PUBLIC SESSION
MEETING CONVENED
Vice Chair Thomas A. Connors called the meeting to order at 9:32 a.m. Also in attendance were Chair Margot Botsford, Commissioner Eron Hackshaw, Commissioner Patrick Hanley, and Commissioner Jeffrey T. Collins. Chair Botsford and Commissioner Hanley participated remotely.
REMOTE PARTICIPATION
Vice Chair Connors announced that the meeting would take place in-person with remote access provided to the public pursuant to the law signed by Governor Healey on March 28, 2025. Vice Chair Connors noted that all votes at the meeting would be taken by roll call.
APPROVAL OF MEETING MINUTES
On the motion of Vice Chair Connors, seconded by Commissioner Collins, the Commission voted 4-0 to waive the reading and approve the public session minutes of the December 18, 2025 Commission meeting. Vice Chair Connors stated that he abstained from the vote as he had not attended the December 18th meeting.
| Vote: | |
|---|---|
| Chair Botsford | Yes |
| Vice Chair Connors | Abstain |
| Commissioner Hackshaw | Yes |
| Commissioner Hanley | Yes |
| Commissioner Collins | Yes |
EXECUTIVE DIRECTOR'S REPORT
Executive Director David A. Wilson presented his monthly report.
Personnel
Mr. Wilson reported Senior Public Information Officer Gerry Tuoti's promotion to Deputy Chief of the Public Education and Communications Division in recognition of his leadership and communications skills and experience and his dedication to work of the Division and the Commission. Vice Chair Connors said that he appreciated Mr. Tuoti's efforts to keep the Commissioners informed about the Commission and conflict of interest law matters in the news.
Budget
Mr. Wilson provided an update on the Commission's Fiscal Year 2027 budget request. He noted that the Governor was expected to file her Fiscal Year 2027 budget proposal, H. 2, the following week. Mr. Wilson stated that the Commission was requesting approximately $4 million for Fiscal Year 2027, a $250,000 increase over the Commission's Fiscal Year 2026 funding, which would support modest cost-of-living and longevity increases for Commission staff. He reported that he and Government Affairs Officer Jennifer McCullough had begun meeting with members of the House and Senate Committees on Ways and Means to advocate for the Commission's full Fiscal Year 2027 budget request and that they had been very well received at the meetings thus far. Mr. Wilson noted that he anticipated continuing such meetings over the coming months. He also noted that Ms. McCullough would continue to be in frequent communication with legislative staff regarding the Commission's budget request and that her State House experience greatly aided the Commission's outreach regarding its budget. Mr. Wilson said that he would, later in the budget process, testify in person before and provide written testimony to the Joint Committee on Ways and Means, as he does each year, in support of the Commission's budget request. He noted that the Commission's budget team and Mr. Tuoti would, as they do each year, help him prepare his written testimony for submission to the Joint Committee on Ways and Means.
Chair Botsford asked whether legislators compare the Commission's efforts with those of other agencies in other jurisdictions and whether legislators view government ethics as a priority. Mr. Wilson in response noted legislators' appreciation of the Commission's service to the Commonwealth and its role in upholding integrity in government. Vice Chair Connors affirmed the importance of the Commission advocating for its work and noted Mr. Wilson's good work presenting the Commission's budget request.
New Commissioner
Mr. Wilson stated that there was nothing new to report regarding the appointment of a new Commissioner to succeed Commissioner Hackshaw. He noted that the Commission posted information about the vacancy on its website and LinkedIn page to inform the public of the opportunity and to direct interested applicants to the notice posted by the Attorney General's Office.
Ongoing Projects
Mr. Wilson reported that substantial progress had been made in the project to replace the Commission's existing SFI e-filing system, which would be discussed during SFI portion of the monthly report of the Legal Division.
