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URA counsel proposes streamlined conflict-of-interest policy for HOF advisory board
Summary
URA associate counsel presented a revised conflict-of-interest policy for the Housing Opportunity Fund (HOF) advisory board that narrows the definition to financial benefit, clarifies disclosure and recusal procedures for funding recommendations, allocation-plan deliberations and RFP preparation, and requests annual disclosures by June 1.
Alex Thomas, associate counsel for the Urban Redevelopment Authority, presented a revised conflict-of-interest policy to the Housing Opportunity Fund (HOF) advisory board at its May 6 meeting, saying the draft is intended to simplify rules for disclosure and recusal and to align the board’s guidance with a commonly used legal standard.
The draft borrows the definition used in the Pennsylvania Public Official and Employees Act, Thomas said, framing a conflict of interest around the use of public authority or confidential information for private financial benefit. Although the HOF advisory board is an advisory body and not subject to that state law, Thomas said the legal team adapted the definition to apply to the board’s work — including funding recommendations, preparation of requests for proposals and voting on the annual allocation plan.
Board members were given three categories in the draft that trigger different procedures. For an actual conflict tied to a funding award recommendation, the draft requires disclosure and recusal from the vote. For conflicts tied to the annual allocation plan, the draft calls for disclosure and generally allows participation in broader discussions while requiring recusal from votes when the member or a close associate is specifically named in an allocation. The draft also introduces explicit guidance about RFP preparation: members who help draft an RFP and have a connection to a potential respondent should disclose the relationship and should not participate in HOF reviews of that RFP.
Several board members asked questions about how the definitions would apply in practice. Tamika Harris, a board member, asked whether representing the mayor’s office would itself create a perceived conflict; Thomas replied that mere affiliation with the city does not, by itself, create the financial-gain component the definition focuses on. Ally Fisher asked whether working for an organization that intends to apply for HOF funds requires recusal from the allocation-plan vote; Thomas said prior legal guidance and the draft both permit members to participate in allocation-plan discussions when an organization may apply in the future, with disclosure encouraged, while requiring recusal when the allocation contains a direct, named benefit to the member’s organization.
The draft also shortens the advisory board’s annual disclosure form and asks members to complete it each year; Thomas said the legal team requests disclosures by June 1 to coincide with the adoption of the updated policy. Thomas invited questions and offered to advise members individually on sensitive situations.
The board did not take a formal vote on the draft at the meeting; Thomas said the UDRA legal team will recirculate the document to members who reported difficulty locating the initial email version.
The draft establishes disclosure as the default response for perceived conflicts and preserves recusal for actual conflicts that create a direct financial benefit. It also adds a specific recommendation that board members avoid participating in HOF review processes for RFPs they helped prepare if they have a connection to a respondent.
Board members thanked Thomas for the clarity and asked that the disclosure form be recirculated. Thomas said staff will distribute the form and is available to answer follow-up questions.
