" ! HOUSE OF REPRESENTATIVES 

111TH CONGRESS

1st Session 

REVIE

10–

OFFICE OF CONGRESSIONAL ETH

UNITED STATES HOUSE OF 

REPRESENTATIVES 

————— 

Report and Findings 

Transmitted to the 

Committee on Standards of Official Conduct 

on September 1, 2010 

and released publicly pursuant to H. Res. 895 of t

110th Congress as amended 

September 2010 


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U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

58–393 

" ! HOUSE OF REPRESENTATIVES 

111TH CONGRESS

1st Session 

REVIE

2010

10–

OFFICE OF CONGRESSIONAL ETH

UNITED STATES HOUSE OF 

REPRESENTATIVES 

————— 

Report and Findings 

Transmitted to the 

Committee on Standards of Official Conduct 

on September 1, 2010 

and released publicly pursuant to H. Res. 895 of t

110th Congress as amended 

September 2010 


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(II) 

OFFICE OF 

CONGRESSIONAL ETHICS 

BOARD 

UNITED STATES HOUSE OF REPRESENTATIVES

ONE HUNDRED ELEVENTH CONGRESS

DAVID SKAGGS, Chair 

PORTER GOSS, Co-Chair 

YVONNE BURKE 

KAREN ENGLISH 

ALLISON HAYWARD 

JAY EAGEN 

WILLIAM FRENZEL 

ABNER MIKVA 

Leo J. Wise, Chief Counsel & Staff Director 

Kedric L. Payne, Investigative Counsel 


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(1) 

REPORT 

Review No. 10–8839 

The Board of the Office of Congressional Ethics (herea

‘‘Board’’), by a vote of no less than four members, on Au

2010, adopted the following report and ordered it to be tra

to the Committee on Standards of Official Conduct of th

States House of Representatives. 

SUBJECT: Representative Thomas Price 

NATURE OF THE ALLEGED VIOLATION: H.R. 4173, 

known as the Wall Street Reform and Consumer Protectio

2009, was reported out of the Committee on Financial Ser

the afternoon of December 2, 2009. H.R. 4173 (the ‘‘Finan

form Bill’’) was passed by the House on December 11, 2009

cember 10, 2009, Representative Price held a fundraiser 

campaign committee called the ‘‘Financial Services Industr

eon’’ that appeared to solicit entities or individuals regis

lobby on the Financial Reform Bill. Further, Representativ

professional fundraiser offered one-on-one meetings betwe

resentative Price and entities registered to lobby on the F

Reform Bill in December 2009. 

If Representative Price solicited or accepted contributi

manner which gave the appearance that special treatmen

cess was being provided to donors or the appearance that 

tributions were linked to an official act, then he may have 

House Rules and Standards of Conduct. 

RECOMMENDATION: The Board of the Office of Cong

Ethics recommends that the Committee on Standards of 

Conduct further review the above allegations because ther

stantial reason to believe that Representative Price solicit

cepted contributions at the fundraiser he held on Decem

2009, in a manner which gave the appearance that speci

ment or access was provided to donors or that contributio

linked to an official act. 

VOTES IN THE AFFIRMATIVE: 4 

VOTES IN THE NEGATIVE: 0 

ABSTENTIONS: 1 

MEMBER OF THE BOARD OR STAFF DESIGNAT

PRESENT THIS REPORT TO THE COMMITTEE ON 

ARDS OF OFFICIAL CONDUCT: Leo Wise, Staff Director 

Counsel. 


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TABLE OF CONTENTS 

I. INTRODUCTION .....................................................................................

A. Summary of Allegations ..............................................................

B. Jurisdictional Statement .............................................................

C. Procedural History ......................................................................

D. Summary of Investigative Activity ............................................

II. REPRESENTATIVE PRICE’S FUNDRAISING EVENTS ....................

A. House Precedent, Rules, and Standards of Conduct ................

B. Position of Influence ....................................................................

C. Timing of Fundraising Event .....................................................

D. Nature of Fundraising Event .....................................................

E. Presence of Key Staff ..................................................................

F. Limited Number of Attendees ....................................................

III. CONCLUSION ..........................................................................................

IV. INFORMATION THE OCE WAS UNABLE TO OBTAIN AND R

OMMENDATIONS FOR THE ISSUANCE OF SUBPOENAS .........


