After a finalist for an insurance brokerage request for proposal (RFP) with the Colchester town and public schools raised concerns about the role that a Board of Finance member who works as a consultant at another insurance brokerage firm played in an interview, the town sought the opinion of an attorney, who found no violation of the Code of Ethics.

On March 31, Chuck Petruccione, who heads Brown & Brown Insurance’s municipal benefits department, sent a letter to Colchester First Selectman Bernie Dennler raising concerns about the role Colchester Board of Finance (BOF) member Jillian Vinci played in a finalist interview for an insurance RFP. According to Petruccione’s letter, Vinci, the only non-employee of the town representing Colchester in the interview, drove most of the conversation and questions.

But after the interview, Petruccione said Brown & Brown became aware that Vinci is a financial and benefits consultant for OneDigital, another insurance brokerage firm in the state. According to Vinci’s LinkedIn profile, she is currently a senior benefits consultant.

“My team and I were quite disturbed when we found this out. We were invited to participate in a finalist meeting, where we unknowingly sat across the table from one of our direct competitors in the market for an hour, answering various questions she posed to us about our processes, our customer base, how we would handle certain situations, our opinions on industry matters and government regulations, etc.” Petruccione wrote in the letter. “We provided samples of our work, discussed proprietary programs and gave details about solutions that had been specifically requested related to other customers we currently represent. We answered everything honestly and truthfully, as we would in speaking with any potential customer. We acted in good faith, not knowing the entire time that the information we were sharing was being provided to one of our direct competitors.”

Petruccione added that he understood OneDigital had not applied for the RFP, likely because Vinci’s position would create a conflict of interest, and said that while he wasn’t sure whether Vinci should have recused herself, she should have made her professional affiliation known.

Petruccione also questioned whether Vinci’s conduct violated the town’s Code of Ethics.

Under Colchester’s Code of Ethics, “public officials and employees are prohibited from participating in “any business or transaction, including but not limited to outside employment with a private business, or have an interest, direct or indirect, which is incompatible with the proper discharge of his/her official responsibility in the public interest or which would tend to impair his/her independent judgment or action in the performance of his/her official responsibilities.”

The code also requires public officials and employees to refrain from voting or participating in any matter with a business or individual with whom they are associated or related to, or if an immediate family member has a financial or personal interest in a contract.

“If such participation is within the scope of the public employee’s or public official’s official responsibility, he/she shall be required to provide written disclosure, which sets forth in detail the nature and extent of such interest, to the [Ethics] Commission.” the Code of Ethics further state.

Petruccione asked the town to confirm whether Vinci had submitted a written statement to the Ethics Commission notifying them she worked for a brokerage firm and would be participating in interviews with competing companies.

“Because one of two things must be true – either she disclosed this to the Commission and a decision was made to not inform our company of this situation; or she did not disclose this and unilaterally decided to withhold this pertinent information from both the Commission and our company.” Petruccione wrote.

He added that he would have asked the Ethics Commission directly, but three of the commission’s five seats were vacant.

According to a source who spoke with Inside Investigator on background and submitted a Freedom of Information Act request for written conflict of interest statements for the town’s BOF members in late May, the town had no responsive documents, meaning Vinci does not have a written conflict of interest statement on file with the Ethics Commission.

After Pettruccine contacted the town, Ethics Commission chair Ursula Tschinkel requested an advisory opinion from the town’s attorney. Town attorney Matthew Ritter wrote an opinion finding that Vinci had not violated the Code of Ethics, largely because she did not meet the definition of associating with a “business” under the town code.

Ritter’s decision noted that the Code prohibits town officials from participating in decisions involving businesses from which they are associated and that the Code defined that as “a business of which the person or a member of his/her immediate family is a director, officer, owner, partner, member, employee, compensated agent or holder of stock which constitutes 5% or more of the total outstanding stock of any class.”

Becuase Vinci is a consultant for OneDigital, Ritter wrote that there was no evidence she fit that definition and “nothing in this definition that would require her to refrain from voting pursuant to the Code” and that she did not need to submit written disclosure detailing the nature of her interest in OneDigital.

Ritter also found that because OneDigital did not participate in the RFP, Vinci had no direct or indirect financial interest in its outcome.

In response to Petruccione’s concern that Brown & Brown provided potentially sensitive information about their internal processes that could be advantageous to their competitors, Ritter pointed to another section of the town code that prohibits public officials from disclosing confidential information acquired through processes like the RFP.

“If the Board of Finance member discloses any confidential information to OneDigital, that would be a different legal analysis.” Ritter wrote.”

“Ms. Vinci was chosen to serve as part of the interview process by her peers on the Board of Finance because of her professional expertise in this field. This was not a secret, and her employer was not a prospective bidder in the process.” Dennler told Inside Investigator in response to a request for comment from Inside Investigator. “After Mr. Petruccione sent correspondence to me, I provided it to the Ethics Commission Chair Ursula Tschinkel. Ms. Tschinkel contacted town counsel Matthew Ritter who provided the attached advisory opinion in response to Mr. Petruccione’s letter.”

“As the analysis clearly demonstrates, there was no violation of the Town’s Code of Ethics and no requirement for Ms. Vinci to provide written notice to the Ethics Commission.” Dennler added.

Asked about vacancies on the Ethics Commission, which according to the town’s website has not met since April 2025, Dennler said, “The Ethics Commission requires volunteers willing to serve. Unfortunately, there were not interested in applicants for several months after a longtime member moved out of town. Since then, the Board of Selectmen has interviewed and appointed a new commission member, and the Ethics Commission once again has quorum. The commission meets on an as-needed basis as called by its chair.”

There are currently two vacancies on the Ethics Commission, down from the three at the time Petruccione submitted his letter.

Following a vote in January, Colchester hired USI as a broker for the town. Dennler said the town has been “very pleased with USI’s work” and has “no regrets about our decision to use them over Brown & Brown.”

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