Financial Disclosure (Public Officers Law §73-a)

The Ethics in Government Act of 1987, as amended, imposes a financial disclosure requirement on any state employee serving in a job title with an annual salary exceeding $90,020 (the current filing threshold). The required statutory form is available in electronic (e-file) format and as a downloadable PDF. Financial disclosure statements are filed directly with the New York State Joint Commission on Public Ethics.

For academic employees serving in a job title with an annual salary exceeding $90,020:

  1. Academic employees of the university must file the financial disclosure statement with the commission by November 15 each year. (Applications for an exemption or an extension, available in PDF format, must be postmarked by November 1.) Academic employees who commence employment after November 15 must file within 30 days of commencing employment. The information required is for the calendar year preceding the November 15 deadline unless otherwise specifically asked in the question. Forms and instructions are available at www.jcope.ny.gov/forms/ethics.html.
     
  2. There is no exemption from filing for anyone who is (a) away from work for any part of the calendar year or (b) working a reduced work schedule. (Employees hired on a permanent part-time basis who are not designated as policy makers are not required to file a financial disclosure statement.) It is the job rate of the position in which the employee serves as of April 1 of the year in which the form is due, and not the actual compensation received during the previous calendar year, that determines whether an individual is subject to the financial disclosure requirements. For further information, please use the commission’s Ethics Opinion Finder to refer to Advisory Opinion No. 05-2.
     
  3. Please note that failure to file or filing late may result in late fees, fines up to $40,000, and publication of the names of delinquent filers on commission’s website, under Enforcement Actions.

Reporting Honoraria
The New York State Joint Commission on Public Ethics regulations set limits on the amount of honoraria state employees and officers can receive. The commission defines an honorarium as:

  1. “a payment, fee or other compensation to a covered individual for services rendered by a covered individual not related to the covered individual’s official duties, which payment, fee or other compensation is made as a gratuity, or as an award or honor; e.g., for delivering a speech, writing or authoring an article or publication or attending a meeting or conference, and”
     
  2. “a payment, whether to a lodging site or a provider of transportation, for travel expenses made to or on behalf of an individual, or reimbursement made to the covered individual for travel expenses incurred, for such services rendered by a covered individual not related to the covered individual’s official duties.”

The key is that the service for which an honorarium is received is not job-related.

The college is required annually to report honoraria received by its employees; the next report will cover the period of April 1, 2014, to March 31, 2015. If you have received honoraria of any amount during this time period, you must complete a “Report of Honoraria” form listing the sources and amount of honoraria received. The form is available on the commission’s website at www.jcope.ny.gov/forms/ethics.html.

If an honorarium received is more than $1,000, it must be reported on Question 13 of the financial disclosure statement.

In the spring semester, the Office of Human Resources will send a campus email reminder with further instructions, including the date these forms are due. It will compile the responses on these forms and send one report for Purchase College.

If you have any questions, you can visit the commission’s website at www.jcope.ny.gov or call the commission at (518) 408-3976.

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Financial Disclosure
Public Officers Law
§73-a