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(3) 

1 H. Res. 895, 110th Cong. § 1(e) (2008) (as amended). 

FINDINGS OF FACT AND CITATIONS TO LAW 

Review No. 10–8839 

On August 27, 2010, the Board of the Office of Cong

Ethics (the ‘‘Board’’) adopted the following findings of fact 

companying citations to law, regulations, rules, and stan

conduct (in italics). The Board notes that these findings do 

stitute a determination that a violation actually occurred. 

I. INTRODUCTION 

A. SUMMARY OF ALLEGATIONS

1. There is substantial reason to believe that Repres

Thomas Price solicited or accepted contributions in a mann

gave the appearance that special treatment or access w

provided to donors or that the contributions were linked to 

cial act. 

2. The Board notes that, among other facts, Representat

held a fundraising event titled ‘‘Financial Services Industry 

eon’’ on December 10, 2009, the day before the House vote

Financial Reform Bill. All but three of the sixteen individu

attended that event represented entities that were regis

lobby on the bill. The Board further notes that Repres

Price is a member of the Financial Services Committee; is 

uty Ranking Member on the Subcommittee on Capital Mar

surance, and Government Sponsored Entities; and introduc

amendments to the Financial Reform Bill during markup. 

B. JURISDICTIONAL STATEMENT

3. The allegations that were the subject of this review 

Representative Price, a Member of the United States Hous

resentatives from the 6th District of Georgia. The Resolu

United States House of Representatives adopted creating t

of Congressional Ethics (‘‘OCE’’) directs that, ‘‘[n]o review 

undertaken . . . by the board of any alleged violation that 

before the date of adoption of this resolution.’’ 1 The House 

this Resolution on March 11, 2008. Because the conduct u

view occurred after March 11, 2008, review by the Board 

cordance with the Resolution. 

C. PROCEDURAL HISTORY

4. The OCE received a written request for a preliminar

in this matter signed by at least two members of the Board 


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2 A preliminary review is ‘‘requested’’ in writing by members of the Board of th

request for a preliminary review is ‘‘received’’ by the OCE on a date certain. Acc

Res. 895 of the 110th Congress (the ‘‘Resolution’), the timeframe for conducting a 

review is thirty days from the date of receipt of the Board’s request. 3 According to the Resolution, the Board must vote on whether to conduct a seco

view in a matter before the expiration of the thirty-day preliminary review. If the 

for a second-phase, the second-phase begins when the preliminary review ends. 

phase review does not begin on the date of the Board vote. 4 Id. at § 1(c)(2)(A)(ii) (2008). 5Statement of the Honorable Tom Price, dated August 27, 2010 (Exhibit 1 at 10–

005). In addition, counsel for Representative Price submitted a letter to Leo Wise, d

6, 2010, and Representative Price submitted a letter to Leo Wise, dated June 22, 2

2 at 10–8839l007–022). 

24, 2010. The preliminary review commenced on May 25

The preliminary review was scheduled to end on June 23, 2

5. At least three members of the Board voted to initia

ond-phase review in this matter on June 21, 2010. The 

phase review commenced on June 24, 2010. 3 The second-p

view was scheduled to end on August 7, 2010. 

6. The Board voted to extend the forty-five day second-p

view by an additional fourteen days, as provided by the Re

on July 29, 2010. Following the extension, the second-phas

was scheduled to end on August 21, 2010. 4

7. Representative Price appeared before the Board a

mitted a written statement, under Rule 9(B) of the OCE’s R

the Conduct of Investigations, on August 27, 2010. 5

8. The Board voted to refer the matter to the Comm

Standards of Official Conduct and adopted these findings 

gust 27, 2010. 

9. This report and findings were transmitted to the Co

on Standards of Official Conduct on September 1, 2010. 

D. SUMMARY OF INVESTIGATIVE ACTIVITY

10. The OCE’s investigation required the collection of 

tion from a number of sources. 

