PUBLIC SESSION
MEETING CONVENED
Chair Margot Botsford called the meeting to order at 9:30 a.m. Also in attendance were Vice Chair Thomas A. Connors, Commissioner Wilbur P. Edwards, Jr., Commissioner Eron Hackshaw, and Commissioner Patrick Hanley.
REMOTE PARTICIPATION
Chair Botsford 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. Chair Botsford 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 Edwards, the Commission voted 5-0 to waive the reading and approve the public session minutes of the July 31, 2025 Commission meeting.
| Vote: | |
|---|---|
| Chair Botsford | Yes |
| Commissioner Edwards | Yes |
| Commissioner Hackshaw | Yes |
| Vice Chair Connors | Yes |
| Commissioner Hanley | Yes |
EXECUTIVE DIRECTOR’S REPORT
Executive Director David A. Wilson presented his monthly report.
Personnel
Mr. Wilson noted that former Enforcement Division Chief Stephen P. Fauteux, who served the Commission in that capacity for over thirty years, had recently passed away. At Mr. Wilson’s request, a moment of silence in Mr. Fauteux’s honor was observed.
Mr. Wilson welcomed new Chief of Finance and Operations Benjamin Bloomenthal and Public Education and Communications Division Chief Donald Siriani, who joined the Commission staff on August 11, 2025, to their first Commission meeting.
Budget
Mr. Wilson provided an update on the Commission’s Fiscal Year 2026 budget. He reported that the Commission’s Fiscal Year 2026 Spending Plan was submitted to the Executive Office for Administration and Finance on August 26, 2025. Mr. Wilson stated that Mr. Bloomenthal and Government Affairs Officer Jennifer McCullough would provide a Fiscal Year 2026 budget overview at the Audit, Finance and Human Resources Committee meeting scheduled for later that day at 1:00 p.m.
1L Career Conference Employer Fair
Mr. Wilson reported that Assistant General Counsel Ting Chiu, Staff Counsel Candies Pruitt, and Senior Assistant General Counsel T. Michael McDonald participated in the Boston University School of Law 1L Career Conference Employer Fair on September 15, 2025. He stated that, although the Commission does not currently have open attorney positions, the event was a valuable opportunity for Commission staff to connect with aspiring lawyers and encourage them to consider careers in governmental ethics law and public service generally. Ms. Chiu stated that attending the event at her alma mater helped raise awareness among incoming 1L students about the Commission’s work and possible future job opportunities. Chair Botsford asked about the turnout. Ms. Chiu reported that the Commission’s table received steady foot traffic and that students had asked thoughtful questions. Commissioner Hanley stated that he would be interested in participating with Commission staff in future career fairs at Boston University School of Law, given his role as a Lecturer there. Commissioner Hackshaw thanked Ms. Chiu, Ms. Pruitt, and Mr. McDonald for attending the fair and stated that, in his capacity as Director for Public Service and Pro Bono in the Career Development and Public Service Office at Boston University School of Law, he sought to ensure that the event included not only large law firms but also government agencies and other public interest employers.
New Commissioners
Mr. Wilson noted that Commissioner Hackshaw’s term will expire on September 21, 2025, reported that he has agreed to continue to serve on a holdover basis, and thanked him for doing so. Mr. Wilson reported that he has been in contact with the Governor’s appointment people concerning the appointment of Commissioner Edward’s successor and has been told that an appointment is near, and with the Office of the Attorney General regarding the appointment of Commissioner Hackshaw’s successor and has been told that a notice of a vacancy on the Commission has been posted. He further reported that the Attorney General’s Office has told him that they would welcome Commission input regarding possible candidates, and he invited the Commissioners to provide him with the names of qualified persons interested in serving on the Commission as potential candidates, which he will pass along to the Office of the Attorney General.
Staff Retirement
Mr. Wilson reported that the retirement party for former Commission Chief Financial Officer Alice Wu was successfully held on August 12th and her last day at the Commission was August 15th. He stated that Ms. Wu’s final week overlapped with Mr. Bloomenthal’s first week, which allowed her to help orientate him in his new role.
