributions and a $1,000 fine for each of the 12 violations.

The Vice Chair also announced that the Board will prepare and submit proposals to the City Council and Mayor to amend the Ordinance so that candidates whose political committees violated the Ordinance but then become insolvent or are dissolved remain responsible for paying fines through any future political committee they may form to run for elected office.

Consideration of Matter Following Meeting with Subject, Pursuant to §2-156-390

1. Case No. 25028.02.IG, Offering, receiving and soliciting of gifts or favors; Fiduciary duty; City-owned property

After considering the written materials presented by the subject, a former employee, the Board VOTED 5-0 to determine that there was insufficient evidence in the record to warrant a finding that the subject violated their fiduciary duty to the City or had a mutual understanding with a City contractor regarding the subject's child and their own judgments or actions as a City employee; and 2) VOTED 3-2 (Sarah Jin and Esther Nieves, absent) to determine that the subject committed three (3) minor violations of the Ordinance by using their City email to communicate about their child.

Consideration of Issuance of Advisory Opinion Pursuant to §2-156-380

1. Case No. 26007.A, Fiduciary duty; City-owned property

The Board VOTED 5-0 (Sarah Jin and Esther Nieves, absent) to continue this matter to the June meeting.

Consideration of Waiver Request Pursuant to §2-156-402

1. Case No. 26013.W, Post-employment restrictions on assistance and representation

The Board VOTED 5-0 (Sarah Jin and Esther Nieves, absent) to continue this matter to the June meeting.

• Other Business

At 4:29 p.m., the Board VOTED 5-0 (Sarah Jin and Esther Nieves, absent) to adjourn the meeting.