11. The OCE requested and received documentary and, 

cases testimonial information, from the following sources: 

(1) Representative Price; 

(2) Representative Price’s Chief of Staff; 

(3) Representative Price’s Legislative Assistant; 

(4) Representative Price’s Fundraiser; and 

(5) Chairman of the House Financial Services Comm

12. The OCE requested and received documentary info

from the following sources: 

(1) American Express; 

(2) Astellas US LLC; 

(3) Bank of America; 

(4) Investment Company Institute; 

(5) KPMG; 

(6) National Association of Federal Credit Unions; 

(7) Psychiatric Solutions Inc.; and 

(8) UBS. 


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6 House Ethics Manual 147 (2008). 

7 Id. 

II. REPRESENTATIVE PRICE’S FUNDRAISING EVE

A. HOUSE PRECEDENT, RULES, AND STANDARDS OF COND

13. The House of Representatives intends that Member

to the standards of conduct stated in Rule 23 of the Rule

House and other relevant Rules of the House in the Hous

Manual, the Code of Ethics for Government Service, and 

precedents of the House and the Committee on Standards 

cial Conduct (‘‘Standards Committee’’) in matters related t

In establishing the OCE, the House charged the Board of 

with assisting it in the enforcement of these standards of 

14. In this matter, as the citations below indicate, the B

viewed the conduct at issue under the pertinent standard

in the House Ethics Manual and the memorandum of th

and Ranking Member of the Standards Committee in the m

Representative Tom DeLay (‘‘DeLay Report’’). The cited se

the House Ethics Manual and the DeLay Report relate to 

priety of certain types of political fundraising activity cond

proximity to pending business of the House and its com

The Board respects the final authority of the Standards Co

in matters referred to it by the OCE for the Standards Co

to determine whether conduct apparently proscribed by 

other standards is deemed to be a violation. In this matter

all referrals to the Standards Committee for further rev

OCE Board reaches no conclusion that a violation has occu

only determines if there is substantial reason to believe th

lation may have occurred. 

15. The OCE Board sees its responsibility to assess the 

applicability of standards of conduct to the facts and circum

of the conduct adduced during its time-limited process an

its prescribed authority. It has done so in this matter. It w

inappropriate for the OCE Board to interpret the stan

pressed in the DeLay matter differently than indicated 

precedents and writings of the Standards Committee. 

16. ‘‘It is probably not wrong for the campaign managers 

islator . . . to request contributions from those for whom t

lator has done appreciable favors, but this should never 

sented as a payment for the services rendered. Moreover, t

bility of such a contribution should never be suggested by t

lator or his staff at the time the favor is done. Furthermo

cent interval of time should be allowed to lapse so that neith

will feel that there is a close connection between the two a

Standards Committee has long advised Members and staff 

should always exercise caution to avoid even the appearance 

licitations of campaign contributions are connected in any w

an action taken or to be taken in their official capacity.’’ 6

17. ‘‘[N]o solicitation of a campaign or political contribu

be linked to an action taken or to be taken by a Member or 

in his or her official capacity.’’ 7 ‘‘In addition, a Member 


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8Memorandum of the Chairman and Ranking Minority Member, Recommendat

position of the complaint filed against Representative DeLay, http://ethics.house.go

tions/Default.aspx?Section=18. 9 Id. 

10 Id. 11 Id. 12 Id. 13 Id. As early as late April 2002, executives from a company that would later atte

2002 fundraising event informed the Standards Committee that they were aware o

fundraiser for Representative DeLay that could affect their business interests. Fur

event, Representative DeLay, his legislative staffer focused on energy issues, and hi

sel, engaged in direct contact with attendees, often discussing a broad range of e

issues. The Standards Committee, in finding that certain fundraising activity ‘‘did 

to House standards,’’ expressly found that ‘‘(1) neither Representative DeLay nor an

on his behalf improperly solicited contributions from Westar, and (2) Representative 

no action with regard to Westar that would constitute an impermissible special f

the Standards Committee’s findings not only analyzed an appearance standard abse

ing of improper solicitation of campaign contributions, but it also did so regardless 

mate position Representative DeLay took on the energy bill. 14 The Standards Committee took a broad view of ‘‘timing’’ standards stating th

ticular, there was the timing of the fundraiser, i.e., it took place just as the House

ference on major energy legislation, H.R. 4, was about to get underway.’’ Id. (emph

