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.

Advisory Opinion Requests 
AOR-420. The Texas Ethics Commission has been asked to consider whether a 
limited liability company may make a political contribution in Texas if one of 
the owners of the limited liability company is a limited liability company owned 
in part by corporations.
AOR-421. The Texas Ethics Commission has been asked about the meaning of the 
term "executive head" for purposes of the financial disclosure requirements and 
other provisions of Government Code, Chapter 572. The request letter asks about 
the following situation: An independent regulatory agency's daily operations are 
overseen by a salaried, solitary gubernatorial appointee ("appointed officer"), 
who serves for a specific term pursuant to statute, and who offices and works at 
the agency's main office on a full time basis. Hired by the appointed officer, 
assisting in the management of the agency's operations, and reporting directly 
to the appointed officer are: "manager no. 1", serving as deputy or assistant to 
the appointed officer, and "manager no. 2". Manager no. 2 is in charge of 
administration and general counsel functions, and oversees accounting, 
purchasing, information resources, human resources, and legal services personnel 
for the agency. Budget personnel report directly to the appointed officer, who 
is the chief fiscal officer of the agency. Manager no. 1 manages several 
division directors whose divisions perform the "mission" work of the agency, 
which involves the exercise of independent judgment by licensed professionals in 
those divisions. 
AOR-422. The Texas Ethics Commission has been asked to consider several 
questions about the interpretation of Election Code sec.253.1611, a provision 
added to the Judicial Campaign Fairness Law in the 1997 legislative session.
Issued in Austin, Texas, on October 29, 1997.
TRD-9714372
Tom Harrison
Executive Director
Texas Ethics Commission Opinion
Filed: October 30, 1997