TEXAS ETHICS COMMISSION
The Texas Ethics Commission is authorized by Government Code, sec.571.091, to 
issue advisory opinions in regard to the following statutes: the Government 
Code, Chapter 302; the Government Code, Chapter 305; the Government Code, 
Chapter 572; the Election Code, Title 15; the Penal Code, Chapter 36; and the 
Penal Code, Chapter 39.
Requests for copies of the full text of opinions or questions on particular 
submissions should be addressed to the Office of the Texas Ethics Commission, 
P.O. Box 12070, Austin, Texas 78711-2070, (512) 463-5800.
Texas Ethics Commission
Opinions
EAO-227 (AOR-251).
Whether the "members" of a Texas farm mutual insurance company, as provided for 
in the Texas Insurance Code, Chapter 16, are "members" of the insurance company 
for purposes of the Election Code, sec.253.098.
Summary of Opinion.
A "member" of a farm mutual insurance company, as provided for in the Insurance 
Code, Chapter 16, is a "member" of the farm mutual insurance company for 
purposes of the Election Code, sec.253.098.
EAO-228 (AOR-254).
Whether a legislator may serve on the board of a private, nonprofit organization 
and, if so, whether the legislator may accept travel reimbursements and meals 
connected with service on the board from the private organization.
Summary of Opinion.
There is no general prohibition against a legislator serving on the board of a 
private entity. The legislator should be aware, however, of the restrictions in 
the Penal Code, Chapter 36 and the Government Code, Chapter 572.
EAO-229 (AOR-255).
Whether a state agency may hire a former agency employee as an independent 
contractor to perform the duties of a hearings examiner.
Summary of Opinion.
The revolving door prohibition in the Government Code, sec.572.054(b) does not 
prohibit a former agency employee from working for the agency as an independent 
contractor to perform the duties of a hearings examiner.
EAO-230 (AOR-257).
Whether certain transfers of political contributions constitute conversions to 
personal use.
Summary of Opinion.
The Election Code, Title 15 does not require that political contributions be 
kept in an account separate from other funds, or even that political 
contributions be kept in an account at all. If a candidate or officeholder 
maintains more than one account, a transfer of political contributions from one 
of those accounts to another is not an expenditure; nor does the transfer 
trigger any reporting requirements. Similarly, the withdrawal of cash from one 
of those accounts is not, by itself, an expenditure; nor does the withdrawal 
itself trigger any reporting requirements.
EAO-231 (AOR-258).
Reporting pledges of political contributions.
Summary of Opinion.
An agreement to transfer money in the future is a contribution. That type of 
contribution is referred to as a "pledge" in Ethics Commission rules and forms. 
A pledge accepted by a candidate or officeholder must be reported on the report 
covering the period in which the pledge is accepted, not when the actual 
transfer of money or goods is made. Once a pledge is reported, it is not 
necessary to report the contribution a second time when the transfer is made.
Questions on particular submissions should be addressed to the Texas Ethics 
Commission, P.O. Box 12070, Austin, Texas 78711-2070, (512) 463-5800.
Issued in Austin, Texas, on October 17, 1994.
TRD-9449714
Sarah Woelk
Director, Advisory Opinions
Texas Ethics Commission
Filed: October 18, 1994