April 10, 2009 | Advisory Memoranda
It is the time of year for filing annual Financial Disclosure Statements (“FDS”) and for reporting Honoraria.
The annual FDS for calendar year 2008 must be filed by Friday, May 15, 2009, by all employees in “policy making” positions and by those non-exempt employees who earn over the threshold amount.
New for this year, the NYS Commission on Public Integrity will be sending the ID and Password information to CUNY filers by Email ONLY. There will be no notifications sent by regular US Mail. Please notify your campus filers of this important change (See Attachment 1, Notice from NYSCPI).
Please be advised the Commission reviews each statement for compliance. If an employee fails to file a statement or files a deficient statement, the Commission will notify the employee and the College in writing of the deficiency and the penalties which will be assessed for continued non-compliance. A copy of the notice of non-compliance with the employee’s name will be posted on the Commission website. If, following written notice by the Commission, the employee continues to knowingly and willfully fail to file a financial disclosure statement or knowingly and willfully with intent to deceive makes a false statement or gives information which the employee knows to be false, then the employee is subject to a civil penalty up to $40,000.
An Honorarium is a speaking fee or compensation received for writing an article or reimbursement for travel expenses not related to official duties. The current reporting year for honoraria is April 1, 2008 to April 1, 2009.
Employees reporting honoraria are required to do so on the form on page 14 of Attachment 2 (Memorandum to College Presidents from Frederick P. Schaffer, dated April 11, 2008). Note that the college’s form for reporting all honoraria to the Commission is available on the website at http://www.nyintegrity.org/forms/ethics.html.
Please note that CUNY employees invited to serve on advisory boards of for-profit companies, whether compensated or not, must request permission of the College President with review by the General Counsel.
Please notify and remind all employees concerned of these requirements. I recommend that first-time filers be directed to review the rules on the NYSCPI web at http://nyintegrity.org/online, and if they have further questions that they contact their College Ethics Officer (see Attachment 3).
I recommend consulting the NYSCPI website for any issues that may arise, or you may always call me. The Commission’s website has detailed instruction on how to file and complete the FDS forms.
Effective April 1, 2009, the filing threshold salary for financial disclosure filing is $84,863 per year or more. Go to the New York State Commission on Public Integrity website at http://www.nyintegrity.org/online.
Please note: All USER ID and PASSWORD letters for the Financial Disclosure filing due May 15th will be emailed to filers on April 9th and 10th. See http://www.nyintegrity.org.