House of Representatives Training
Mr. Wilson reported that he and General Counsel/Legal Division Chief Eve Slattery were scheduled to conduct two ethics training sessions for the House of Representatives. Commissioner Collins asked whether the training sessions were for House members or staff. Ms. Slattery responded that the training sessions were primarily for House members. Mr. Wilson noted that two training sessions were scheduled to accommodate House members who are unable to attend one of the sessions. He further reported that Public Education and Communications Division Chief Don Siriani would later conduct a separate training session for House staff. Mr. Wilson asked whether the staff training had been scheduled. Mr. Siriani responded that it had not yet been scheduled.
Next Meeting
Mr. Wilson reminded the Commission that its next Commission meeting was scheduled for February 26, 2026 at 9:30 a.m.
AUDIT REPORT OF THE OFFICE OF THE STATE AUDITOR
Mr. Wilson reported that the State Auditor's Office had concluded its audit of the Commission, which began in February 2025, and issued its final report. He noted that the Auditor's Office is required by law to perform an audit of state agencies about every three years. Ms. Slattery explained that the audit initially focused on how the Commission conducts reviews and investigations regarding statements of financial interests, the receipt and processing of written requests for advisory opinions, and the issuance of advisory opinions, and later expanded to include the Commission's investigations of alleged violations of the conflict of interest law and financial disclosure law.
Ms. Slattery reported that Commission staff responded to eight separate requests for documentation and forty-five separate requests for information during the audit. She further reported that the audit resulted in no "findings" regarding the objectives of the performance audit: the Commission's timeliness in responding to requests for advice and investigating complaints, or processing statements of financial interests. Ms. Slattery noted that the State Auditor's Office identified a finding related to the Commission's internal control plan, noting that the plan was not reviewed and updated on an annual basis. She explained that the Commission conducted a thorough review of its internal control plan in 2020 and then amended it in response to the COVID-19 pandemic and later adopted, including adopting telecommuting policies, and that the plan continued to be effective due to its robustness. She stated that annual review is an ongoing obligation and that, going forward, Chief of Finance and Operations Benjamin Bloomenthal had agreed to serve as the Commission's internal control plan officer and to ensure that the plan is reviewed and updated regularly as needed. Ms. Slattery reported that the State Auditor's Office also recommended that the Commission update other internal policies, including policies relating to information systems, including those guided by Executive Office of Technology Services and Security standards, and that formal written policies would assist the Commission during periods of staff transition. Ms. Slattery noted that the auditors would return in approximately six months to review the Commission's progress and that the Commission intended to complete policy updates by that time.
Commissioner Hackshaw asked whether the Auditor's Office required substantive changes to Commission policies or only annual review. Ms. Slattery responded that the Auditor's Office did not identify specific changes that must be made but recommended that the Commission maintain documentation showing that the internal control plan and policies are reviewed annually. Mr. Wilson stated that the internal control plan was most recently updated on November 21, 2024, following a lengthy review process that included input from the Office of the Comptroller. He noted that the update occurred outside the audit period and that the auditors did not indicate that the plan was deficient, but rather that the Commission must document yearly review of the plan even if substantive changes are not required. Commissioner Hackshaw asked whether annual internal control plan review should be presented to the Commission or handled internally and asked what evidence the Auditor's Office required. Ms. Slattery responded that Commission approval by vote may be required for certain updates and that Commission staff would develop a process to determine which items are administrative and may be handled internally and which matters should be brought to the Commission for approval.
PUBLIC EDUCATION AND COMMUNICATIONS DIVISION MATTERS
Public Education and Communications Division Chief Don Siriani presented his memorandum reporting on the Public Education and Communications Division's activities during December 2025.
Mr. Siriani congratulated Mr. Tuoti on his appointment as the new Deputy Chief. He noted that Mr. Tuoti's deep institutional knowledge, coupled with his high level of professionalism and dedication to public service, would be invaluable to the Division in his new role.
Mr. Siriani reported that the Division engaged in year-end rollover procedures for the Commission's conflict of interest law online learning platform. He stated that Division staff had initiated contacting elected state and county officials for whom the Commission is responsible regarding their conflict of interest law education requirements, and noted that, for the current year, such officials were required to acknowledge receipt of the summary of the conflict of interest law. Mr. Siriani further reported that some elected officials had already begun to acknowledge receipt of the summary and that the training portal undergoes annual changes as part of the rollover process.
