DEKALB COUNTY BOARD OF ETHICS

Formal Advisory Opinion: 2026-1

Request Date: January 5, 2026

1. Introduction

This Advisory Opinion is issued in response to a request by Edmund Wall, a principal of Piper Sandler & Co., for a Formal Advisory Opinion regarding whether his uncompensated service as Chair of the DeKalb County Pension Board creates an actual or apparent conflict of interest that would prohibit Piper Sandler from being considered for award under RFP 2025-048 (Financial Advisor Services).

1. Statement of Facts

• Edmund Wall serves as an uncompensated Chair of the DeKalb County Pension Board, a fiduciary body that acts collectively.
• Piper Sandler & Co. submitted a response to RFP 2025-048 for Financial Advisor Services to DeKalb County.
• The Financial Advisor role under RFP 2025-048 is advisory in nature; the Financial Advisor does not control pension assets.
• The Pension Board does not award the Financial Advisor contract under RFP 2025-048.
• On August 8, 2025, the Ethics Officer responded informally to a generalized “dual management” inquiry from procurement staff, stating the scenario “appears to be an actual conflict.”
• On November 12, 2025, the Ethics Officer clarified that her communications reflected informal guidance, not a formal Board determination, and advised that a formal advisory opinion could be sought.
• On December 22–23, 2025, the Ethics Officer again advised Edmund Wall that prior emails were informal Ethics Officer guidance and directed him to seek a formal opinion from the Board.
• There is no overlapping control between the Financial Advisor is an advisory role and Edmund Wall’s fiduciary Pension Board role.
• Any potential intersection of the two roles can be addressed through recusal and disclosure obligations.

III. Relevant Law

DeKalb County Code of Ethics, Section 22A-4(a):

“Public officials shall avoid participating in any official action in which they have a financial or personal interest that would impair their objectivity or independence of judgment.”

DeKalb County Code of Ethics, Section 22A-4(b):

“No official or employee shall engage in any activity or transaction that is prohibited by law now existing or hereafter enacted which is applicable to him or her by virtue of his or her being an official or employee of DeKalb County.”

Pension Ordinance conflict provisions (disclosure and abstention framework).

1. Conclusion

Accordingly, the Board of Ethics has concluded that no categorical conflict of interest exists prohibiting consideration of Piper Sandler & Co. under RFP 2025-048 solely by virtue of Edmund Wall’s uncompensated service as Chair of the DeKalb County Pension Board. Edmund Wall must comply with disclosure, confidentiality, and recusal obligations if a specific intersecting matter arises. The Board further clarifies that the Ethics Officer’s prior informal communications addressed a differently framed, generalized inquiry and do not control this formal advisory determination.