“The governor said his administration, Utah's delegation to Washington, D.C., and local Utah leaders weren't given any notice that a specific proposal was in the works, prompting frustration...”
Thursday, March 19, 2026
Tuesday, March 17, 2026
Re: GRAMA Notice of Appeal
From: GovernmentRecordsOffice DGO...
Subject: Re: GRAMA Notice of Appeal – Puente v. GOEO (IAA Grant)
Date: March 17, 2026 at 12:01:14 PM MDT
To: Joe Puente..., [GOEO Director], [Agency Counsel]
Cc: [State Auditor], [Marcus Hardy], [GOEO Records Officer], [Jon Pierpont], [Adam Duncan]
Good afternoon,
I've attached two letters that schedule an appeal hearing. If you have any questions, please let me know. I encourage the parties to work with the Government Records Ombudsman to resolve as much of the appeal as possible, especially if you are on a tight deadline. Monica Minaya's contact information is in the attachment.
Regards,
~Rebekkah
Rebekkah Shaw
Utah Department of Government Operations
Division of Archives and Records Service
Government Records Office...
Monday, March 16, 2026
Revised GRAMA Notice of Appeal
To: [Lonny Pehrson, Director Government Records Office]
Cc: [GOEO Director, Et. Al.]
Director Pehrson,
Please accept this email and the attached documents as my revised GRAMA Notice of Appeal to the Director of the Government Records Office under Utah Code §§ 63G‑2‑402 and 63G‑2‑403, regarding the March 3, 2026, decision of the Governor’s Office of Economic Opportunity (GOEO) denying my records request related to an Industrial Assistance Account grant.
Attached are the following documents:
Appeal_Notice_GRO_Director_GOEO_Revised_20260316.pdfAppEx_01_20260303_GRAMA_AppealDenial.pdfAppEx_02_20260108_GOEO_Boar..JAN26_PublicNotice_1372663.pdfAppEx_03_20260210_GOEO_Board_8JAN26_Minutes_1389373.pdfAppEx_04_20260130_GOEO_Boar..o_to_Text_generated_Transcript.pdfAppEx_05_20260305_ConceptVsMotion.pdfAppEx_06_20260209_GRAMA_Request_IAA.pdfAppEx_07_20260108_AllMaterials_GOEOBoard_-_1.8.26_1372663.pdf AppEx_08_20250523_Articles_Inc..ation_NUOVO_FILM_FEST_INC.pdfAppEx_09_20260210_GRAMA_Denial_PF_PIO.pdfAppEx_10_20260218_GRAMA_Appeal.pdfAppEx_11_20260302_GRAMA_AppealFollowUp.pdfAppEx_12_20260210-20260305_GOEO_Meeting_V_Minutes.pdfAppEx_13_20260302_Response_GRAMAAppealFollowup.pdfAppEx_14_20250325_SB02_Sec1_Subsec1a_It22.pdfAppEx_15_20260128_UTStateAuditor_Info_Case_016517.pdfAppEx_16_20260218_GRAMAAppealRecieved.pdfAppEx_17_20260220_UFA_GOEO_EthicsConductEvaluation.pdf
I am simultaneously serving this Notice and all exhibits upon GOEO and the Attorney General’s Office by copying them on this email, consistent with Utah Code § 63G‑2‑403.
Please confirm receipt of this appeal and all attachments—I never received confirmation of my previous submission.
Sincerely,
Joseph L. Puente…
Salt Lake City…
* * *
Subject: Re: Request for written clarification of legislative intent regarding S.B. 2 lapse provision and GOEO authority
Date: March 16, 2026 at 8:37:59 AM MDT
To: Steven Allred (Deputy Fiscal Analyst)Cc: [Sen. Jerry W. Stevenson (Executive Appropriations Chair), Rep. Val L. Peterson (Executive Appropriations Chair)][Christine R. Gilbert (Drafting Attorney/Deputy General Counsel),(State Auditor)
Mr. Allred,
Thank you for the prompt response to my previous email. However, my original questions remain unanswered. As stated previously:
I respectfully request a written response addressing:
- Whether, in your understanding... S.B. 2 permits GOEO to treat conditional Sundance funds as available if the condition precedent was not met.
- Whether a lapse provision in S.B. 2 may lawfully be ignored, bypassed, or reinterpreted by GOEO in the administration of those funds.
- If such authority is believed to exist, the specific statutory text or legal basis supporting that conclusion.
- Whether GOEO’s present course of action is consistent with the legislative intent underlying the appropriation and lapse language adopted in S.B. 2.
I would appreciate a direct written response stating whether, in your view, the Legislature intended these funds to lapse if the statutory condition was not satisfied.
Respectfully,
Joseph L. Puente
Thursday, March 12, 2026
RE: Clarification Request
Subject: RE: Request for written clarification of legislative intent regarding S.B. 2 lapse provision and GOEO authority
From: Steven Allred [(Deputy Fiscal Analyst)]
Date: March 12, 2026 at 11:01:29 AM MDT
To: [Sen. Jerry W. Stevenson (Executive Appropriations Chair), Rep. Val L. Peterson (Executive Appropriations Chair)]
Cc: [Christine R. Gilbert (Drafting Attorney/Deputy General Counsel),(State Auditor),(State Agency Counsel Division, Utah Attorney General's Office)]
Mr. Puente,
The Legislature rescinded funding for the Sundance Film Festival in "Current Fiscal Year Supplemental Appropriations" (Senate Bill 3, 2026 General Session), items 27 and 194.
* * *
“...this item takes back the appropriated funds.”
Just to be clear, the funds did not “come back,” as was stated on January 8, but the legislature has decided to take them back.
How we got here...
Originally published on Puente’s Perspective.
“This is NOT about ‘A.I.’ or the local film industry.”