Deputy Chief Gerry Tuoti reported that a technical issue had occurred during the rollover process of the online training program, which was resolved on January 7, 2026. He stated that at the end of each calendar year, the vendor, SkillBurst, must unpublish the prior year versions of the training course materials and replace them with new versions to ensure that due dates and compliance tracking remain accurate. Mr. Tuoti noted that public employees are required to acknowledge receipt of the summary of the conflict of interest law every year and complete the conflict of interest law training every two years. He explained that, due to a coding error by the vendor, the system incorrectly assigned a January 31, 2026 due date to users who were not actually due to complete the training, including individuals who had completed the course in 2025 and should not have had a January 2026 due date, which resulted in confusion among affected users. Mr. Tuoti further reported that approximately 61,000 users were affected, while approximately 290,000 users were not affected.
Mr. Tuoti stated that the vendor responded promptly and worked with Commission staff to resolve the issue, including correcting the due dates to reflect the proper compliance schedule. He said that the Division contacted all agencies and municipalities using the Commission's online learning platform and drafted messaging that the vendor distributed through the system to affected users explaining that the issue had been resolved. Mr. Tuoti noted that if a user completed the training in 2026 before they were required to do so, they would still receive credit for the completion. He reported that, during the period of increased user activity, the system experienced temporary strain on server capacity due to a large number of users attempting to complete training early, but that this issue had also been addressed. Mr. Tuoti further reported that the Division responded to more than 800 inquiries from users during the period of the issue, which he stated was fewer than the number of inquiries received in January of the prior year. He noted that the system was currently operating normally, that the number of inquiries had tapered down, and that the Division did not anticipate further issues. He thanked Mr. Siriani, Senior Program Coordinator Arthur Xia, and Special Assistant Arisa Waguespack for responding to user inquiries.
Commissioner Hackshaw asked whether users who completed the training after receiving the incorrect notice would have their due dates reset. Mr. Tuoti responded that a user who was not due until later in 2026 but completed the training early in January would have a new due date based on the January completion date, consistent with the statutory two-year requirement. Vice Chair Connors said that the technical issue was resolved quickly but could have had more substantial ramifications due to the scale of the system. Mr. Tuoti stated that the vendor responded appropriately and that he was relieved that the issue only affected approximately 61,000 users rather than a larger number. Commissioner Hackshaw asked whether there would be additional cost to the Commission for the vendor's work correcting the issue. Mr. Tuoti responded that annual rollover procedures are included within their service agreement and that the vendor corrected the coding issue without additional cost. Mr. Siriani said that, while the issue caused a spike in user activity and help desk response volumes, the Division responded professionally and communication with the vendor remained open. He reported that the system issued approximately 3,500 certificates in the week prior to the rollover coding change and approximately 43,000 certificates during the period of increased activity.
Mr. Siriani reported that the Division would resume its in-house seminar program in March 2026. He stated that the Division had scheduled a number of upcoming seminars to be conducted in-person, virtually, and in hybrid format, including a seminar for the Boston City Council, and that he anticipates conducting a seminar for Boston Public Schools and the Boston Zoning Board of Appeals in the future. Mr. Siriani reported that the Division would conduct a seminar for the University of Massachusetts in February 2026. He further reported that the Division had scheduled two hybrid seminars for MassDevelopment, one to be held in Boston and the other at Devens. Mr. Siriani stated that the next seminars would be conducted for the Massachusetts Town Clerks' Association in February 2026 and was expected to be several hours in length.
LEGAL DIVISION MATTERS
General Counsel/Legal Division Chief Eve Slattery reported on the activities of the Legal Division in December 2025.
Legal Division Metrics for December 2025
Ms. Slattery presented the following Legal Division metrics for December 2025.