Cybersecurity Training
Mr. Wilson reported that the Commission staff would participate in a training program on cybersecurity facilitated by the MassCyberCenter on September 30, 2025 at 12:00 p.m. Chair Botsford asked whether the training was intended to instruct Commission staff on the Commission’s internal systems. Mr. Wilson explained that the training will provide a broader opportunity to address cybersecurity issues as part of the Commission’s Internal Control Plan. He noted that IT Specialist Tony Webb has regularly implemented system updates and provided Commission staff with information about cybersecurity threats as part of his responsibilities.
Ice Cream Social
Mr. Wilson reported that the Commission’s annual ice cream social is scheduled for September 30, 2025 at 2:00 p.m.
Next Meeting
Mr. Wilson reminded the Commission that the next Commission meeting was scheduled for October 23, 2025 at 9:30 a.m. Following discussion, the Commission scheduled its subsequent meetings for November 20, 2025 at 9:30 a.m. and December 18, 2025 at 9:30 a.m.
APPOINTMENT OF CHAIR OF AUDIT, FINANCE AND HUMAN RESOURCES COMMITTEE
The Commission by acclamation appointed Commissioner Hanley to serve as Chair of the Audit, Finance and Human Resources Committee.
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 July and August 2025.
Mr. Siriani reported that no press releases were issued in July and August. He further reported that, while there was no public education seminars conducted in July and August, he is scheduled to conduct seminars for the Tri County Clerks’ Association, the Massachusetts Cultural Council, the Executive Office of Health and Human Services, the Office of the Inspector General Academy, and the Trial Court Officer Academy in October.
Mr. Siriani stated that Senior Public Information Officer Gerry Tuoti, Senior Program Coordinator Arthur Xia, and Receptionist Arisa Waguespack responded to calls and e-mails regarding the online learning training program and hosting platform. He reported that, to date, 336,361 public employees and a total of 826 municipalities and other public agencies have registered to use the learning management system.
Mr. Siriani provided an update on the Legal Case Management System project. He said that the Executive Office of Technology Services and Security is currently reviewing the accessibility of the system’s online forms and public portals.
Mr. Siriani reported that, as the Commission’s Public Records Access Officer, Mr. Tuoti, responded to 31 public records requests in July and in August, and that over 7,000 records were provided in response to those requests.
Mr. Siriani reported that the Commission’s LinkedIn page currently has over 1,000 followers. He stated that the increase in followers allows the Commission’s content to reach a wider audience and encouraged LinkedIn users to follow the Commission’s page to stay informed about the Commission’s work.
Public Education and Communications Division and Information Technology Report for Fiscal Year 2025
Mr. Siriani presented the Public Education and Communications Division and Information Technology Report for Fiscal Year 2025. He reported that, during Fiscal Year 2025, 17 press releases and 17 news items were issued by Mr. Tuoti and Mr. Xia, 47 public education seminars attended by 1,956 public employees were conducted, and that former Public Education and Communications Division Chief David Giannotti and Mr. Tuoti responded to 443 calls and emails from the media and the public. Mr. Siriani stated that Information Technology Specialist Tony Webb has continued to ensure that the Commission’s systems remain secure and reliable, with no significant downtime internally or externally. He noted that Mr. Webb is continuing to work with the vendor on the Legal Case Management System project to implement features to allow the system to accommodate online forms submissions of complaints, requests for advice, conflict of interest law disclosures, electronic case filings, public records requests, updated lists of special municipal employees, and charter school board member financial disclosures.
LEGAL DIVISION MATTERS
General Counsel/Legal Division Chief Eve Slattery reported on the activities of the Legal Division in July and August 2025.
Ms. Slattery reported that there was a significant increase in calls in July due to an incident involving the SFI Public Inspection Module. Legal Division Deputy Chief/SFI Lauren Duca explained that a public user ran a script to automate bulk downloading of all the SFIs in the system for the years 2018 to 2024 at a rate of approximately four per second, which prompted the SFI system to notify filers multiple times that their Calendar Year 2024 SFI had been viewed, including those who filed in prior years but who did not and were not required to file for Calendar Year 2024. Ms. Duca further reported that the incident resulted in more than 400 calls from affected filers seeking clarification. She stated that the SFI Team will work with the vendor to prevent automated scripts in the future and to implement safeguards in the new SFI system.
Vice Chair Connors asked whether the issue could be corrected in the current SFI system. Ms. Duca explained that implementing a technical fix would require substantial expenditure, which would not be practical given the upcoming transition to the new system. She stated that under the financial disclosure law, filers will continue to receive notices when their SFIs are viewed, and that the SFI Team can deactivate user credentials if a public user engages in similar automated bulk downloading. She noted that public users seeking bulk access to SFIs are expected to submit requests directly to the Commission, which then manages the process and provides notice to filers accordingly.