When I learned about the approval of a $2 million grant for “Nuovo Film Festival, Inc.,” two things stood out to me:
The lengths to which the GOEO went to hide what they were doing.
The completely redundant goals of the project
When articles started to appear in the local media toward the end of January, most of the attention was focused on “A.I.” hype, which members of the local film community latched onto with understandable frustration. Leaders of existing film-focused nonprofits—myself included—coordinated and reached out to the Nuovo “board” requesting a meeting. As of this post, to my knowledge, nothing has been scheduled.
The way it’s been framed in the press, this $2 million grant looks like a done deal. Some of my colleagues are already trying to make their peace with it. I commented on a post in the Utah Filmmakers™ Facebook group:
While most appear to have taken a “wait and see” position, I’ve been trying to find out what’s really going on. When headlines include phrases like “...Initiative gets $2 million from state,” “Utah invests $2 million in an AI-driven film ecosystem,” and “Utah invests $2M in AI cinema,” it creates the impression that this is something that has already happened. These are “news” articles, after all. Of course, headlines are often clickbait—hyperbole and oversimplification to get more ad impressions. Then we read in the articles themselves that the grant has only been “approved” or “...in a standard detail-gathering phase before the grant award is finalized.”
Some articles refer to the GOEO specifically as the agency behind the grant, others treat it as something incidental, as if it may or may not have anything to do with the grant, or as one local writer phrased it, “Working within the context of the Governor’s Office of Economic Opportunity…” (emphasis added, also, F#*%¡&’ really!?!) There are references to “planners,” but no one is identified by name, nor is anyone directly quoted.
As far as I could tell, only one journalist appears to have even made an effort to verify what is still, as far as the press is concerned, just an industry rumor, having reached out to the GOEO and reporting “... board members did not respond to a request for comment.”
I’m not a journalist, but I used to moonlight as a stringer for a rural weekly newspaper, and I’ve acquired a few skills in finding public information for routine due diligence.
While there is nothing on the GOEO’s official website discussing or even referring to a $2 million grant, a diligent search on the Public Notice Website for the state of Utah can yield the following results:
“1389373.docx” appears to be an automatically generated filename for the official minutes of the January 8 GOEO Board meeting—posted on February 10 and accompanying the agenda for the following meeting.
This document is the only written confirmation—but confirmation, nevertheless—that the GOEO Board unanimously approved a $2 million grant for “Nuovo Film Festival, Inc.”
Prior to February 10, the only way anyone could have learned about it would have been with a similar search yielding similar results:
“1373837.m4a” is the 50+minute audio recording of the January 8 GOEO Board meeting. The proposal, followed by a unanimous vote of approval, takes up about 12 minutes of the recording, starting around 32 minutes in.
Unlike the other items that were discussed, this was the only item lacking any information of substance on the written agenda—available on the same web page on January 6:
Perhaps none of the Board members felt the need to comment on the news since it’s all there in the official record. Short of a photo-op with a giant novelty check being handed to the grantee, it certainly seems like a done deal.
Still, I decided to ask for more details about the approval of this grant, since the only publicly available written information amounts to about a page and a half of text. I submitted a formal GRAMA Records Request, which the GOEO’s Records Officer denied, claiming—among other excuses, “...no decision has been made regarding this funding…”
This made no sense to me, so I appealed the denial to GOEO’s Executive Director, who also denied it, adding that the January 8 meeting “...concluded with the Board's recommendation that GOEO support the concept.” A statement that does not square with the verifiable facts in their own official records.
The January 8 agenda said “The Board will vote to approve one IAA grant.” Not a “concept.”
The official minutes of the meeting confirmed what was clearly understood on the audio recording from January 8, that the Board “...recommends Nuovo Film Festival Incorporated (NFI) for an Industrial Assistance Account grant of $2,000,000…” and the motion “...passed with unanimous consent.”
I’ve been told that I have an overdeveloped sense of fairness, and I’ve been known to be trusting of others, to a fault. I will take someone at the word if I haven’t been given a reason not to. So, if I find out someone has lied to me, after the fact, I might be a little more bothered by it than most.
I also have a very low tolerance for people who think they can get away with feeding me an obvious line of bullshit, and God help them if they lie to me when I already know the truth.
Wednesday, March 11, 2026
Request for written clarification of legislative intent (email)
Subject: Request for written clarification of legislative intent regarding S.B. 2 lapse provision and GOEO authority
To: [Sen. Jerry W. Stevenson (Executive Appropriations Chair), Rep. Val L. Peterson (Executive Appropriations Chair)]
Cc: [Christine R. Gilbert (Drafting Attorney/Deputy General Counsel), Steven Allred (Deputy Fiscal Analyst),(State Auditor),(State Agency Counsel Division, Utah Attorney General's Office)]
Dear Senator Stevenson and Representative Peterson:
The question presented is straightforward: if the Legislature made the availability of the Sundance funding contingent on a stated condition, and that condition was not satisfied, does GOEO have any lawful authority to reappropriate, retain, obligate, expend, or otherwise preserve access to those funds? Relatedly, does GOEO have any authority to disregard, evade, or administratively nullify a lapse provision enacted by the Legislature?
My concern is that GOEO’s conduct reflects more than a mere interpretive disagreement. The available record suggests an effort to proceed without a sufficiently transparent written basis, coupled with approval of minutes that appear too vague and incomplete to permit meaningful public scrutiny of what the board actually did. In a matter involving conditional appropriations and lapse language, that lack of clarity directly undermines legislative control over public funds and impairs the public’s ability to assess whether the executive branch is acting within lawful bounds.