15 Id. 

accept any contribution that is linked with any specific off

tion taken or to be taken by that Member.’’ 8

18. ‘‘[T]he scope of the House standards of conduct in t

is broader than that of the criminal bribery statute . . . th

standards of conduct generally preclude any link between t

tation or receipt of a contribution and a specific official acti

19. ‘‘Put another way, there are fundraising activities tha

violate any criminal statute but may well violate House st

of conduct.’’ 10

20. ‘‘[T]here are certain proffered campaign contributi

must be declined, and certain fundraising opportunities th

be forgone, solely because they create an appearance of i

conduct.’’ 11

21. ‘‘The broad House standards of conduct in this area 

extremely important ones.’’ 12

22. These standards were expressly addressed in the De

port. In that matter, a June 2002 energy industry fundra

held for Representative DeLay, coordinated by a forme

staffer working as a lobbyist and various energy industry l

Five energy companies and their executives attended the 

Three months later in September 2002, during a House-Sen

ference over a broad-sweeping energy bill, Representativ

took part in the conference as an appointed conferee. 

23. The Standards Committee specifically noted the f

factors in finding that Representative DeLay’s fundraising 

did not conform to House standards: (1) Representative De

sition of significant influence on certain legislation; (2) the 

of the fundraiser in connection to certain legislative activi

consideration by the House; (3) the nature of the fundraisin

(4) the presence of key staff members at the event; and (5) 

ited number of attendees in direct contact with both Repres

DeLay and his staff. 15 In determining whether a matter w

further review, the OCE compared conduct at issue to thes

as detailed below. 


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16Memorandum of Interview of Representative Price’s Legislative Assistant, da

2010 (‘‘Legislative Assistant MOI’’) (Exhibit 3 at 10–8839l025). 17Summary of Amendments Submitted to the Rules Committee for H.R. 4173—

Reform and Consumer Protection Act of 2009, http://rules.house

mentldetails.aspx?NewsID=4516. 

B. POSITION OF INFLUENCE

24. Representative Price is a Member of the House F

Services Committee. He is the Deputy Ranking Member of 

committee on Capital Markets, Insurance, and Governme

sored Enterprises. 

25. He also serves as the Chairman of the Republica

Committee. 

26. During the markup of the Financial Reform Bil

House Financial Services Committee, Representative Pri

duced approximately eight amendments. 16

27. Following the markup, he also offered six amendm

the Financial Reform Bill to the Rules Committee. 17

C. TIMING OF FUNDRAISING EVENT

28. On December 10, 2009, Representative Price held 

raiser at the Capitol Hill Club in Washington, DC. 


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18 Invitation to December 10, 2009 Financial Services Industry Luncheon (Exhi

8839l027). 19Memorandum of Interview of Representative Price’s Fundraiser, dated Ju

(‘‘Fundraiser MOI’’) (Exhibit 5 at 10–8839l031). 

29. The invitation for the fundraiser labeled the event a 

cial Services Industry Luncheon.’’ 18

30. The day after the Financial Industry Services 

Luncheon, December 11, 2009, the House of Representativ

on the Financial Reform Bill. 

31. According to Representative Price’s Fundraiser, sh

planning this event in late September or October 2009. 19 A

to Representative Price’s Legislative Assistant, the Financ


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20Legislative Assistant MOI (Exhibit 3 at 10–8839l024). 21 Email from Representative Price’s Fundraiser to Edward Hill and Paul Kanga

vember 3, 2009 (Exhibit 6 at 10–8839l034). The Board notes that in the DeLay 

Standards Committee found that Representative DeLay’s June 2002 fundraiser had 

ance of impropriety, even though it had been planned over one month in advance. 22Memorandum of Interview of Chairman of the Financial Services Committee, da

2010 (Exhibit 8 at 10–8839l041). 23Memorandum of Interview of Representative Price, dated July 29, 2010 (Exhi

8839l038). 24 Email from Representative Price’s Fundraiser to Edward Hill and Paul Kanga

vember 3, 2009 (Exhibit 6 at 10–8839l034). 25 Id. 

ices Committee’s first markups on legislation that was ul

consolidated into the Financial Reform Bill, began in Se

2009. 20 Based on information that the Fundraiser provide

OCE, the finalized invitation for the December 10th lunch

first distributed on November 3, 2009. 21

32. The Board notes that the Chairman of the Financial 

Committee told the OCE that Members would have know

vember 2009 that the Financial Reform Bill would be out 

mittee and on the House floor for a final vote in December 

D. NATURE OF FUNDRAISING EVENT

33. According to Representative Price, his fundraiser is 

sible for scheduling and organizing his campaign fun

events in Washington, DC. 23

34. Representative Price’s Fundraiser told the OCE tha

cided to have a fundraising event tailored to the financial 

industry because Representative Price is on the Financial 

Committee. 

