Please see the below reminders regarding compliance with New York State Ethics Requirements for State Employees:
FINANCIAL DISCLOSURE STATEMENTS
The annual Financial Disclosure Statement ("FDS") filing for calendar year 2024 must be filed by Thursday,
May 15, 2025, by all employees in “policy-making” positions and by those non-exempt employees who earn over the threshold amount (The filing threshold for financial disclosure will apply to anyone serving in a job title with an annual salary in excess of $115,252 (as of 4/1/2025). For detailed instructions, please go to the COELIG webpage regarding FDS,
https://ethics.ny.gov/fds-filing-information-and-forms .)
A notification from COELIG regarding 2024 Financial Disclosure Statement was sent out in mid-April via email from
ethics@PROTECTED to those employees required to file.
All newly hired employees are required to file an FDS for the previous year within 30 days of being appointed to a covered position. Any employee promoted into a policy-making position, or newly designated as a policy-maker, must also file an FDS within 30 days of assuming the new position.
Employees who are designated as policy-makers, or those earning over the CSEA Salary Grade-24 rate ($115,252 as of 4/1/2025) and who have not received an exemption from COELIG, are required to file an annual financial disclosure statement with COELIG.
Please be aware that you must use the following website (NY.gov):
https://my.ny.gov/ to access your COELIG online FDS account. If you do not already have a NY.gov account, please contact Russell Platzek, York College Ethics Officer, at
rplatzek@PROTECTED .
Definition of Policy-Maker
Policy-makers are typically employees who manage a group of people, including chairs, deans, directors or other heads of academic departments; or who exercise certain authority or discretion in helping formulate or implement the goals and policies of the state
or a state agency.
If an employee is unsure whether the employee has been designated as a policy-maker by their school or college, the employee should contact Russell Platzek, York College Ethics Officer, at
rplatzek@PROTECTED .
Department Chairs as Policy-Makers
University school and college department chairs are CUNY employees charged with administrative duties, including purchasing authority (however limited) and the management of the members of the department and support staff.
Under COELIG’s definition of a policy-maker, department chairs in academic departments possess discretionary policy-making authority and therefore are considered policy-makers and such individuals will not be granted an exemption from filing an FDS.
Please also note that school or college department chairs are required to file an FDS for 2024 by the May 15, 2025 deadline for policy-makers, even if they already filed as an academic filer for 2023 before the November 15, 2024 deadline. Department chairs only need to file an FDS in May of each year and need not file in November unless and until they end their term as chair and return to a non-policy-making faculty position.
FDS Non-Compliance
COELIG reviews each FDS for compliance. Employees who fail to file an FDS or who file a deficient FDS will be notified by COELIG by email to their CUNY email address. Notices of non-compliance are posted on the COELIG website and will be sent to the school or college.
If, following written notice by COELIG, an employee continues to knowingly and willfully fail to file an FDS, or knowingly and willfully with intent to deceive makes a false statement or gives information that the employee knows to be false, the employee is subject to a civil penalty up to $40,000. Please review recent enforcement actions posted on COELIG’s website.
A filer may request a 45-day extension of time to file the FDS based on justifiable cause or undue hardship. Extensions may be requested through the FDS Online Filing System or by completing and submitting a PDF form, which must be received or postmarked on or before the filing due date. If you have any questions, please contact Russell Platzek, York College Ethics Officer, at
rplatzek@PROTECTED .
HONORARIA
All CUNY employees are required to comply with the law and regulations governing the receipt and reporting of honoraria earnings, regardless of their designation as a policy-maker (see Title 19 NYCRR Part 930: Honoraria).
COELIG generally defines an honorarium as a payment for a service that is not part of an employee’s official duties. Examples include delivering a speech, writing or publishing an article, and participating in a public or private conference, convention, or
meeting. Honoraria also include expenses incurred for travel, lodging and meals related to the service performed.
CUNY Employees Not Employed in Academic Titles
Individuals must submit this form to their school or college’s ethics officer “within a reasonable period of time prior to the performance of the service for which an Honorarium is offered,” and the school or college’s ethics officer must review and approve the activity in accordance with Parts 930.4 and 930.5.
CUNY Faculty: Full Time and Adjunct
All CUNY faculty are exempt from the restrictions on the receipt of honoraria revenues, provided that the service performed by the faculty member is within the subject matter of his or her academic discipline. This exemption means:
1. CUNY faculty do not need to seek approval to receive honoraria; and
2. CUNY faculty may receive honoraria income from an interested source.
However, CUNY faculty must still report the receipt of any and all honoraria. The exemption for academic positions does not relieve faculty from the reporting requirement.
COELIG, while defining honoraria as compensation for work unrelated to an employee’s official duties, still requires faculty to report receipts of all speaking fees; reimbursed travel expenses; or payments received for writing and/or presenting written materials.
All records of honoraria income received by CUNY employees during the period April 1, 2024 through March 31, 2025 must be forwarded to the College Ethics Officers by May 1, 2025.
A University school or college does not need to report honoraria to COELIG. However, each school and college needs to retain all honoraria reports for three years.
CUNY employees (in both academic and non-academic titles) who file an FDS must also report all honoraria in excess of $1,000 on their annual FDS.
OFFICIAL ACTIVITY EXPENSE PAYMENTS
Any FDS filer may accept payment or reimbursement from a third party for travel or expenses related to an activity that is part of, and related to his official position given that certain conditions are met (See Title 19 NYCRR Part 931). Any such payments in excess of $1,000 are reportable on the FDS. An example of such a payment would be reimbursement for travel and lodging offered by the sponsor of a conference related to college admissions to a University’s college vice president for admissions. These payments or reimbursements from third parties are rare and must be pre-approved by College Ethics Officers. The College must retain records of such approvals for three
years.
OUTSIDE ACTIVITIES
An Outside Activity is any outside employment, either public or private, engaged in on an ongoing basis by a CUNY employee who has been designated a policy-maker that is unrelated to responsibilities and duties performed by the employee for CUNY. Please be aware that an Outside Activities Report must be submitted for review and approval by your appointing authority
before an individual engages in an outside activity. For more information, please see the Outside Activities FAQs on our website at:
https://www.cuny.edu/about/administration/offices/legal-affairs/policiesresources/ethics/outside-activities-faq/.