As reflected in the materials collected at https://goeo.joepuente.org, the dispute concerns not only the underlying availability of funds, but also the integrity of the public record used to justify GOEO’s position. Those materials include the timeline of events, GRAMA appeal materials, transcript-to-minutes analysis, and supporting documents addressing whether GOEO’s later characterization of board action is supported by the actual record.
I raise this issue because I am a filmmaker, an advocate for Utah’s film industry and nonprofit sector, and a citizen deeply committed to ethical and representative government. I have also devoted five years of my life to military service, and I take seriously any indication that legislatively imposed limits on appropriated funds may be treated as optional by an executive office.
I am copying Christine R. Gilbert, as the drafting attorney, and Steven M. Allred, as the fiscal analyst, because this issue goes directly to statutory construction, appropriations control, and the intended legal effect of the condition and lapse language enacted in S.B. 2. Their inclusion is meant to ensure that any response is informed by the bill’s drafting context and fiscal structure, and to clarify whether GOEO’s present position is consistent with the legislation as written and understood at the time of enactment.
Accordingly, I respectfully request a written response addressing:
Whether, in your understanding as the bill’s sponsors, S.B. 2 permits GOEO to treat conditional Sundance funds as available if the condition precedent was not met.
Whether a lapse provision in S.B. 2 may lawfully be ignored, bypassed, or reinterpreted by GOEO in the administration of those funds.
If such authority is believed to exist, the specific statutory text or legal basis supporting that conclusion.
Whether GOEO’s present course of action is consistent with the legislative intent underlying the appropriation and lapse language adopted in S.B. 2.
I would appreciate a direct written response stating whether, in your view, the Legislature intended these funds to lapse if the statutory condition was not satisfied.
Respectfully,
(signed)
Joseph L. Puente
Salt Lake City, Utah
Salt Lake City, Utah
(attachment: [20260311_SB2SponsorsGOEO.pdf])
Thursday, March 5, 2026
GRAMA Notice of Appeal submitted to the State Records Committee
Subject: GRAMA Notice of Appeal – Puente v. GOEO (IAA Grant)
Date: March 5, 2026 at 2:11:06 PM MST
Director Pehrson,
Please accept this email and the attached documents as my GRAMA Notice of Appeal to the State Records Committee under Utah Code §§ 63G‑2‑402 and 63G‑2‑403, regarding the March 3, 2026 decision of the Governor’s Office of Economic Opportunity (GOEO) denying my records request related to an Industrial Assistance Account grant.
Attached are the following documents:
Appeal_Notice_SRC_GRAMA_GOEO_20260305.pdf
AppEx_01_20260303_GRAMA_AppealDenial.pdf
AppEx_02_20260108_GOEO_Boar..JAN26_PublicNotice_1372663.pdf
AppEx_03_20260210_GOEO_Board_8JAN26_Minutes_1389373.pdf
AppEx_04_20260130_GOEO_Boar..o_to_Text_generated_Transcript.pdf
AppEx_05_20260305_ConceptVsMotion.pdf
AppEx_06_20260209_GRAMA_Request_IAA.pdf
AppEx_07_20260108_AllMaterials_GOEOBoard_-_1.8.26_1372663.pdf AppEx_08_20250523_Articles_Inc..ation_NUOVO_FILM_FEST_INC.pdf
AppEx_09_20260210_GRAMA_Denial_PF_PIO.pdf
AppEx_10_20260218_GRAMA_Appeal.pdf
AppEx_11_20260302_GRAMA_AppealFollowUp.pdf
AppEx_12_20260210-20260305_GOEO_Meeting_V_Minutes.pdf
AppEx_13_20260302_Response_GRAMAAppealFollowup.pdf
AppEx_14_20250325_SB02_Sec1_Subsec1a_It22.pdf
AppEx_15_20260128_UTStateAuditor_Info_Case_016517.pdf
AppEx_16_20260218_GRAMAAppealRecieved.pdf
AppEx_17_20260220_UFA_GOEO_EthicsConductEvaluation.pdf
I am simultaneously serving this Notice and all exhibits upon GOEO and the Attorney General’s Office by copying them on this email, consistent with Utah Code § 63G‑2‑403.
Please confirm receipt of this appeal and all attachments.
Sincerely,
Joseph L. Puente…
Salt Lake City…
Tuesday, March 3, 2026
Fact Check on $2M grant (email to press)
Subject: (2 sources) Fact Check on $2M grant for Utah nonprofit
Date: March 3, 2026 at 6:51 PM
Local press coverage about the future of Utah’s “film ecosystem” and the possible role that “A.I.” might have to play in it, leave readers with a distinct impression that a $2M grant to a nonprofit organization nobody has heard of was a done deal. Especially when the headlines include phrasing like, “...Initiative gets $2 million from state,” “Utah invests $2 million in an AI-driven film ecosystem,” and “Utah invests $2M in AI cinema.”
Obviously, this is clickbait for those whose interests in filmmaking and machine learning overlap. It becomes problematic only when the stories themselves make assertions such as “Nuovo Film Festival, Inc... has received $2 million...”
The articles state that the grant takes the form of an Industrial Assistance Account, so references were also made to the Utah Governor’s Office of Economic Opportunity (GOEO), though there were no press releases on the topic and no quotes from GOEO staff. As far as I can tell, only one journalist—not from Utah and with established bona fides, writing for an industry publication—appears to have at least made an effort, publication—appears to have at least made an effort, including in their coverage “... board members did not respond to a request for comment.”
I had to jump through some bureaucratic hoops to obtain the two attached letters. The first is from Patrick Fitzgibbon, the GOEO Public Information Officer, denying a GRAMA Records Request regarding a grant for “Nuovo Film Festival, Inc.” worth $2M, in which they stated the following:
“...a formal grant application has not yet been generated or submitted…no decision has been made regarding this funding, the grant has not been awarded, and no award letters, scoring sheets, or executed contracts currently exist.”