35. The Fundraiser worked with at least two lobbyi

resenting organizations registered to lobby on the Financia

Bill to organize the event and solicit contributions. 24 In 

from the Fundraiser to representatives for the Bank of 

and the Property Casualty Insurers Association of America 

nalizes the date for the Financial Services Industry Lunch

thanks the two hosts ‘‘for helping round up [their] collea

this event.’’ 25


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26Fundraiser MOI (Exhibit 5 at 10–8839l031). 27 Email from Representative Price’s Fundraiser to Paul Kangas, dated Decemb

(Exhibit 9 at 10–8839l043). 28See Lobbyist Disclosure Database, U.S. House of Representatives, available 

lobbyingdisclosure.house.gov/index.html. 29 Id. 

36. The Fundraiser told the OCE that she distributed th

tion to financial services industry organizations that she 

from a larger database of past and potential donors to Rep

tive Price’s campaign. 26

37. According to the attendee list for the luncheon th

resentative Price provided to the OCE, twenty organ

planned to attend. Of the twenty organizations listed 

attendee list 27, seventeen were registered to lobby on the F

Reform Bill. 28 The three remaining organizations were re

lobby on other legislation pending before the Financial 

Committee: Marsh & McLennan Companies, Inc.; Morongo 

Mission Indians; and Pace LLP. 29


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30 Email from Representative Price’s Campaign Fundraiser to Edward Hill, date

9, 2009 (Exhibit 10 at 10–8839l047). 31 Email from Representative Price’s Fundraiser to Jennifer Bogart, dated Decem

(Exhibit 11 at 10–8839l050); Fundraiser MOI (Exhibit 5 at 10–8839l032). 

38. On December 9, 2009, the Fundraiser asked one of th

ists hosting the event to contact a list of financial services 

companies to attend the Financial Services Industry Lunc

next day. 30 Specifically, the Fundraiser requested that the 

America lobbyist contact HSBC, Wachovia, Morgan 

Checkfree, American Financial Services Association and M

Omaha. 

39. Also on December 9, 2009, the Fundraiser sent an 

another campaign fundraiser with a list of financial service

try organizations that should be contacted to attend Repres

Price’s lunch the next day. 31 Specifically, the Fundraiser l

following companies for ‘‘targeted follow ups’’: New Yo


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32 Id. 33 Email from Representative Price’s Fundraiser to Anna Beth Strong, dated N

2009. (Exhibit 12 at 10–8839l053). 34Memorandum of Interview of Representative Price’s Chief of Staff (‘‘Chief of 

(Exhibit 13 at 10–8839l056); Fundraiser MOI (Exhibit 5 at 10–8839l030). 35Fundraiser MOI (Exhibit 5 at 10–8839l030). 

NAIPA; TransUnion; Lincoln National; ICBA; Assura

NAMIC. 32

40. In addition, during the week before the Financial 

Industry Luncheon, the Fundraiser arranged one-on-one m

between Representative Price and potential campaign c

tors. 33

41. One potential campaign contributor for which the Fu

scheduled a meeting with Representative Price was the Inv

Company Institute. On December 1, 2009, Representati

had a one-on-one meeting with a representative for the Inv

Company Institute, which was attended by Representativ

Chief of Staff and Fundraiser. 34

42. The Fundraiser told the OCE that the one-on-one 

was not a fundraising event. 35


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36 Chief of Staff MOI (Exhibit 13 at 10–8839l056). 37 Email from Representative Price’s Fundraiser to Dean Sackett, dated Novemb

(Exhibit 14 at 10–8839l060). 

