Frequently Asked Questions
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WHAT IS THE ANNUAL DISCLOSURE LAW?
New York City’s Annual Disclosure Law, Section 12-110 of the City’s Administrative Code “Admin. Code”), requires that over 9,000 New York City employees and elected officials file annual reports of their financial affairs, as well as the financial affairs of their spouses or domestic partners and dependent children.
The purpose of the Annual Disclosure Law is to provide accountability on the part of public servants and to help ensure that there are no prohibited conflicts of interest between City employees’ official responsibilities and private interests.
The law is administered and enforced by the New York City Conflicts of Interest Board (“COIB”), as mandated by the New York City Charter.
WHO FILES ANNUAL DISCLOSURE REPORTS?
WHEN ARE REPORTS FILED?
Annual disclosure reports are filed annually during a four-week period starting on a date designated by COIB.
Candidates for elective office must file their annual disclosure reports no later than 25 days after the last day for filing their designating or independent nominating petitions pursuant to the election law.
Persons leaving City service are also required to file an annual disclosure report, known as a termination report, covering the part of the last year in which the filer was a public servant. This report is due within 60 days after the employee or official leaves.
WHAT IS MY LOG-IN ID?
If you work at a Mayoral agency, your 7 digit Employee Identification Number is your log-in id for the filing application.
If you work at a non-Mayoral agency or are a compensated member of a board or commission, your log-in id is based on your agency acronym, the first letter of your last name, and the last 4 digits of your social security number. E.g. if you work at NYCHA, and the first letter of your last name is “A”, and the last 4 digits of your social security number are “1234” - your log-in id would be NYCHAA1234.
IS IT POSSIBLE TO OBTAIN AN EXTENSION OF TIME TO FILE?
If a person can show justifiable cause or undue hardship, he or she may be able to obtain an extension of time to file his or her annual disclosure report.
Requests for an extension of time to file a report must be emailed or postmarked to COIB no later than 15 days before the deadline for filing the annual disclosure report.
WHAT HAPPENS WHEN A REPORT IS FILED LATE?
If a report is not filed within one week after the due date, and the filer has not been granted an extension, the late filer is subject to a fine of a minimum of $250 and a maximum of $10,000, pursuant to Admin. Code § 12-110(g).
Failure to pay the fine when requested constitutes an intentional violation of the Annual Disclosure Law, which is also a violation of Chapter 68 of the City Charter. Such a violation is a misdemeanor, and is also punishable by disciplinary action and a civil fine up to $10,000.
WHAT HAPPENS IF A REPORT IS NOT FILED OR IF FALSE STATEMENTS ARE MADE ON THE REPORT?
Any intentional violation of the Annual Disclosure Law, including a failure to file or a misstatement, such as a misstatement of assets and liabilities, can subject the person required to file a report to assessment by COIB of a civil penalty of up to $10,000.
In addition, any intentional violation of the Annual Disclosure Law is a misdemeanor punishable by imprisonment for not more than one year or by a fine of up to $1,000 or both. An intentional violation is also grounds for disciplinary penalties.
MAY A REPORT BE AMENDED?
Occasionally, a public servant unintentionally omits certain information in the report or unintentionally includes incorrect information. In those cases, the filer can contact COIB and request an amendment password.
MAY THE PUBLIC SEE THE REPORTS?
Under the law, the public is entitled to inspect the public portions of a public servant’s annual disclosure report. COIB is required to notify the filer of any such request to inspect the report.
By law, the public servant’s home address is withheld from public inspection, unless the home is co-owned with a non-relative. Financial information pertaining solely to the public servant’s spouse or domestic partner or dependent children is withheld from public inspection, unless the information involves an actual or potential conflict of interest on the part of the public servant.
CAN A FILER REQUEST PRIVACY?
At the time the report is filed or at any time thereafter, except when a request for inspection is pending, a filer may request that COIB withhold certain items in the report from public inspection. The request must show that public inspection of the item would be an unwarranted invasion of the filer’s privacy or a risk to the safety or security of any person. COIB will review the privacy request when a request to view the report is made and make a determination.
WHAT HAPPENS IF I AM A REQUIRED FILER AND I'M TRANSFERRING TO ANOTHER CITY AGENCY?
If you are transferring from one city agency to another, your filing status may or may not remain the same. The annual disclosure liaison at your new agency will inform you if you are required to file in your new position.
HOW LONG ARE REPORTS KEPT ON FILE?
Annual disclosure reports must be maintained on file for a period of six years from December 31st of the calendar year to which the report relates. The reports are destroyed after six years, unless there is an ongoing investigation of the filing public servant.
CAN A FILER APPEAL THE REQUIREMENT TO FILE AN ANNUAL DISCLOSURE REPORT?
Any employee designated as a required to file by his or her agency may appeal the determination that he or she is required to file an annual disclosure report with COIB , first to his or her agency and then to the COIB. Your annual disclosure liaison can provide you with the appeal forms.
WHO MAY I CONTACT WITH QUESTIONS REGARDING ANNUAL DISCLOSURE?
Each city agency has an annual disclosure liaison who may help you with any inquiries you may have regarding the annual disclosure process.
In addition, the Annual Disclosure Unit staff at the Conflicts of Interest Board is available to answer your questions. Please contact the staff at 212-437-0739 or firstname.lastname@example.org.