Patrick Fitzgibbon
The second letter is an affirmation of that denial from Jefferson Moss, the Executive Director of the GOEO, making similar citations but also addressing recent press coverage:
“...I note that your February 18 appeal letter referenced press coverage suggesting that GOEO has already funded the Nuovo Film Festival. I understand how these reports could lead to that conclusion; however, I can assure you that those reports do not reflect the current status of this project, and no funding has been approved.
Jefferson Moss, GOEO Director
Do news outlets issue retractions anymore, or do they just update their web pages and hope no one goes back to check whether they ever got it right?
Honestly, I’m less concerned about the current state of journalism than I am about government cronyism and potential fraud in the nonprofit sector. I know that Nuovo Film Festival, Inc. is technically a nonprofit on paper—meeting a bare minimum standard to qualify for legal existence—but so do a parade of “Talent Agencies” in the Beehive state scamming young models with “acting classes” and “professional photos” with little more than a Facebook page and a DBA (usually in that order).
[attachments]
https://www.joepuente.org/2026/02/ethics.html
* * *
From: Rémi Rostan…studiolhc...Subject: Re: (2 sources) Fact Check on $2M grant for Utah nonprofitDate: March 3, 2026 at 10:48:40 PM MST
Hello Joe,It's been corrected.Thank you,R
GRAMA Appeal denial letter
From: Patrick Fitzgibbon...
Subject: GRAMA Appeal Response
Date: March 3, 2026 at 3:30:00 PM MST
Mr. Puente,
Please see the attached response to your GRAMA appeal.
--
Patrick Fitzgibbon
Public Information and Communications Manager...
“...While Scott Anderson presented a new concept to support the film industry to the GOEO Board on January 8, 2026, the presentation was intended to promote public awareness and transparency about a preliminary idea. That presentation concluded with the Board's recommendation that GOEO support the concept. To be clear, the GOEO Board does not approve this type of grant — it only provided its recommendation. This nuance has been underreported in media coverage of this subject...
“I note that your February 18 appeal letter referenced press coverage suggesting that GOEO has already funded the Nuovo Film Festival. I understand how these reports could lead to that conclusion; however, I can assure you that those reports do not reflect the current status of this project, and no funding has been approved.” (emphases added)
(signed)Jefferson MossGOEO Director
Monday, March 2, 2026
GRAMMA Appeal Follow-up
To: GOEO Director Jefferson Moss, et. al.
Subject: Follow‑up on Expedited GRAMA Appeal – Denial Dated 2/10/26
Date: March 2, 2026 at 10:32:35 AM MST
Subject: Follow‑up on Expedited GRAMA Appeal – Denial Dated 2/10/26
Date: March 2, 2026 at 10:32:35 AM MST
Dear Director Moss,
I am writing to follow up on my appeal of the denial of my expedited GRAMA records request, which is dated February 10, 2026, but was not actually sent to or received by me until February 17, 2026.
Because I did not receive the denial until February 17—ten (10) full calendars days after the denial was apparently written—that is the date on which I first had notice of the denial and from which I calculated my appeal timeline. I submitted my appeal and requested expedited consideration on February 18, 2026.
Utah’s GRAMA statutes require that governmental entities respond “as soon as reasonably possible” and within the applicable statutory time limits, and to provide notice if any extraordinary circumstances are being claimed that would extend those limits. As of today, March 2, 2026, I have not received:
- A decision on my request for expedited handling of the appeal;
- A substantive written decision on the appeal itself; or
- Any notice that extraordinary circumstances are being claimed, along with an estimated date for a decision.
In light of the elapsed time since my February 18 appeal and request for expedition, I am requesting:
- Written confirmation of the current status of my appeal and my request for expedited consideration; and
- Either an immediate written decision on the appeal or clear written notice of any statutory basis you are relying on to extend the response time, including a specific expected decision date.
If I do not receive a written response or decision by the close of business today, March 2, 2026, I will treat the lack of response as a denial and proceed to the next level of appeal and any other remedies available under Utah statutes.
If you believe a response has already been sent, please re‑send it, as I have not received it.
Thank you for your prompt attention to this matter.
Sincerely,
(Signed)
Joseph L. Puente
Salt Lake City, Utah
* * *
Email reply From: Patrick Fitzgibbon…
Subject: Re: Follow‑up on Expedited GRAMA Appeal…
Date: March 2, 2026 at 4:04 PM,
Mr. Puente,
When you submitted your appeal to Director Moss on February 18, I appreciated your copying all vested parties on that correspondence.
Our counsel sent you an acknowledgement of receipt that same day.
Regarding the timeline for a decision, we are following the standard review period outlined in code, which sets the deadline for a formal response this Wednesday, March 4.
Please keep an eye on your inbox at that time.
* * *
From: Joseph L. Puente…
Subject: Re: Follow‑up on Expedited GRAMA Appeal – Denial Dated 2/10/26
Date: March 2, 2026 at 4:05:24 PM MST
To: Patrick Fitzgibbon…
Subject: Re: Follow‑up on Expedited GRAMA Appeal – Denial Dated 2/10/26
Date: March 2, 2026 at 4:05:24 PM MST
To: Patrick Fitzgibbon…
Thank you. I appreciate the update.
Saturday, February 21, 2026
Additional press coverage
“How Utah Is Trying to Rewire Film Production Economics With a $2 Million AI Bet”
Article by Streaming Wars Staff
* * *
LinkedIn Post by Eugenio Fierro
* * *
LinkedIn Post by LHC
"The state grants $2 million to the Nuovo Film Festival to launch an AI-centered ecosystem: creation lab, AI stage, expanded incentives, and local training. Ambition: attract talent and studios, reduce production costs, and position Utah as a next-generation film hub."
