SUNY University-Wide Human Resources Manual
Orientation
- Financial Disclosure

last updated: Thursday July 1, 2004

New York State passed a new Ethics in Government Act in 1987 (section 75-a of the NYS Public Officers Law) that established an Ethics Commission with primary responsibility for preventing ethics violations. The intent of the law is to "restore" public trust in New York State Government. Among other provisions, the law requires certain State officers, employees and political party members to file financial disclosure reports with the NYS Ethics Commission annually.

Within SUNY, employees required to file annual financial disclosure statements include:

    1. All policy makers regardless of the amount of compensation received. Policy makers include the Chancellor, vice chancellors, and associate vice chancellors in SUNY System Administration. At SUNY campuses, policy makers include the President, vice presidents, and deans.

    2. All employees not otherwise exempted who earn annual compensation at or above the job rate of Salary Grade 24, which was $70,851 in 2002. Additional salary factors such as department chair stipends and "also receives" are included with base annual salary in determining filing requirements.

Academic Employees

SUNY academic employees must file financial disclosures at the beginning of each academic year with a usual filing deadline of November 15th. Until 2003, the NYS Ethics Commission Advisory Opinion 90-15 provided special simplified filing procedures and forms for SUNY academic employees. As of the November 15, 2003 filing period academic employees who have been designated policy makers, or are at or above the Salary Grade 24 salary threshold, will be required to complete the longer statutory financial disclosure form and file it directly with the Ethics Commission instead of the abbreviated SUNY-1 form with the campus. However, academic employees who are not policy makers and are required to file only on the basis of salary, are eligible to file for an exemption from the disclosure reporting requirement pursuant to Executive Law section 94(9)(K). Such exemption applications will have to be filed to the Commission on an annual basis. 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 that would preclude the Commission from granting the exemption request.

Academic employees who apply for sponsored research grants will still have to file the SUNY-2 disclosure form since this it is necessary to meet federal grant requirements.

SUNY policy makers and all other employees required to file on the basis of total compensation received

SUNY policy makers and all other employees required to file on the basis of total compensation received must file by May 15th each year.

Employees required to file the financial disclosure form can do so electronically or they may use the "Financial Disclosure Form (pdf)". There is also a form for academic employees or other employees to use to annual request an exemption. Links to the forms are available under forms at the end of this section.

Reference(s):

Advisory Opinion 90-15, State Ethics Commission
addressing the issue of special application of the financial disclosure rules to academic employees of SUNY and CUNY
http://www.nysl.nysed.gov/edocs/ethics/90-15.htm

Curtis Lloyd memorandum
advising campuses of the elimination of the abbreviated filing procedures for academic employees previously provided by Advisory Opinion 90-15 above.

Changes to SUNY Academic Employee Filing Requirements (Advisory 03-6)
http://www.dos.state.ny.us/ethc/opinions/03_06.html

Ethics On-Line Training from the Governor's Office of Employee Relations
http://www.goer.state.ny.us/Train/onlinelearning/eth/intro.html

Frequently Asked Questions, NYS Ethics Commission - Financial Disclosure
http://www.dos.state.ny.us/ethc/fdfaq.html

Instructions for Filing Financial Disclosure Forms
http://www.dos.state.ny.us/ethc/FDSInstructions.html

NYS Public Officers Law, Section 73-a - Financial Disclosure
http://www.dos.state.ny.us/ethc/POL73a.html

SUNY Financial Disclosure - NYS Ethics Commission
http://www.dos.state.ny.us/ethc/SUNY.html#add1

Form(s):

Financial Disclosure Electronic Filing
http://www.dos.state.ny.us/ethc/ethel.html

Financial Disclosure Form (pdf)
http://www.dos.state.ny.us/ethc/pdfs/0956.pdf

Financial Disclosure Form - Request for Individual Exemption from filing(pdf)
http://www.dos.state.ny.us/ethc/pdfs/individualform.pdf