- Written advice. The Legal Division answered by letter or e-mail 41 written requests for advisory opinions under G.L. c. 268A and c. 268B. Of these requests, 1 pertained to SFIs.
| For comparison: | |
|---|---|
| December 2024 (same month prior year) (total/SFI): | 55/11 |
| November 2025 (previous month) (total/SFI): | 32/1 |
- Oral advice. The Legal Division attorneys provided advice by telephone in response to 285 requests for advice from state, county, and municipal officials. Of these requests, 5 pertained to SFIs.
| For comparison: | |
|---|---|
| December 2024 (same month prior year) (total/SFI): | 301/7 |
| November 2025 (previous month) (total/SFI): | 276/4 |
- Review of municipal letters. Division staff reviewed 0 letters issued by city solicitors/town counsel pursuant to G.L. c. 268A, § 22 and 930 CMR 1.03.
| For comparison: | |
|---|---|
| December 2024 (same month prior year): | 1 |
| November 2025 (previous month): | 1 |
- Backlog. As of January 15, 2026, the Division had no pending requests for written advice that were more than 30 days old. As of that date, there were a total of 11 pending requests for written advice.
Adjudicatory Matters
Ms. Slattery presented the January/February calendar of conferences/hearings in pending Commission adjudicatory proceedings.
SFI Report
Legal Division Deputy Chief/SFI Lauren Duca provided an update on Statements of Financial Interests (SFI) for Calendar Year 2025.
Ms. Duca said that the SFI Team responded to requests for legal and technical assistance from liaisons working on the preparation and submission of their agency's Calendar Year 2025 Designation Lists of filers, which were due by January 5, 2026. She reported that the SFI Team updated and revised filing materials, including the Quick User Guide for filers, and that the SFI system was successfully rolled over to the Calendar Year 2025 filing season.
Ms. Duca stated that when the system was rolled over, the SFI Team identified an issue with the system's filer notification function that could have resulted in notices being sent to individuals who did not need to file an SFI for Calendar Year 2025. She explained that, because the system indicated it would generate over 8,000 notices despite having just under 4,000 filers for Calendar Year 2025, the SFI Team drafted and issued its own notice regarding the opening of the filing season rather than using the system's notice function. Ms. Duca reported that approximately 200 filers have filed to date. She noted that there is typically an initial surge of filings at the opening of the filing season, followed by a period of reduced activity until mid-April.
Ms. Duca provided an update on the project to replace the Commission's existing SFI filing system. She reported that, after reviewing and scoring the written proposals submitted in response to the Commission's request for quotation and the oral presentations, and reviewing the reference checks and best and final offers responses, the Commission's Strategic Sourcing Team selected an apparent successful bidder contingent upon a successful negotiation and reduction in the proposed licensing, maintenance and support costs for the replacement system to a level that would be sustainable for the Commission. Ms. Duca stated that negotiations were ongoing and that she hoped to conclude negotiations soon so that the Commission may engage the selected bidder and begin work on the new system.
ENFORCEMENT DIVISION MATTERS
Enforcement Division Chief Monica Brookman presented the Enforcement Case Metrics and Enforcement Intake and Matter Metrics for December 2025.
Ms. Brookman reported that, while the number of complaints received increased in December, the Matter backlog remained relatively the same. She said that she hoped to not at any time have more than ten matters in the informal investigative stage that are considered backlog.
Enforcement Procedures Amendment
Ms. Brookman stated that the Commission's Enforcement Procedures currently provide that 30-Day Notices, which advise the subject of an inquiry that the Enforcement Division intends to present a Preliminary Inquiry Report to the Commission at its next meeting, are to be sent by first class mail. Ms. Brookman said that the Enforcement Division believed it would be more efficient and practical to send 30-Day Notices primarily by e-mail. She explained that, by the time a Preliminary Inquiry Notice is sent, the Enforcement Division has typically been in regular contact with the subject or the subject's attorney and that nearly all communication at that stage is conducted by e-mail. She further explained that Preliminary Inquiry Notices issued by the General Counsel to advise a subject of the initiation of an investigation are routinely sent by e-mail, after confirming the subject's preferred e-mail address. Ms. Brookman stated that the Enforcement Division proposed revising the Enforcement Procedures to provide that 30-Day Notices be sent by electronic mail, with first class mail used if necessary or upon request.