* * *
Monday, February 23, 2026
“With Sundance gone, Utah bets on AI film festival as a force for 'social change'”
Article by Andrew Chapados
Friday, February 20, 2026
Ethics & Conduct Evaluation (facsimile)
Originally published on the Utah Filmmakers™ Association's Disclosure website on January 20, 2026.
Current Revision: 2026-02-23
Entity: Governor’s Office of Economic Opportunity (GOEO)
Public Body: Business Development Board
Subject of concern: Grant approval process
Date of incident: January 8, 2016
Actions taken by the Business Development Board of the Utah Governor’s Office of Economic Opportunity (hereinafter, “GOEO” inclusive) in regard to its handling of a proposed Industrial Assistance Account (IAA) grant worth two million dollars ($2,000,000 USD) appear to conflict with multiple specific standards across all sections of the Utah Filmmakers™ Ethics Code, raising significant concerns with UFA™ Leadership. The GOEO is thus being evaluated using the Enumerated Version of the UFA™ Code of Ethics & Conduct.
While it is acknowledged that the GOEO is not formally affiliated with Utah Filmmakers™, it is the state government agency that oversees the Utah Film Commission, which is a Utah Filmmakers™ Associate Organization. This fact is noted with assurance that the findings of this evaluation will have no effect on their participation in the Associate Program, since—to the best of our knowledge—the Film Commission was unaware of the GOEO’s actions.
The results of this evaluation are intended for informational purposes only.
Utah Filmmakers™ Ethics Code – Relevant Standards
The following outlines the expectations of the Utah Filmmakers™ Association regarding the decorum of its Corporate Principals, Leadership, Associates, and Members toward colleagues, employees, contractors, clients, customers, and the community—as well as participants in any official, associated, and/or affiliated programs, forums, activities, and events. These standards are based on the organization’s core values of Professionalism, Integrity, and Respect.
1.0 Professionalism
1.1 Demonstrating competence, accountability, and productivity
Standard: Demonstrating competence, accountability, and productivity in one’s occupation to the best of their abilities.
Analysis – Competence, accountability, productivity: Approving a large, one‑time IAA grant for a new nonprofit organization with no track record, no public competitive process, and minimal documented vetting of economic‑development merit suggests weak due diligence and risk assessment, which conflicts with the expectation of competent, accountable decision‑making described in §1.1.
1.2 Acknowledging limitations and embracing learning
Standard: Acknowledging one’s own limitations and embracing opportunities for learning and development, either on the job or via educational material or training.
Analysis – Acknowledging limitations and learning: GOEO discussion—focused largely on staff assurances rather than hard evidence, comparable proposals, or industry benchmarks—indicates a limited understanding of the film industry and little‑to‑no effort to consult independent expertise, contrary to the standard described in §1.2 of embracing learning and recognizing one’s limits.
1.3 Accepting responsibility for one’s actions
Standard: Accepting responsibility for one’s actions. Owning difficult decisions and mistakes and being accountable for them—making necessary corrections where possible and/or relinquishing one’s stewardship over a particular program, project, or task, if necessary.
Analysis – Accepting responsibility and making corrections: Once public concerns were raised about process irregularities (lack of notice to other organizations, unclear criteria, potential favoritism), there is no visible indication that the GOEO revisited or corrected the decision, held a follow‑up review, or publicly accounted for its process, which conflicts with the standard described in §1.3 to own difficult decisions and make necessary corrections.
1.4 Embracing the collaborative nature of team projects
Standard: Embracing the collaborative nature of team projects, with willingness to assist others and to seek out and accept assistance from others with more knowledge and experience.
Analysis – Collaboration and seeking assistance: The GOEO did not appear to formally consult the Utah Film Commission, local film‑focused nonprofit organizations, or broader film‑industry stakeholders in a transparent way, despite the grant’s direct impact on that ecosystem, undermining the expectation described in §1.4 to embrace collaboration and seek assistance from those with more experience in the subject area.
1.5 Delegating responsibility and creating opportunities
Standard: Being able to delegate responsibility and give others opportunities to learn, grow, and excel.
Analysis – Delegating and creating opportunities: By unanimously approving the direction of a substantial, ad‑hoc grant to a single new entity instead of designing or using a structured, competitive program that could allow multiple Utah‑based film‑focused organizations to apply, the GOEO effectively concentrated opportunity rather than delegating and creating broader pathways for others to learn and grow, contrary to the standard described in §1.5.
1.6 Recognizing and avoiding conflicts of interest
Standard: Recognizing and avoiding conflicts of interest which may occur whenever one’s pursuits in a particular subject lead one to actions, activities, or relationships that undermine—or appear to undermine—one’s ability to make honest and impartial choices when performing one’s duties and harm the collective interests of a project or program.
Analysis – Avoiding conflicts of interest and appearances: The decision process lacks clear, documented conflict‑of‑interest screening for GOEO staff with any personal, political, or business ties to the proposed grant recipient, its principals, or associated venues; proceeding without such clarity creates at least an appearance of conflict of interest, which directly contradicts §1.6.
1.6.1 Use of position, resources, or insider opportunities
Standard: This includes—but is not limited to—situations like using one’s position of authority, exploiting group resources for personal gain, or taking for oneself opportunities discoverable only through one’s position.
Analysis – Use of position, resources, or insider opportunities: Approving a proposal to award a substantial IAA grant to a single new nonprofit organization—through a questionable process effectively hidden from similar organizations—creates the impression that access came from insider relationships and state resources rather than an open field of opportunity, aligning with the very behavior §1.6.1 warns against.
2.0 Integrity
2.1 Ensuring objectivity, fairness, and non‑exploitation
Standard: Ensuring that one is objective, fair, and does not exploit others, their hard work, or their mistakes.
