TEXAS ETHICS COMMISSION

Ethics Advisory Opinions

Whether communications and appearances while representing an intervening party during judicial review of an agency order constitute prohibited communications to or appearances before the agency's officers or employees by a former member of the governing body of the agency. (AOR-751.)

The Texas Ethics Commission is authorized by section 571.091 of the Government Code to issue advisory opinions in regard to the following statutes: (1) Chapter 572, Government Code; (2) Chapter 302, Government Code; (3) Chapter 303, Government Code; (4) Chapter 305, Government Code; (5) Chapter 2004, Government Code; (6) Title 15, Election Code; (7) Chapter 159, Local Government Code; (8) Chapter 36, Penal Code; (9) Chapter 39, Penal Code; (10) Section 2152.064, Government Code; and (11) Section 2155.003, Government Code.

Questions on particular submissions should be addressed to the Texas Ethics Commission, P.O. Box 12070, Capitol Station, Austin, Texas 78711-2070, (512) 463-5800 or opinions@ethics.state.tx.us.

Issued in Austin, Texas, on September 9, 2026.

TRD-202603935

Amanda Arriaga

General Counsel

Texas Ethics Commission

Filed: September 9, 2026


Whether the TEC may impose a civil penalty pursuant to Section 572.033 of the Government Code for a late personal financial statement (PFS) if the Texas Ethics Commission (TEC) did not send the filer a notice to file as required by Section 572.030 of the Government Code. (AOR-752.)

The Texas Ethics Commission is authorized by section 571.091 of the Government Code to issue advisory opinions in regard to the following statutes: (1) Chapter 572, Government Code; (2) Chapter 302, Government Code; (3) Chapter 303, Government Code; (4) Chapter 305, Government Code; (5) Chapter 2004, Government Code; (6) Title 15, Election Code; (7) Chapter 159, Local Government Code; (8) Chapter 36, Penal Code; (9) Chapter 39, Penal Code; (10) Section 2152.064, Government Code; and (11) Section 2155.003, Government Code.

Questions on particular submissions should be addressed to the Texas Ethics Commission, P.O. Box 12070, Capitol Station, Austin, Texas 78711-2070, (512) 463-5800 or opinions@ethics.state.tx.us.

Issued in Austin, Texas, on September 9, 2026.

TRD-202603936

Amanda Arriaga

General Counsel

Texas Ethics Commission

Filed: September 9, 2026


Whether the requestor's legislative training materials require a legislative advertising disclosure statement.

Whether the requestor's planned business activities require her register as a lobbyist. (AOR-753.)

The Texas Ethics Commission is authorized by section 571.091 of the Government Code to issue advisory opinions in regard to the following statutes: (1) Chapter 572, Government Code; (2) Chapter 302, Government Code; (3) Chapter 303, Government Code; (4) Chapter 305, Government Code; (5) Chapter 2004, Government Code; (6) Title 15, Election Code; (7) Chapter 159, Local Government Code; (8) Chapter 36, Penal Code; (9) Chapter 39, Penal Code; (10) Section 2152.064, Government Code; and (11) Section 2155.003, Government Code.

Questions on particular submissions should be addressed to the Texas Ethics Commission, P.O. Box 12070, Capitol Station, Austin, Texas 78711-2070, (512) 463-5800 or opinions@ethics.state.tx.us.

Issued in Austin, Texas, on September 9, 2026.

TRD-202603937

Amanda Arriaga

General Counsel

Texas Ethics Commission

Filed: September 9, 2026


Whether contributions given to fund an individual voter's legal expenses are political contributions requiring reporting by either the individual or the specific purpose committee that the individual remains an active campaign treasurer for. Whether the requestor has any Title 15 campaign-finance obligations for the contributions received and spent for their individual election contest litigation. (AOR-754.)

The Texas Ethics Commission is authorized by section 571.091 of the Government Code to issue advisory opinions in regard to the following statutes: (1) Chapter 572, Government Code; (2) Chapter 302, Government Code; (3) Chapter 303, Government Code; (4) Chapter 305, Government Code; (5) Chapter 2004, Government Code; (6) Title 15, Election Code; (7) Chapter 159, Local Government Code; (8) Chapter 36, Penal Code; (9) Chapter 39, Penal Code; (10) Section 2152.064, Government Code; and (11) Section 2155.003, Government Code.

Questions on particular submissions should be addressed to the Texas Ethics Commission, P.O. Box 12070, Capitol Station, Austin, Texas 78711-2070, (512) 463-5800 or opinions@ethics.state.tx.us.

Issued in Austin, Texas, on September 9, 2026.

TRD-202603938

Amanda Arriaga

General Counsel

Texas Ethics Commission

Filed: September 9, 2026