Sen. Noel Frame

The Sequencing — The Critical Timeline

Understanding this conflict requires understanding the order of events. Frame did not join a firm that happened to have government contracts. She voted to create a government program, then became an owner of the firm hired to run it.

The Contracts

Total state payments to the firm during Frame's ownership period (September 2022 onward): $1,340,765, per her own F1 disclosures. Total payments across the firm's full history with state agencies: approximately $1.84 million.

Additional confirmed Commerce engagements: DEIR assessment, Homeownership Disparities Work Group, Condo Conversion/AHAB study, Homeless Service Provider Stipends outreach, Comprehensive Planning engagement resources (active 2025). The firm also holds subcontracts through Kinetic West for Commerce work.

The Non-Competitive Contract — K532

The Governor's Office K532 contract is the most significant legal finding. Under RCW 42.52.120(2)(c), a legislator with a beneficial interest in a state agency contract that was awarded non-competitively must obtain post-award LEB approval. The K532 contract was awarded in March 2024, during Frame's ownership.

Advisory Opinion 24-01 — The Board's Own Framework

In October 2024, the LEB issued Advisory Opinion 24-01 on its own motion, establishing criteria for evaluating legislator contracts with state agencies. It identifies three automatic disqualifiers. The third is directly relevant to Frame:

• The work arose out of legislation or a budget proviso in which the legislator was the prime sponsor, primary negotiator, or committee chair.
• The contract requires advocacy on the part of the legislator with other legislators, staff, or state agencies.
• The contract requires advocacy regarding policies customarily within the legislator's official purview. Frame sits on the Senate Housing Committee as Vice Chair. Uncommon Bridges' Commerce contracts are almost entirely housing-related. If any of the firm's work involves advocacy regarding housing policy, this constitutes an automatic conflict under the board's own stated criteria.

The opinion also lists 12 non-automatic "totality of circumstances" factors. Several cut directly against Frame: 20% ownership stake (Factor 1 — size of economic interest); partner compensation tied to firm revenue which depends on government contracts (Factor 3 — financial benefit as part owner); Managing Partner role (Factor 4 — legislator's role); and the fact that Frame joined BDS Planning the same month she entered the legislature, meaning she has no pre-legislative expertise that predates her public role (Factor 11).

The Google Conflict

Frame's household has a second, structurally independent conflict. It is legally weaker than the Uncommon Bridges finding — but the facts are worth stating clearly.

Frame is the prime sponsor of SB 5708 ("Protecting Washington Children Online"), restricting algorithmic feeds on platforms used by minors. YouTube clearly qualifies under the bill's definitions. The bill passed the Senate 36–12. Frame voted yes as prime sponsor. No recusal.

The directional problem is the central issue: Frame is sponsoring legislation that would impose costs on Google, not help it. Under current WA ethics law — including In re Alvarado (2025-11) and In re Parshley (2025-37) — sponsoring broadly applicable legislation that affects an industry where a family member works is not a cognizable violation. The legal risk on this conflict is low. But the disclosure facts are accurate: the household's primary income source and $100K–$200K in personal equity are at Google, and Frame sponsored a bill that Google's trade associations testified against.

Full Income Summary (2024 F1)

The Legal Framework

Five statutes govern this analysis. The most relevant is RCW 42.52.120, which creates a three-track framework for legislators with beneficial interests in state agency contracts:

• Track A (competitive, multiple bidders): No LEB approval required. Applies to the PSH Advisory Committee contract, Commerce 24-63610-003, and the Puget Sound Partnership contract.
• Track C (non-competitive): Post-award LEB approval required under RCW 42.52.120(2)(c). Applies to Governor's Office K532. Whether approval was obtained is unknown.
• Ambiguous: Commerce 21-46108-311 is classified "Personal Services — Non-Client," which does not map cleanly to competitive or non-competitive. It was awarded before Frame's ownership but extended through June 2023, overlapping with her ownership period.

The closest precedent is In re Murray (1999-05), where the LEB found a technical violation when a budget committee co-chair failed to obtain pre-approval for a non-competitive contract with an agency he oversaw. The board characterized it as a "technical violation" but noted the structural problem. Murray was a salaried contractor with no ownership stake; Frame is a Managing Partner whose compensation varies with firm revenue. No existing LEB case is squarely on point for a legislator who is simultaneously (1) a managing partner and substantial owner of a consulting firm with multiple state agency contracts and (2) a vice chair on the budget committee funding that agency.

What Has Not Been Reported

A review of InvestigateWest, Washington State Standard, Seattle Times, KUOW, The Stranger, and Crosscut finds no prior reporting connecting: Frame's Uncommon Bridges income to her Housing Committee or Ways & Means roles; the K532 non-competitive contract during her ownership; the HB 1724 sequencing (voted to create program, became owner of implementing firm seven months later); or the GOOG personal equity holding alongside the SB 5708 sponsorship.

Verification

F1 Disclosure (2024, most recent)

F1 Disclosure (2023)

F1 Disclosure (2022 — first year of ownership)

State payments (PDC contributions dataset)

FY2024 Agency Contracts (K532 source)

Advisory Opinion 24-01

HB 1724 (PSH Advisory Committee)

SB 5708 (Children Online)

Vendor checkbook (full payment history)