The New York State Joint Commission on Public Ethics (“Commission”)  today announced that it has reached a settlement agreement with Bolton-St. Johns, LLC for violating the Lobbying Act by not timely filing hundreds of lobbyist statements of registration, registration amendments, and lobbying bi-monthly reports during the 2021-22 biennial period. 

In the agreement, Bolton-St. Johns admits that it failed to file 464 such statements and reports on time, accruing late fees of $129,890. Bolton filed an Application for Waiver of Late Filing Fee with the Commission, which was denied and eventually led to the settlement. Bolton has submitted the overdue filings to the Commission and, in the end, will pay $97,417 to settle the violations.

Under the Lobbying Act, the Commission can impose of a fee not to exceed $25 per day that a filing is late, although it generally assesses fees based on a schedule in the Comprehensive Lobbying Regulations, 19 NYCRR Part 943.10(g) and 943.11(d); both provide for a flat fee of $75 to $2,000 per filing, depending on how overdue the filing is.

As part of the settlement, in addition to any random audit of its filings, Bolton-St. Johns shall cooperate with any request by this Commission, or any successor agency or commission, to review its records related to lobbying activity during the 2021-22 biennial to determine whether filings that were required to be made have been made in a timely manner and are accurate and complete.

To read more about the Comprehensive Lobbying Regulations and the late fee schedule mentioned above, go to www.jcope.ny.gov and click on Laws, then Lobbying Laws and Regulations, and then 19 NYCRR Part 943 Comprehensive Lobbying Regulations (2020 Revisions).

To read more about this settlement agreement, go to www.jcope.ny.gov  and click on Investigations and then Enforcement Actions.