Analysis – Objectivity, fairness, and not exploiting others: Favoring one nascent organization for a major grant, without a transparent comparison with established organizations that provide similar or greater economic and cultural benefits, undermines objectivity and fairness and implicitly exploits the work of those existing organizations that were never given equal access to this opportunity, as described in §2.1.
2.2 Giving everyone an equal opportunity to speak up
Standard: Giving everyone an equal opportunity to speak up when someone else doesn’t.
Analysis – Equal opportunity to speak up: Other film‑focused entities, nonprofit organizations, and film‑industry stakeholders were not meaningfully engaged or given a platform to provide input before the GOEO voted to approve the grant; this conflicts with the standard to give everyone an equal opportunity to speak up when decisions affect them, as described in §2.2.
2.3 Being just toward organizations and businesses
Standard: Being just toward colleagues, fellow organizations, and businesses.
Analysis – Being just toward organizations and businesses: Granting a large, one‑off subsidy to a single new private entity, without a transparent policy foundation or even‑handed access to comparable support, reflects preferential treatment rather than justice toward “fellow organizations and businesses,” breaching §2.3.
2.4 Avoiding unethical behavior and practices
Standard: Avoiding unethical behavior and/or practices to the best of one’s ability.
Analysis – Avoiding unethical practices: While explicit illegality has not been established, the opaque, secretive, non‑competitive approach to deploying public funds is a classic example of questionable practice that §2.4 counsels against, particularly given the potential for perceived favoritism, disregard of public trust, and misuse of taxpayer funds.
2.5 Honesty and transparency when actions impact others
Standard: Being honest and transparent when one’s actions impact others (e.g., decisions affecting the livelihoods of employees and/or contractors).
Analysis – Honesty and transparency when actions impact others: The GOEO did not clearly articulate to the broader community why the proposed grant recipient was selected, how it met the formal criteria, or how comparable opportunities would be made available to others; this lack of proactive transparency about a decision with material impact on existing organizations and vendors directly conflicts with §2.5.
2.6 Prohibition of malicious, deceitful, or petty conduct
Standard: Malicious, deceitful, or petty conduct will not be tolerated.
Analysis – Prohibition of malicious, deceitful, or petty conduct: Even if overt malice is not established, the GOEO’s handling of the grant disclosure evidences deceitful behavior inconsistent with §2.6. Pertinent details of the proposal—including the $2 million cost, the nature of the project, and the intended recipient—were not summarized in the agenda and could only be discovered by members of the public willing to listen to the entirety of a 50‑plus‑minute audio recording of the January 8 board meeting, during which a substantial portion of the discussion focused on this grant despite its bare‑bones description on the published agenda. Unlike other decisions made the same day, GOEO issued no press release about this award, and the grant was not reported in the press until January 22, nearly two weeks later. Taken together, these choices suggest an intentional effort to keep the most salient facts technically public but practically obscure, which falls squarely within the kind of deceitful and petty conduct that §2.6 rejects.
2.7 Misrepresentation in professional interactions
Standard: If one is discovered to be lying or misrepresenting themselves in their professional interactions, they may be disassociated from the organization and/or removed from official forums.
Analysis – Misrepresentation in professional interactions: If, as reported, the opportunity was publicly framed as a neutral economic‑development initiative while privately functioning as a bespoke deal for one favored organization, that constitutes a form of misrepresentation about the nature and accessibility of the grant, violating §2.7’s prohibition on misrepresenting oneself or one’s actions.
2.8 Adhering to the highest ethical standards of business conduct
Standard: Adhering to the highest ethical standards of business conduct and accepting responsibility for acquiring sufficient knowledge of—and making a conscious effort to comply with—all federal, state, county, and municipal laws, regulations, and best practices pertaining to the environment, commerce, industry, safety, labor, discrimination, and privacy, in order to recognize potential risks and to know when to seek legal advice.
Analysis – State laws (SB 2) and regulations (IAA restrictions): Of particular concern under §2.8 is the GOEO’s treatment and description of the underlying funding source, which shows a failure to respect both the letter and intent of S.B. 2 (the 2025 New Fiscal Year Supplemental Appropriations Act) and basic norms of public finance. During the meeting, it was stated that the $2 million IAA grant would use money “previously allocated to Sundance” and that, with Sundance leaving Utah, that money had “come back.” In reality, S.B. 2 appropriated $3.5 million for the Sundance Institute on the express condition that Sundance remain in Utah and directed the GOEO not to disburse those funds and to allow them to lapse if Sundance chose to leave the state. Once Sundance announced its relocation and confirmed that future festivals would be held outside Utah, those contingent dollars were required to lapse, not to be repurposed at the GOEO’s convenience. By approving a $2 million award described as using money “previously allocated to Sundance,” and by characterizing those funds as having “come back” rather than as an appropriation that was never meant to be deployed if the condition failed, the GOEO effectively treated restricted, contingent funds as discretionary money. This conflicts directly with §2.8’s requirement to acquire sufficient knowledge of governing laws and regulations, to honor explicit appropriations language and lapse provisions, and to seek fresh, transparent legislative authorization before diverting condition‑bound, one‑time funds for an unrelated purpose.
3.0 Respect
3.1 Default respect for people and institutions
Standard: Being respectful of people, property, institutions, and the environment should be by default—no one should demand that respect be “earned.”
Analysis – Default respect for people and institutions: By bypassing the established film ecosystem and its institutions when designing or approving the deployment of a major grant to an unknown, unproven nonprofit organization, the GOEO signaled limited respect for Utah’s existing nonprofit organizations, film industry professionals, and community‑based efforts that have operated for decades without such bespoke support.
