July 1, 2003
MEMORANDUM
TO: Campus Financial Disclosure DesigneesFROM: 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.