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STATE OF LOUISIANA <br /> 4,OF.L�Uls DEPARTMENT OF STATE CIVIL SERVICE <br /> �,��r,,:, �E,�f'2 LOUISIANA BOARD OF ETHICS <br /> y ;,' ��"\ 9 P.O.BOX 4368 <br /> A � <br /> * �"� �� �. . u * BATON FiOUGE,LA 70821 <br /> `O�iioENc�� (225)219-5600 <br /> ••«o»-•' FAX:(225)381-7271 <br /> 1-800-842-6630 <br /> www.ethics.la.gov <br /> December 8, 2025 <br /> Austin Feldbaum <br /> Hazard Mitigation Administrator <br /> Office of Hazard Mitigation <br /> 1300 Perdido Street, 9th Floor <br /> New Orleans, LA 70112 <br /> Re: Docket No. 2025-667 <br /> Advisory Opinion <br /> Dear Mr. Feldbaum: <br /> Tlie Louisiana Board of Ethics, at its meeting on December 5, 2025, considered your request for <br /> an advisory opinion regarding whether the Code of Governmental Ethics (the "Code") prohibits a <br /> City of New Orleans employee from entering into a transaction with the City to receive fimding <br /> through FEMA's Plood Mitigation Assistance grant program. <br /> FACTS PROVIDED <br /> The Hazard Mitigation Oftice of the City of New Orleans (the "City") administers the City's <br /> participation in FEMA's Flood Mitigation Assistance ("FMA") grant program. The City, as a <br /> subrecipient of the State of Louisiana's award, distributes federal funding to eligible participating <br /> homeowners for architectural and construction activities as part of approved mitigation projects. <br /> The City enters into a Voluntary Elevation Agreement ("VEA") with each participating <br /> homeowner. The VEA includes the following provision: <br /> Section C. Prohibition of Financial Interest in Agreement. No elected ofticial <br /> or employee of the City shall have a financial interest, direct or indirect, in this <br /> Agreement. For purposes of this provision, a financial interest held by the spouse, <br /> child, or parent of any elected official or employee of the City shall be deemed to <br /> be a financial interest of such elected official or employee of the City. Any willfiil <br /> violation of this provision, with the expressed or implied knowledge of Property <br /> Owner(s), shall render this Agreement voidable by the City and shall entitle the <br /> City to recover, in addition to any other rights and remedies available to the City, <br /> all monies paid by the City to Property Owner(s) pursuant to this Agreement <br /> without regard to Property Owner(s)' otherwise satisfactory performance of the <br /> Agreement. <br /> Reade Nossaman, a homeowner who initially applied for the FMA grant program through the <br /> City's Hazard Mitigation Office in 2021 but was not selected, reapplied in 2022 after he became <br /> en�ployed by the New Orleans Aviation Board on September 6, 2022. The New Orleans Aviation <br /> Page 1 of 3 (BD 2025-667) <br /> AN EQUAL OPPORTUNITY EMPLOYER <br />