43. Representative Price’s Chief of Staff told the OCE 

one-on-one meeting was a fundraising event. He also e

that the ‘‘FR Mtg’’ note on Representative Price’s calenda

meeting indicates that it was a fundraising meeting. 36

44. The scheduling of the one-on-one meeting appears 

been finalized in an email from the Fundraiser to the Inv

Company Institute, where the Campaign Fundraiser provi

minder for a ‘‘1–1 meeting with Price on Dec 1st.’’ This r

was sent after the Investment Company Institute agreed t

the December 10th Financial Services Industry Luncheon. 3


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38 Email from Representative Price’s Fundraiser to Anna Beth Strong, dated N

2009 (Exhibit 12 at 10–8839l053). 39See Lobbyist Disclosure Database, U.S. House of Representatives, available 

lobbyingdisclosure.house.gov/index.html. 40Fundraiser MOI (Exhibit 5 at 10–8839l031). 41Legislative Assistant MOI (Exhibit 3 at 10–8839l025). 42 Email from Representative Price’s Fundraiser to Paul Kangas, dated Decemb

(Exhibit 9 at 10–8839l043). 43Fundraiser MOI (Exhibit 5 at 10–8839l032). 44 Id. 

45. According to an email from the Fundraiser to Repres

Price’s scheduler, one-on-one meetings were also schedule

cember 1st for Clark and Weinstock and an entity called ‘

Clark and Weinstock is a firm registered to lobby on the F

Reform Bill. 39

E. PRESENCE OF KEY STAFF

46. Representative Price’s Chief of Staff attended the D

10th fundraiser. 40

47. Representative Price’s Legislative Assistant, who is 

sible for financial services issues, did not attend the Decem

fundraiser. 41

F. LIMITED NUMBER OF ATTENDEES

48. On the day of the Financial Services Industry L

twenty individuals representing twenty separate organiza

dicated that they would attend. 42

49. According to the Fundraiser, approximately sixteen 

uals attended. 43 She stated that the following four peopl

attendee list did not attend: Mike Moran (Credit Suisse

Patterson (JP Morgan Chase), Liz Varley (SIFMA), and Da

(Wells Fargo). 44

III. CONCLUSION 

50. In conclusion, based on the evidence available to t

Representative Price held a Financial Services Luncheon 

cember 10, 2009, which was the day before the House vot

Financial Reform Bill. Representative Price is a Membe

House Financial Services Committee and Deputy Ranking 

of the Subcommittee on Capitol Markets, Insurance and 

ment Sponsored Enterprises. Representative Price’s Fundr

licited organizations that were registered to lobby on the F

Reform Bill for contributions to attend this event during th

up of the legislation and two days before the vote. Thirtee

sixteen individuals who attended the event represented o

tions registered to lobby on the Financial Reform B

attendees had access to Representative Price and his Chief 


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In addition, the Fundraiser offered at least one of the c

contributors one-on-one access with Representative Price 

Chief of Staff the week before the event, which the donor a

51. For these reasons, The Board recommends that th

ards Committee further review the above allegations becau

is substantial reason to believe that Representative Price 

or accepted contributions at the fundraiser he held on D

10, 2009, in a manner which gave the appearance tha

treatment or access was provided to donors or that contr

were linked to an official act. 

IV. INFORMATION THE OCE WAS UNABLE TO OBTAI

RECOMMENDATIONS FOR THE ISSUANCE OF SUBPO

52. In every instance, the OCE asked the recipient of 

Request for Information to identify any information they 

and the reason they were withholding it. However, absent 

thority to subpoena the evidence in possession of the witn

impossible for the OCE to verify if information was withh

not documented. 

53. The OCE included with its Request for Information

quest for Information Certification’’ document that ask

identified by the OCE to ‘‘certify that I have provided the 

Congressional Ethics all information requested in the Req

Information, dated [June 1, 2010], and if I have not provid

quested document or certain information, then I have ident

document or information that was not available or withh

why it was not available or withheld. This certification 

subject to 18 U.S.C. § 1001 (commonly known as the Fals

ments Act).’’ 


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54. Of the eight third-party entities discussed above, 

lowing returned the certification: 

(1) Astellas US LLC 

55. The following third party provided documents but di

turn the certification: 

(1) Bank of America 

56. The following third parties informed the OCE th

would not be providing all of the information requested or 

provide all of the information requested: 

(1) American Express 

(2) Investment Company Institute 

(3) KPMG 

(4) National Association of Federal Credit Unions 

(5) Psychiatric Solutions 

(6) UBS 


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