Monday, August 13, 2012



I’ve heard from some interested parties that it is difficult to understand what negative effect the new JJOKE guidelines on reportable business relationships may have.

I think using the JOKE’s own employees as an example might illustrate the danger from the new guidelines.

So with that thought in mind I decided to review the JJOKE financial disclosure reports again with an eye towards getting a return on my financial investment (copying fees) and lo and behold I saw the following two facts.

Fact one, JOKE executive director Ellen Biben reported that she has a mortgage with “Chase” which is JP Morgan Chase.

Fact two JOKE press flack John Milgram reported that he has a revolving line of credit in excess of $5,000 with “American Express.”

What do these two facts have in common?

Both Milgram and Biben are state employees under the JOKE guidelines for “reportable business relationships.”

And both “Chase” and “American Express” are clients of lobbyists and therefore, subject to the guidelines for “reportable business relationships.”

And both the mortgage and revolving line of credit are within the definition of compensation requiring reporting if provided by a client to a state employee.

And lastly,neither “Chase” nor “American Express” has reported Biben or Milgram and their respective “reportable business relationship” on their client semiannual reports, nor have they amended their reports to correct this filing deficiency.

Based on these facts I intend to use the JOKE’s new website feature, “Tips and Complaints” to report these violations. This will allow the Commission to begin the process to investigate and fine these two clients. Although Ms. Biben and Mr. Milgram should have done so themselves as they created the guidelines and are certainly aware of their reportable business relationship partner’s failure to report said relationships (which brings up a related issue of why didn’t Biben and Milgram recuse themselves from the discussion of these guidelines but that’s for another blog and a separate ethics complaint).

My goal is twofold, either the JOKE will recognize the folly of their new guidelines and “tweak” them so that the violations of Chase and American Express are no longer violations (no thanks necessary from the lobbying community this is what vigilante ethics is all about) or they will actually punish Chase and American Express sending a clear message to the lobbying community and their clients that the JOKE is completely out of control. That action could result in many of the big lobbying clients trying to avoid being the next example. I guess my investment in the financial disclosure reports has the potential to reap some benefits after all.

Depending on what the JOKE does, I might be in the market to trade in my minivan. Maybe Chairwoman DiFiore can help me shop for a new Bentley.

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