SIGNIFICANT GROWTH IN ETHICS AND LOBBYING GUIDANCE AND EDUCATION ...
In just its second full year of operation, the Commission on Ethics and Lobbying in Government (the Commission or COELIG) has responded to marked increases in requests for guidance on ethics and lobbying matters and amplified its statewide ethics education processes to great success, Executive Director Sanford N. Berland announced today. COELIG and its agency partners oversaw the delivery of comprehensive instructor-led and on-demand ethics training to more than 170,000 executive branch employees in 2024, an increase of over more than 14% over 2023.
In that same period, COELIG’s ethics and lobbying advice and guidance units responded to more than 40,000 workforce, user, and public inquiries and requests for guidance and assistance. Further, the agency’s investigations and enforcement staff commenced a significant number of new matters and completed and resolved a substantial number of investigations of pending matters.
“Recognition of the critical importance of universal workforce and lobbying ethics training and guidance is growing across state government, and its impact is evidenced by the marked increase in inquiries and guidance requests from the field received in 2024,” Executive Director Berland said. “Despite the varying technologies being used across the breadth of state agencies and variations in staffing levels, COELIG, in partnership with the hundreds of agencies that make up the executive branch of state government, continues to build on the strong foundation of our exceptionally motivated, dedicated, knowledgeable, and effective staff to achieve our mission and goals.”
“At its core, the Commission is wholly committed to fulfilling its mission to foster public confidence that our state’s government is working in the public’s interest,” Chair Leonard B. Austin said. “The achievements quantified in this analysis demonstrate that through expanded education and training, expert guidance, and vigorous enforcement of the state’s ethics and lobbying laws, the hard work is well underway to achieve that undertaking.”
Ethics Education COELIG is responsible for administering comprehensive ethics training to approximately 330,000 officers and employees at nearly 400 state agencies and departments, as well as to more than 10,000 lobbyists and clients. The Commission developed the New York State Ethics Training Application (SETA) to fulfill the unprecedented and nationally unique program of mandatory annual ethics training mandated by the 2022 Ethics Commission Reform Act (ECRA).
More than 86,000 executive branch officers and employees received instructor-led comprehensive ethics training delivered by agency ethics officers or members of the COELIG education team in 2024, while 83,715 completed comprehensive on-demand training.
Contributing to this success, the Commission launched the Statewide Ethics Training Application (SETA) in 2024, the first statewide ethics training application of its kind, which makes it possible to schedule, track, and monitor ethics trainings and compliance with training requirements at the individual employee level. Additionally, COELIG’s Comprehensive Ethics Training Course (CETC) is now available through the Statewide Learning Management System (SLMS), which has broadened availability to a large and growing number of employees. Ethics training aims to provide the state workforce with the information and tools they need to recognize and avoid potential conflicts of interest, to identify when to seek advice and guidance, and to comply in all respects with the state’s ethics laws and regulations.
The following table shows the year-over-year growth in ethics training efforts from 2023 to 2024.
COELIG Ethics Trainings Held |
Total Employees Who Received Live or On-Demand Training |
Employees Who Completed On-Demand Training |
Employees Who Completed Live Training |
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Ethics and Lobbying Guidance
The Commission regularly provides advice, guidance, and assistance to state officers and employees, and lobbyists and clients concerning ethics and lobbying laws. On a daily basis, the Commission’s teams of knowledgeable staff and counsel answer questions and address issues in both formal and informal communications.
Notably, Commission staff responded to 39,491 lobbying inquiries and processed nearly 63,000 lobbying filings in 2024. COELIG anticipates lobbying registrations, reports, and amendments will continue to be filed at historically high rates. In addition, the staff provided ethics guidance in response to more than 1,300 requests on such topics as outside activities, post-state service employment, and conflicts of interest, a 60% increase over 2023.
The following table shows the year over year growth for Commission guidance from 2023 to 2024.
ETHICS AND LOBBYING GUIDANCE
Investigations and Audits
The Commission continues to receive tips, complaints, and reports that are reviewed for possible violations of New York’s ethics or lobbying laws. If the preliminary review of information warrants a formal investigation, the subject of the investigation receives a written notice of allegations, often referred to as the “15-day letter,” to which they may respond within 15 days. The Commission opened 22 investigations in 2024 and closed 113 matters last year.
The following table compares investigation and enforcement matters handled in 2023 to 2024.
Tips, Complaints, and Reports Received |
Notice of Allegations Letters Sent |
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The Commission conducts a Random Review Program for Financial Disclosure Statements (FDS) and a Random Audit Program for reports and registration statements filed by lobbyists and their clients to ensure accuracy and compliance with statutory requirements and to provide guidance when necessary.
In 2024, COELIG completed 861 random audits of lobbying filings and a total of 1,156 targeted and random reviews (990 and 166, respectively) of Financial Disclosure Statements filed by statewide elected officials, members of the legislature, senior state government officials and other filers. As a result of the latter, the Commission issued 486 Requests for Additional Information Letters (RAILs) in 2024.
The following table compares audits and reviews for 2024 to 2023.
Random Audits of Lobbying Filings Completed |
Random FDS Reviews Completed |
Requests for Additional Information Letters (RAILs) Sent After Random Review |
RAILs Sent After Targeted FDS Reviews |
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The Commission is the first New York State ethics agency subject to the Freedom of Information Law (FOIL). Members of the public may request access to lobbying filings, financial disclosure statements, and other records filed with the Commission but not otherwise available online. In 2024, COELIG received 203 unique record access requests and responded to 196 requests, meeting all FOIL requirements . This equates to more than 51,000 pages of documented information provided to the public.
These and other preliminary statistics will be reviewed, finalized, and published in COELIG’s 2024 Annual Report. That report will feature further highlights of the Commission’s work to fulfill its mission to restore public trust in government through education, training and ensuring compliance with the state’s ethics and lobbying laws. The 2022 and 2023 Annual Reports are published on the COELIG website.
Created by New York state law in July 2022, the Commission’s charge is to restore public trust in government by ensuring compliance with the state’s ethics and lobbying laws and regulations. It has jurisdiction over more than 320,000 officers and employees at state agencies and departments, including commissions, boards, state public benefit corporations, public authorities, SUNY, CUNY, and the statutory closely affiliated corporations; the four statewide elected officials and candidates for those offices; employees and members of the state Legislature and legislative candidates; and state and local lobbyists and their clients.
The Commission administers, enforces, and interprets New York’s ethics and lobbying laws by providing information, education, and guidance regarding ethics and lobbying laws; promoting compliance through audits, investigations, and enforcement proceedings; issuing formal and informal advisory opinions; and promulgating regulations implementing the laws under its jurisdiction.
The Commission promotes transparency by conducting its proceedings publicly to the fullest extent permitted by law and by making the financial and other disclosures filed by those subject to the Commission’s authority publicly available. These disclosures include, but are not limited to, annual financial disclosure statements filed by over 30,000 individuals, and millions of records contained in registrations and activity and expense reports filed by lobbyists and their clients.
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