May a City employee take official action that would affect the financial interests of a person who was a client of theirs prior to their joining the City?
Yes. The City and State Conflict of Interest Restrictions only apply to current financial relationships. So long as the present financial relationship does not exist, a conflict of interest will not arise. As such, a City employee is not prohibited from taking official action that would affect a former client.
These advice tidbits are for reference only. They are not intended as legally protective guidance or binding interpretation of laws within the Board's jurisdiction. You can request individualized informal advice by contacting BOEGCStaff@phila.gov or clicking the Ask for Advice button on the Board's website.