Commissioner Hackshaw asked whether the Enforcement Division receives read receipts if a 30-Day Notice is directed to a recipient's spam folder. Ms. Brookman responded that the Enforcement Division had not used read receipts for such notices. She noted that, if a 3D submission was not received, the Enforcement Division would follow up with the subject or his attorney.
On the motion of Vice Chair Connors, seconded by Commissioner Hackshaw, the Commission voted 5-0 to amend the Commission's Enforcement Procedures to provide that 30-Day Notices be sent by electronic mail, with first class mail used if necessary or upon request.
| Vote: | |
|---|---|
| Chair Botsford | Yes |
| Vice Chair Connors | Yes |
| Commissioner Hackshaw | Yes |
| Commissioner Hanley | Yes |
| Commissioner Collins | Yes |
PERFORMANCE EVALUATION OF EXECUTIVE DIRECTOR
Vice Chair Connors stated that the evaluation of the Executive Director would be conducted in public session, but requested that all staff, except for Mr. Wilson, Ms. Slattery, and Senior Program Coordinator Arthur Xia leave the room during the evaluation. He said that he and Commissioner Hackshaw would lead a discussion of the Executive Director's core competencies and major responsibilities during the period of July 1, 2024 to June 30, 2025.
Vice Chair Connors and Commissioner Hackshaw informed the commissioners of the input they received during interviews with staff regarding Mr. Wilson's performance and discussed his self-evaluation. They then led a discussion of Mr. Wilson's performance including a review of his core competencies and major job responsibilities.
[Commissioner Hackshaw left the meeting at 11:07 a.m.]
On the motion of Chair Botsford, seconded by Vice Chair Connors, the Commission voted 4-0 to delegate to Vice Chair Connors and Commissioner Hackshaw the preparation and signing of the Executive Director's written evaluation on behalf of the Commission.
| Vote: | |
|---|---|
| Chair Botsford | Yes |
| Vice Chair Connors | Yes |
| Commissioner Hanley | Yes |
| Commissioner Collins | Yes |
[The Commission recessed at 11:11 a.m. and reconvened at 11:24 a.m.]
Next Meeting
Mr. Wilson reminded the Commission that its next Commission meeting was scheduled for February 26, 2026 at 9:30 a.m. Following discussion, the Commission scheduled its subsequent meeting for March 26, 2026 at 9:30 a.m.
EXECUTIVE SESSION
At 11:25 a.m., on the motion of Vice Chair Connors, seconded by Commissioner Collins, the Commission voted 4-0 to enter executive session to discuss matters subject to the provisions of G.L. c. 30A, § 21, subparagraph (a)(7), and § 18, and G.L. c. 268B, §§ 3 and 4, including investigatory matters, preliminary inquiries, summons authorization requests, and adjudicatory matters.
| Vote: | |
|---|---|
| Chair Botsford | Yes |
| Vice Chair Connors | Yes |
| Commissioner Hanley | Yes |
| Commissioner Collins | Yes |
Vice Chair Connors stated that the Commission would not reconvene in public session following the executive session.
LIST OF DOCUMENTS USED AT THIS MEETING
- Agenda for the Commission Meeting of January 22, 2026
- Minutes of the Commission Meeting of December 18, 2025, Public Session
- Audit Report of the Office of the State Auditor, issued December 24, 2025
- Memorandum, dated January 16, 2026, from Public Education and Communications Division Chief Donald Siriani to the Commission concerning Public Education and Communications Division activities in December 2025
- Memorandum, dated January 15, 2026, from General Counsel/Legal Division Chief Eve Slattery to the Commission setting forth Legal Division matters for the meeting
- Calendar of hearing dates and pre-hearing conferences in pending Commission adjudicatory matters
- Enforcement Case Metrics
- Enforcement Intake and Matter Metrics
- Memorandum, dated January 9, 2026, from Enforcement Division Chief Monica Brookman to the Commission regarding an Enforcement Procedure Amendment
- Performance Evaluation Form for Executive Director David A. Wilson (Evaluation Period: 7/1/24 to 6/30/25)
Respectfully submitted,
Arthur Xia
Senior Program Coordinator