Legal Division Metrics for July and August 2025
Ms. Slattery presented the following Legal Division metrics for July and August 2025.
- Written advice. The Legal Division answered by letter or e-mail 303 (July) and 34 (August) written requests for advisory opinions under G.L. c. 268A and c. 268B. Of these requests, 259 (July) and 3 (August) pertained to SFIs.
| For comparison: | |
|---|---|
| July 2024 (same month prior year) (total/SFI): | 39/4 |
| August 2024 (same month prior year) (total/SFI): | 47/1 |
| May 2025 (previous month) (total/SFI): | 33/5 |
- Oral advice. The Legal Division attorneys provided advice by telephone in response to 434 (July) and 345 (August) requests for advice from state, county, and municipal officials. Of these requests, 123 (July) and 10 (August) pertained to SFIs.
| For comparison: | |
|---|---|
| July 2024 (same month prior year) (total/SFI): | 337/12 |
| August 2024 (same month prior year) (total/SFI): | 317/6 |
| May 2025 (previous month) (total/SFI): | 339/17 |
- Review of municipal letters. Division staff reviewed 0 (July) and 0 (August) letters issued by city solicitors/town counsel pursuant to G.L. c. 268A, § 22 and 930 CMR 1.03.
| For comparison: | |
|---|---|
| July 2024 (same month prior year): | 3 |
| August 2024 (same month prior year): | 0 |
| June 2025 (previous month): | 0 |
- Backlog. As of September 11, 2025, the Division had 0 pending requests for written advice that were more than 30 days old. As of that date, there were a total of 9 pending requests for written advice.
Adjudicatory Matters
Ms. Slattery presented the September/October calendar of conferences/hearings in pending Commission adjudicatory proceedings.
Litigation Matters
Ms. Slattery reported that the Supreme Judicial Court had issued a decision in the matter of Dean Tran v. Commonwealth, in which former Senator Dean Tran sought interlocutory review after his motion to dismiss based on a claim of legislative immunity from criminal prosecution was denied by a Superior Court judge. She stated that the Supreme Judicial Court held that the criminal prosecution of a legislator for a violation of Chapter 268A did not violate separation of powers principles. Ms. Slattery explained that former Senator Dean Tran had been indicted for using his official position to secure unwarranted privileges by using his office staff to perform campaign work with public resources during business hours.
Legal Division Report for Fiscal Year 2025
Ms. Slattery presented the Legal Division Report for Fiscal Year 2025. Ms. Slattery reported that the Legal Division responded to more than 5,000 requests for advice, including municipal counsel opinion reviews. She thanked the Legal Division staff for their dedication in providing timely and accurate advice to public employees. Ms. Slattery noted that this represents a decrease from the previous year, due in part to new reporting methods of the Legal Case Management System.
Ms. Slattery reported that the average monthly backlog of requested written opinions decreased to 1.4 from 2.4 in the prior year, which can be attributed to the Division being fully staffed. She further reported that Legal Division attorneys reviewed approximately 294 disclosures for completeness and served as legal advisors to Commission members in nine adjudicatory proceedings.
Ms. Slattery stated that the Legal Division also submitted an amicus letter on behalf of the Commission in a case addressing the interpretation of “unwarranted privilege,” in which the Supreme Judicial Court affirmed the Commission’s interpretation.
SFI Report
Ms. Duca provided an update on Statements of Financial Interests (SFI) for Calendar Year 2024. She reported that the Calendar Year 2024 filing season was nearly complete, with one filer remaining who had received an extension. Ms. Duca stated that the Public Inspection Module had been temporarily taken offline for review and testing, and that the Legal Division responded to public records requests manually during that period. She reported that the SFI Team handled 484 calls in July, a significant increase from the prior month.
Ms. Duca stated that the Commission had hired a consultant, Gartner, Inc., to assist with the development of the new SFI system. She reported that the consultant completed discovery work and conducted listening sessions with Commission staff, designators, liaisons, filers, and public users, as well as a market scan that included outreach to agencies in other states. She stated that the consultant will provide technology recommendations to the Commission and that staff are preparing procurement documents to obtain a system developer, which will be posted on COMMBUYS. Chair Botsford asked whether funding was available for the project. Ms. Duca stated that the consultant and the new SFI system are being funded through capital funding secured by Government Affairs Officer Jennifer McCullough. She reported that the Commission received $1.2 million for the project and that additional funding may be requested.