3.2 Inclusive, polite, patient, and courteous conduct
Standard: Being respectful means being inclusive, polite, patient, understanding, and courteous.
Analysis – Inclusive, polite, patient, and courteous conduct: Interactions with the GOEO and its staff, described by stakeholders as dismissive of concerns about fairness and process, indicate a failure to engage in inclusive, courteous communication, particularly toward those questioning the decision.
3.3 Respecting rights to opinions and diversity of views
Standard: One must respect the rights of others to privacy, personal space, and to have and express their own opinions, and recognize that there is strength in diversity.
Analysis – Respecting rights to opinions and diversity of views: Nothing undermines respect for others’ right to have and express differing opinions on the proper use of public funds like minimizing or taking steps to prevent public disclosure.
3.4 Valuing different perspectives for problem‑solving
Standard: Understand that different perspectives on issues can be valuable for solving problems and generating new ideas.
Analysis – Valuing different perspectives for problem‑solving: The GOEO did not appear to seek out, let alone use, critical feedback from filmmakers, film‑related nonprofit executives, festival organizers, and film‑industry advocates as an opportunity to refine its approach, failing to meet the expectation described in §3.4 to treat different perspectives as valuable inputs for solving policy and process problems.
3.5 Resolving disagreements constructively
Standard: When disagreements occur—and they will—it is imperative that every effort is made to identify the underlying causes immediately and try to resolve them constructively.
Analysis – Resolving disagreements constructively: The GOEO’s failure to seek input from film‑industry experts ensured that no disagreements would be voiced, to say nothing of identifying their underlying causes and attempting constructive resolution.
3.6 Avoiding exclusionary behavior
Standard: Any kind of violence, victimization, discriminatory or exclusionary behavior, or harassment toward others for any reason will not be tolerated.
Analysis – Avoiding exclusionary behavior: Designing or approving a grant pathway that is effectively accessible only to one organization—without open notice or a replicable path for similarly situated organizations—constitutes exclusionary behavior in the economic‑opportunity sense, contrary to §3.6.
3.7 Avoiding uncomfortable or threatening environments
Standard: An environment where people feel uncomfortable or threatened is neither productive nor creative.
Analysis – Avoiding uncomfortable or threatening environments: When state‑backed favoritism is perceived, other organizations, festivals, vendors, and film workers understandably feel their livelihoods and opportunities are at risk; this fosters the kind of uncomfortable, insecure environment that §3.7 warns against as neither productive nor creative.
Evaluation Findings
When mapped against the enumerated UFA™ Code of Ethics & Conduct, the GOEO’s approach to the IAA grant shows systemic conflicts with core expectations of Professionalism (§§1.1–1.6.1), Integrity (§§2.1–2.8), and Respect (§§3.1–3.7), centering on a lack of transparent criteria, absence of equal opportunity, and failure to engage and protect the broader film community affected by its decision.
Of all these concerns, the board’s handling of the underlying SB 2 appropriation stands out as the most alarming breach of the Ethics Code: by treating condition‑bound, contingent funds as discretionary money that had simply “come back,” and by repurposing those dollars without updated, explicit legislative authorization, the GOEO departed not only from the spirit of §2.8 but from basic, widely understood norms of lawful and transparent stewardship of public funds.
Framed against the UFA™ Ethics Code, this situation justifies treating both the GOEO and the nonprofit organization for which it approved a grant as ineligible for any form of endorsement by or association with the Utah Filmmakers™ organization. In no uncertain terms, the pattern of behavior—culminating in the decision to describe and deploy SB 2’s lapsed, contingent appropriation as if it were an unrestricted pool of discretionary money—disqualifies both the GOEO and the proposed grant recipient from participating in any UFA™ project or program and, due to such a profound and public ethical failure, must not be held out—formally or informally—as endorsed resources or associated in any way, shape, or form with the Utah Filmmakers™ Association.
1.0 Organizational trust and positions of responsibility
A prior internal case showed that when an official UFA™ representative, while occupying a position of trust and public recognition, violated core ethical expectations, the consequences were dismissal from their positions of responsibility and revocation of credentials, guided by legal counsel and a structured evaluation under this same Ethics Code. That precedent establishes that occupying any role that influences how Utah filmmakers view “legitimate” resources requires a high bar of Professionalism, Integrity, and Respect, not just the absence of criminal conduct.
By analogy, the GOEO held a similar position of practical and public trust with respect to Utah’s creative economy, effectively signaling to the community at large—in a manner that was technically public but practically obscure—that the proposed IAA grant recipient was a vetted, high‑value resource by recommending it as the beneficiary of a special, one‑time subsidy of two million dollars ($2,000,000 USD). When that decision is demonstrably inconsistent with basic ethical norms, good‑governance practice, and unambiguous legislated instructions, it fails the same trust test the Utah Filmmakers™ Association applied to its own representative.
2.0 Awareness and complicity of the nonprofit principals
The way the nonprofit organization in question surfaced—an unknown entity with a redundant mission that suddenly became the target of extraordinary state assistance—only makes sense if its principals understood the unusual lengths the GOEO was willing to go on their behalf.
2.1 Red Flags
Key red flags that reasonable industry actors would recognize include:
- A new, largely unheard‑of nonprofit being fast‑tracked for a large, bespoke grant outside a transparent, competitive process.
- A mission overlapping heavily with existing film‑aligned nonprofit organizations, festivals, infrastructure, and other community‑oriented programs, signaling redundancy rather than clearly differentiated public value.
- Political and PR framing that positioned the unknown entity as a marquee economic‑development asset despite having no track record, a move any experienced organizer would recognize as disproportionate to its demonstrated capacity.
For a nonprofit’s principals, accepting that arrangement is not ethically neutral; it indicates a willingness to benefit from opaque, preferential treatment, which conflicts directly with UFA™ expectations around integrity, fairness, and avoiding even the appearance of exploiting public systems for private advantage.
