Response to Submission by Office of the State Comptroller to JCOPE’s proposed Advisory Opinion on restrictions on elected officials soliciting/accepting campaign support from enforcement subjects

SUMMARY

The Government Ethics Committee submitted a supplemental letter to the Joint Commission on Public Ethics (JCOPE) concerning interactions between an elected official (or members of his or her immediate staff or leadership team) and significant campaign contributors while those contributors have active matters before that elected official. The Committee reiterated its view that such interactions present the appearance of a conflict of interest, if not an outright conflict. The Committee further urged that members of the legislature should not be exempt from ethical practices put in place to guard against these dangers; while legislators, by their nature, interact regularly with significant contributors as part of the election process, doing so without appropriate safeguards – such as well-understood and accepted disclosure obligations – raises risks to government effectiveness.