Ms. Duca presented the SFI Filing Season Report for Calendar Year 2024. Ms. Duca reported that the Calendar Year 2024 SFI filing season was the most successful since 2012. She stated that the season opened on January 27, 2025, which was the earliest opening date to date, and that 3,872 filers were required to file. Ms. Duca reported that the overall compliance rate was 99.38%, the highest ever recorded by the Commission, and that 98.88% of filers submitted their forms electronically. She noted that only 14 Formal Notices of Lateness were sent, a 62.5% reduction from the previous year, and that no referrals were made to the Enforcement Division for non-filers. Ms. Duca further reported that the SFI Team responded to 1,752 requests for assistance and thanked Special Assistant Rose Costa, Information Technology Specialist Tony Webb, and Administrative Assistant Theresa Meli-Omodei for their hard work. Mr. Wilson commended Ms. Duca and the SFI Team for overseeing the Calendar Year 2024 SFI filing season and the development of a replacement SFI system simultaneously. He reported that the Commission will soon issue a Request for Quotes (RFQ) for system development. He said that the Commission will need to obtain additional capital funding and future operating funding for licensing fees.
Chair Botsford asked whether the Commission anticipated changes to the substance of the SFI form. Ms. Slattery responded that prior to starting work on the RFQ for a consultant on SFI system replacement project, the Legal Division had been reviewing the regulations interpreting the financial disclosure law, including whether categories such as retirement funds and cryptocurrency should be added as reported investments. Mr. Wilson noted that the new SFI system will incorporate the flexibility to accommodate such changes. Chair Botsford stated that the Commission should ensure that nothing substantive in the form is outdated.
ENFORCEMENT DIVISION MATTERS
Enforcement Division Report for Fiscal Year 2025
Enforcement Division Chief Monica Brookman presented the Enforcement Division Report for Fiscal Year 2025. Ms. Brookman reported that the Enforcement Division filed five Orders to Show Cause and conducted nine adjudicatory proceedings in Fiscal Year 2025. She further reported that the Division negotiated eight disposition agreements, issued two public education letters, and sent 113 private education letters. Ms. Brookman thanked the Enforcement Division for their hard work during the fiscal year.
Ms. Brookman reported that the Division had transitioned to the new Legal Case Management System, which replaced the legacy system, Ethos. She stated that the new system allows for more accurate reporting by distinguishing between complaints received and matters investigated, and that staff have spent considerable time testing and providing input to improve its functionality.
Ms. Brookman presented the Enforcement Intake and Matter Metrics for July and August 2025.
EXECUTIVE SESSION
At 10:35 a.m., on the motion of Chair Botsford, seconded by Vice Chair Connors, the Commission voted 5-0 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 |
| Commissioner Edwards | Yes |
| Commissioner Hackshaw | Yes |
| Vice Chair Connors | Yes |
| Commissioner Hanley | Yes |
Chair Botsford 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 September 18, 2025
- Minutes of the Commission Meeting of July 31, 2025, Public Session
- Memorandum, dated September 11, 2025, from Public Education and Communications Division Chief Donald Siriani to the Commission concerning Public Education and Communications Division activities in July and August 2025
- Memorandum dated September 11, 2025 from Public Education and Communications Division Chief Donald Siriani to the Commission concerning Public Education and Communications Division and Information Technology Report for Fiscal Year 2025
- Memorandum, dated September 11, 2025, 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
- Memorandum dated September 11, 2025 from General Counsel/Legal Division Chief Eve Slattery to the Commission concerning the Legal Division Report for Fiscal Year 2025
- Memorandum dated September 10, 2025 from Legal Division Deputy Chief/SFI Lauren Duca to the Commission concerning the SFI Filing Season Report for Calendar Year 2024
- Memorandum dated September 10, 2025 from Enforcement Division Chief Monica Brookman to the Commission concerning the Enforcement Division Report for Fiscal Year 2025
- Enforcement Intake and Matter Metrics
Respectfully submitted,
Arthur Xia
Senior Program Coordinator