Dear Filer:

It is time for non-academic Baruch College personnel in “policy-making” positions to file Annual Financial Disclosure Statements (“FDS”) for calendar year 2013. Academic filers will file by November 15, 2014 and will receive a reminder email. It is also time for all academic and non-academic Baruch College personnel, regardless of the “policy-making” designation, to file Honoraria Reports(“Honoraria”) for the period April 1, 2013 to March 31, 2014. The deadline for filing the FDS isThursday, May 15, 2014 and the deadline for reporting Honoraria to the Baruch College Ethics Officeris May 1, 2014.This memorandum and the attachments from the CUNY Office of General Counsel and the New York State Joint Commission on Public Ethics (“JCOPE”)will provide you with the information necessary to file in timely manner.

I.Financial Disclosure Statements

Who Must File

Section §73-a of the Public Officers Law requires all employees in “policy-making” positions and all non-exempt employees who earn $90,020 or greater in calendar year 2013 to file an FDS. The purpose of requiring financial disclosures is to highlight any potential conflicts of interest that may exist for you as a public employee. The FDS will request information about items such as major assets, sources of income, sources of gifts, real property, liabilities, offices held with a political party, and outside employment.

A “policy-maker” is defined as an employee who: (1) manages a group of people or processes with financial implications; (2) deals with vendors; administers contracts,grants, franchises, revocable consents, concessions, variance, or special permits; (3) negotiates or approves leases, permits, or licenses; or (4) is involved in the sale or rental of goods, services, or real property.

Department Chairs are included in the definition of “policy-maker” because they possess discretionary policy-making authority, manage the department and support staff, and have purchasing authority (however limited). Therefore, Department Chairs must file an FDS by May 15, 2014, even if they filed as an Academic Filer by the November 15, 2013 deadline. JCOPE will not grant Department Chairs an exemption from filing.

Newly hired employees must file an FDS within thirty (30) days of being appointed to a covered position. Employees promoted into a policy-making position, newly designated a policy-maker, or whose salary has now reached the $90,020 threshold, must also file an FDS within 30 days of the qualifying event.

JCOPE Notification

You willsoon receive an email from JCOPE on your CUNY email account. You will not receive notification on your personal email account. This email will contain a link that will direct you to the JCOPE filing site.If that link does not work, you can also go to the JCOPE webpage and select “Ethics Online Financial Disclosure System.” Once you are there, you can obtain your password and file on-line. This is a change from previous years when your password was mailed in advance.

Exemptions and Extensions

You can file directly for exemptions (non-policy-makers may apply for exemptions) & extensions (two types of extensions – Justifiable Cause/Undue hardship & IRS extension) on the website or by printing the appropriate form off the website and mailing it to the Commission (address on website).The exemption and extension forms must be postmarked by May 15, 2014 to file for an exemption or extension for the May 15, 2014 FDS filing. You may check the status of your exemption or extension request on your profile on the JCOPE website. Please note that if you are filing for an exemption JCOPEDOES NOT accept copies ofthe CUNY By-laws, which contains job titles. You must describe your job per the instructions on the website and upload your official Baruch College job description or most recent performance evaluation. Incomplete requests will not be accepted. You do not have to file annually for exemptions if your circumstances have not changed (same title/duties).

Filing Deadline

As previously stated, the deadline for filing your Financial Disclosure Statement is May 15, 2014. The on-line system is available 24 hours a day and can be accessed on the JCOPE webpage. Should you have any questions about the electronic filing system,you should callthe “Help Line” for financial disclosure questions at (518) 474-3973. The office is open from 8:30 a.m. to 4:30 p.m. on business days.

Penalty for Non-Compliance

Each FDS will be reviewed by JCOPE for compliance. Employees who fail to file an FDS or who file a deficient FDS will be notified by JCOPE of the non-compliance at their CUNY email addresses. All notices of non-compliance will be posted on the JCOPE website and sent to Baruch College. If, following a written notice, an employee fails to file an FDS or knowingly and willfully with intent to deceive makes a false statement or provides information which the employee knows to be false, that employee is subject a civil penalty of up to $40,000 and the posting of the employee’s name as a delinquent filer on the JCOPE website.

III.Honoraria

Who Must File

All CUNY employees in academic and non-academic titles must comply with the attached rules on the “Limitations on the Receipt of Honoraria and Reimbursement for Travel Expenses.” JCOPE defines honorarium as “a speaking fee or compensation received from writing an article, or reimbursement for travel expenses not related to official duties.”

Non-Academic Titles

CUNY employees in non-academic titles must seek prior approvalfrom the Baruch College President (in consultation with the Ethics Officer at Baruch College) to accept honoraria. A copy of the approval is sent to CUNY’s General Counsel. The receipt of the honoraria must be reported to the Ethics Officer at Baruch College. Honoraria cannot be: (1) accepted for speaking or writing in an area that is related to the CUNY employee’s duties; or (2) received from a disqualified source. A disqualified source is defined by the Ethics Rules as an individual or entity seeking to do or actually doing business with CUNY, such as current vendors, vendors courting our business, and unions.

Academic Titles

CUNY faculty do not have to seek prior approval to receive honoraria and may receive honoraria from a disqualified source “to the extent that the publication of books and articles, delivery of speeches or attending meetings or conferences are within the discipline of the individuals involved.” See Section 930.7. However, all CUNY faculty must report the receipt of all honoraria and are not exempt from the reporting requirement.

Reporting Honoraria

You should access to download the honoraria reporting form. All records of honoraria received by CUNY employees between April 1, 2013 and March 31, 2014, must be recorded on the form. All reports must be forwarded to the Ethics Officer at Baruch College by May 1, 2014. College Honoraria Reports are due to JCOPE by June 1, 2014.

Reporting Honoraria on the FDS

All CUNY employees in both academic and non-academic titles who are required to file an FDS must report all honoraria received in excess of $1,000 on the FDS.

If you have any questions regarding this notification, please contact JCOPE at or my office at the number below.

Sincerely,

Stephanie Vullo

Ethics Officer

Tel: 646-312-3320

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