JCOPE Seeks Public Comment on Proposed Source of Funding Regulations
The Joint Commission on Public Ethics (JCOPE) is seeking public comments on its proposed amendments to its source of funding disclosure regulations.
JCOPE’s emergency regulations regarding the amended source of funding law go into effect on September 23, 2016.
JCOPE has also commenced a the formal rule making process for the permanent adoption of these revised source of funding disclosure regulations, which will be published in the New York State Register. JCOPE will accept comments on them through October 29th.
Per JCOPE:
“Among the key changes in the regulations based on the legislation: (1) the threshold for disclosure of sources of funding by a lobbying entity was reduced from $50,000 to $15,000 in annual expenditures on lobbying (which must be at least three percent of the client’s total expenditures); and (2) whereas entities that met the threshold previously were required to disclose the sources of any funding contributions over $5,000, they would now have to disclose the sources of contributions of $2,500 or more.”
I will also note one additional change that membership organizations will want to take note of, the proposed change to 19 NYCRR § 938.3 which, provides: “If a contribution includes only membership dues, fees, or assessments, the Client Filer should disclose the contribution as $0.”
For those membership organizations that are subject to the source of funding disclosure requirement, simply having to identify their members who pay more than $2,500 in dues (rather than having to list the amount of dues each member pays) should make compliance somewhat easier.