SUNY University-Wide Human Resources Manual
Curtis Lloyd Memorandum - Academic Financial Disclosures

July 1, 2003

MEMORANDUM

TO: Campus Financial Disclosure Designees

FROM: Curtis Lloyd, Director, University-wide Human Resources

SUBJECT: Financial Disclosure of SUNY Academic Employees

As you are aware, we have had ongoing discussions with the New York State Ethics Commission regarding proposed procedural changes to the special Financial Disclosure Filing process (SUNY-1 form) that had been developed with SUNY's participation for faculty. We have been notified by the Ethics Commission that they are going to terminate the SUNY-1 filing process for academic filers effective with the November 15, 2003 filing period.

Academic filers above the salary threshold of $70,851 will be required to complete the longer statutory financial disclosure statement and file it directly with the Ethics Commission instead of the abbreviated SUNY-1 form filed with the campus. Filings may be accomplished by either remitting a paper version of the form to the Commission or filing electronically via the Commission's Internet based e-filing system.

In addition to these changes, academic employees, who have not been designated as policymakers by the campus, will also be eligible to file for an exemption from the disclosure reporting requirements pursuant to Executive Law section 94(9)(K). Such applications will be submitted on an annual basis to the Commission. The Commission will render its determination based on a review of job duties and a certification by the academic employee that, during the reporting year, he or she was not involved in grant activity or any other activity which would preclude the Commission from granting the exemption request. It is the Commission's expectation that although SUNY academics will now be filing the longer statutory form, fewer academics will be required to participate in the financial disclosure reporting process.

The Commission's determination will also affect the SUNY-2 filing process; the form filed upon application for sponsored research grants. They have indicated that with the reversion to the statutory form for academics, the State will no longer have an interest in the SUNY-2 form. This disclosure linked to grant applications will, however, remain necessary under federal grant requirements. The University and the Research Foundation will need to consider possible changes to the form to assure compliance with federal law. In the meantime, the SUNY-2 form should continue to be used.

If you need additional information or have any questions, please let me know.