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 $115,252 (effective April 1, 2025). 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 Commission on Ethics and Lobbying in Government.
Under Section §73-a of the Public Officers Law, state officials and employees are required to file an annual statement of financial disclosure (FDS). An FDS is a publicly available record containing information about financial holdings and professional associations of the filer and their spouse. The purpose is to provide transparency in order to prevent conflicts of interest and abuses of official position and to help the filer identify and manage potential conflicts of interest.
Academic employees of the university must file the financial disclosure statement with the commission by November 15 each year. Employees may request a filing extension or an exemption directly on New York State Commission on Ethics and Lobbying in Government website or by printing out the application and mailing it in. Requests must be received by the November 15 filing deadline. The status of the request can be tracked online. 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 New York State Commission on Ethics and Lobbying in Government.
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. 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 Advisory Opinions to refer to Advisory Opinion No. 05-2.
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 the commission’s website (under Notices of Delinquency).
The New York State Commission on Ethics and Lobbying in Government defines an honorarium as:
Any payment made in exchange for rendering a service or activity that is not part of your official duties. Examples include: delivering a speech, writing or publishing an article, or participating in a public or private conference, convention, meeting, or similar event.
Payment or reimbursement of expenses for travel, lodging, or meal(s) related to the service performed.
All faculty members of SUNY and CUNY (except SUNY community colleges) and State officers and employees with certain titles (research scientist; cancer research scientist; research physician; research psychiatrist; psychiatrist) are exempt from the Honorarium approval procedures (including the conditions for approval), provided that the service performed is within the subject matter of their official academic or research discipline.
If you are not a faculty member or an employee with an above-named title, a request for approval of an honorarium must be submitted in writing to your agency’s Ethics Officer before performing the service or activity. Purchase College’s Ethics Officers are Amanda Zallo, Senior Human Resources Manager, and Kathleen Farrell, Chief Human Resources Officer.
State employees who are required to file a financial disclosure statement (“FDS”) – even those who are exempt from the honorarium approval requirements – are obligated to report any honorarium in excess of $1,000 (or all honoraria, the total of which exceed $1,000 received from a single offeror) in their FDS for the applicable year.
Restrictions on honoraria:
State personnel, equipment, and time cannot be used in preparing the service for which an honorarium is offered.
State funds cannot be used to pay the covered person’s attendance, registration, travel, lodging, or meal expenses.
If the service is to be performed during the covered person’s official work day, you must charge accrued leave (other than sick leave) to perform such service.
If the honorarium is offered by or on behalf of an interested source, it may only be accepted if it is unreasonable to infer that the honorarium was intended or expected to influence the covered person, or was intended as a reward.
The Ethics Officer/approving authority must determine that the offeror is not being used to conceal that the honorarium is actually offered or paid by an interested source.
Acceptance of an honorarium must not create even the appearance of a conflict of interest – in violation of Public Officers Law § 74 (the Code of Ethics).
If you have any questions, you can visit the commission’s website at https://ethics.ny.gov/ or call the commission at (518) 408-3976.
