The New York City Conflict of Interest Board has ruled that television advertisements for the city's, NYC BONDS program do not violate city charter regulations.

The ads feature Mayor David N. Dinkins and Comptroller Elizabeth Holtzman attempting to drum up interest in the bonds, which are sold in small denominations and targeted for retail investors.

The ruling follows a June 29 letter to the board by Assemblyman Alan G. Hevesi, D-Queens, who is running against Holtzman in the Democratic primary for comptroller.

Hevesi asked the board to determine if the television advertisements violate the city charter by creating "the appearance of a conflict of interest."

The city charter prohibits officials from using their position in government for private gain.

But the board found that the ads do not violate the charter, according to a July 16 letter to Holtzman.

"In sum, your participation in the advertising for the bond program was intended to help develop a new retail market for city obligations," the board said. "As such, your participation is consistent with your official duties as city comptroller."

Hank Morris, a spokesman for the Hevesi campaign, had no comment on the board's ruling.

But the matter may not be dead, according to Richard Bryers, a spokesman for Rudolph W. Giuliani, the Republican-Liberal candidate running against Dinkins in the upcoming mayoral election.

Bryers said the Giuliani campaign did not request a ruling from the Conflict of Interest Board because members of the board are chosen by the mayor, and the request would not be taken seriously.

Bryers confirmed that the Giuliani campaign has written the city's Campaign Finance Board, which in a July 7 memo suggested that Giuliani pursue "a formal complaint," rather than get an advisory opinion.

A spokeswoman for the finance board said that because Giuliani requested "a specific remedy," he should submit a formal complaint about the ads.

Bryers said Giuliani's legal staff is examining the issue.

"We're discussing right now if we should file a formal compliant," Bryers said. "We'll know [what to do] sometime this week."

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