3.0 UFA™ Values and the Associate Program
Utah Filmmakers™ explicitly defines its mission as championing reputable, Utah‑based film industry resources and guiding filmmakers by promoting its Core Values of Professionalism, Integrity, and Respect. The Associate Program is by invitation only and reserved specifically for “vetted and select individuals, organizations, and events” that the UFA™ is comfortable presenting as examples of what filmmakers should want to work with.
3.1 Vetting considerations
The vetting mandate has several implications:
- The UFA™ must actively screen for alignment with salient ethical and governance norms, not just basic legality.
- The UFA™ cannot credibly recommend organizations that accept or depend on opaque government favoritism at odds with the industry standards the UFA™ publicly encourages others to adopt.
- Prior cases show that when someone’s conduct contradicts those norms, the UFA™ withdraws trust and formal association, not by “overlooking” the behavior for strategic reasons.
Given what is now known about the proposed grant recipient—its opaque origin, redundant mission space, and reliance on ethically compromised state action—that entity, its principal members, and any successor brand rooted in that relationship cannot meet the threshold for invitation into the Associate Program or even an informal endorsement as a “reputable” resource.
4.0 Failure of basic ethical standards (common‑sense commerce)
The conduct described fails not just the specifics of the UFA™ Ethics Code, but a set of basic, widely understood expectations for doing business and stewarding public money:
- Public funds should be allocated through clear criteria, non‑discriminatory eligibility, and transparent processes that give similarly situated entities a fair chance.
- Organizations should avoid arrangements that reasonably appear to be “inside deals,” especially where public trust and community ecosystems are at stake.
- New nonprofits entering a crowded mission space should differentiate themselves through genuine service value, not by leveraging political access for disproportionate subsidies.
These are “common knowledge” norms in nonprofit management and economic‑development practice; ignoring them is inconsistent with the basic business literacy that the Utah Filmmakers™ Association encourages its individual members and member organizations to adopt. When a state board and its favored grantee disregard such fundamentals together, their credibility as partners or exemplars in the Utah film ecosystem collapses.
5.0 Implications for GOEO and the proposed grant recipient vis‑Ã ‑vis Utah Filmmakers™
Taken together, the pattern of behavior justifies the conclusion that:
- The GOEO’s Business Development Board, as an institution, has disqualified itself from serving as any kind of informal ethical reference point for the Utah film community until it transparently acknowledges and corrects the practices that led to its unanimous approval of a $2 million proposal that, as of the preparation of this memorandum, remains innocuously described by them only as an “Industrial Assistance Account (IAA) Grant.”
- Alternatively, all members who were present and voted in favor of the motion could simply resign from the Business Development Board.
- The proposed grant recipient organization and its principals—whose emergence and early viability depended on that compromised patronage—cannot be treated as a reputable, model partner for filmmakers under UFA™ standards, regardless of later rebranding or program growth.
In no uncertain terms, that places both the GOEO and the proposed grant recipient in the same practical category as the former UFA™ representative who was stripped of responsibilities: entities that, due to profound and public ethical failure, must not be held out—formally or informally—as endorsed resources or associated in any way, shape, or form with the Utah Filmmakers™ Association.
Prepared by:
Joseph L. Puente
Founder/President
Utah Filmmakers™ Association
ATTACHMENT(S)/ENCLOSURE(S)
“Ethics & Conduct Evaluation—Addendum”
(20260220_GOEO_EvalAdendum.PDF)
Ethics & Conduct Evaluation — Addendum (online facsimile)
Current Revision: 2026-02-23
(Download PDF version)
Current Revision: 2026-02-23
(Download PDF version)
Inclusive use of “GOEO” to represent both the state government Agency/Entity and Public Body.
For purposes of this evaluation, “GOEO” is used inclusively to refer to both (1) the Governor’s Office of Economic Opportunity as a state government agency/entity and (2) its Business Development / Board of Economic Opportunity as a public body.
1.0 Governor’s Office of Economic Opportunity (Entity) and Business Development Board (Public Body)
Using “GOEO” inclusively for both the Governor’s Office of Economic Opportunity and its Business Development / Economic Opportunity Board is justified because, in law and practice, the board is structurally and functionally part of the office, not an independent entity.
1.1 Statutory and structural linkage
Utah Code creates “the Governor’s Office of Economic Opportunity” as a single office and then creates “the Board of Economic Opportunity” within that office, making the board an internal governing body rather than a separate organization. The statute also requires the office to obtain the advice of “the GOEO board” before changing policies, explicitly treating the board as part of the same institutional framework.
2.0 Administrative and public‑facing practice
State records list the Business Development / GOED Business Development / GOEO board under the Governor’s Office of Economic Opportunity, with shared address, staff contacts, and mission language. GOEO’s own “Boards” and “About GOEO” pages describe the board as part of GOEO’s governance and advisory structure, reinforcing that decisions made by the board are, in effect, actions of GOEO itself.
3.0 Ethics‑analysis rationale
Because the UFA™ evaluation is focused on how public power and resources were exercised around the approval of an IAA grant, treating the office and its board jointly as “GOEO” reflects the real chain of responsibility:
- The office administers programs and manages the money.
- The board advises, approves, and authorizes key actions under that office’s authority.
For purposes of an ethics assessment, there is no practical separation between “GOEO staff” and “the Board” in terms of impact on the film community; both operate under the same statutory mandate and brand, so referring to them collectively as “GOEO” accurately captures the unified institutional actor whose conduct is being evaluated.
Prepared by:
Joseph L. Puente
Founder/President
Utah Filmmakers™ Association
Founder/President
Utah Filmmakers™ Association