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44512	2023/Goldberg,_Deborah_section_23_disclosure_11.8.23_(1).pdf	The Commonwealth of Massachusetts OFFICE OF THE STATE TREASURER STATE HOUSE, ROOM 227 BOSTON, MASSACHUSETTS 02133 A DEBORAH B. GOLDBERG TREASURER AND RECEIVER GENERAL TEL (617) 367-6900 FAX (617) 248-0372 November 8, 2023 Ms. Eve Slattery Division Chief and General Counsel State Ethics Commission One Ashburton Place, Room 619 Boston, MA 02108 RE: Commonwealth's Economic Empowerment Trust Fund Disclosure of Appearance of Conflict of Interest, M.G.L. c. 268A $23(b)(3) - Citizens Dear General Counsel Slattery: I am writing as the Massachusetts Treasurer and as Chair of the Economic Empowerment Trust Fund ("EETF") Board of Trustees. The purpose of this correspondence is to disclose, in accordance with M.G.L. C. 268A, that during the period of November 2022 to September 2023, I sought donations for, and on behalf of, the EETF pursuant to M.G.L. c. 10, §35QQ. The EETF is a recognized 501(c)(3) tax-exempt nonprofit organization that was created pursuant to M.G.L. c. 10, §35QQ. The EETF is tasked with encouraging and facilitating economic empowerment throughout the Commonwealth by, among other things, supporting and promoting wage equality, establishing financial literacy programs, creating college savings accounts, and establishing college and career readiness programs in the fields of STEM. Pursuant to its enabling statute, the Legislature has directed the EETF to accept private contributions and publicly or privately funded grants. Additionally, M.G.L. c. 10 §35QQ requires the Treasurer to "maximize the balance of the [EETF] by soliciting private donations, gifts, grants and bequests for the fund, including through direct and indirect fundraising." Pursuant to this authority and as required by M.G.L. c. 268A §23(b)(3), I disclose that I have, on behalf of the EETF, submitted an application in response to Citizens publicly advertised invitation to nonprofit organizations to apply for funding for financial literacy programs that teach good financial practices.¹ I submitted this application electronically on November 29, 2022, through the Citizens online submission portal. Citizens notified the Commonwealth on March 23, 2023, that it had awarded EETF $40,000 as the result of the application. This contribution was received on April 26, 2023. Citizens currently provides banking services, and may in the future provide additional services, to the Office of the Treasurer and Receiver General ("Treasury").2 To reiterate, as required by M.G.L. c. 268A and pursuant to guidance provided by the State Ethics Commission, I provide this formal written disclosure for myself and on behalf of the Treasury to dispel any potential appearance of a conflict of interest resulting from this grant request and from EETF's receipt of $40,000 from Citizens. Taking into account the facts that I have disclosed above, I feel that I and the employees of the Treasury can perform our official duties objectively and fairly. If your office has any questions and/or concerns, please do not hesitate to contact my office. Thank you for your time and attention to this matter. Sincerely, Deborah B. Goldberg Treasurer and Receiver General Chair, Economic Empowerment Trust Fund Board of Trustees 1 In addition to providing instructions on how to apply, Citizens' publicly advertised funding opportunity stated that one of its primary focuses is to support programs that "[t]each [m]oney [m]anagement through financial literacy programs that provide individuals and small businesses with tools needed to be fiscally healthy." 2 Citizens Financial Group, Inc. ("CFG") is the bank holding company for Citizens and Citizens Bank of Pennsylvania and is organized under the Laws of the State of Delaware with a principal place of business in Providence, Rhode Island. The Treasury may currently or in the future engage in business with CFG, Citizens, and/or Citizens Bank of Pennsylvania.