The State University of  New York 
Compliance & Disclosure Under the Honest Leadership & 
Open Government Act of 2007
Laws, Rules & Public Disclosure
?	Political Campaign Activities
?	Gifts, Events & Travel
?	Lobbying Expenses (LD-2)
?	Lobbying Contributions (LD-203)

Political Campaign Activities
?	Laws Affecting NYS Employees
?	Laws Affecting SUNY & Institutions of Higher Education
Permitted Gifts:  Significant Change in 2007 

?	House and Senate pass amendments to the Lobbying Disclosure 
Act of 1995 and to internal House and Senate rules
?	Federal, STATE, and local governments remain exempt
?	Significant restrictions placed on all others
?	Note:  There are different rules for the Executive Branch!
Permitted Events
?	Federal, STATE, and local exemptions apply.
?	However, others are held to certain standards:
?	Widely Attended Events
?	Educational Events
?	Charity Events

Permitted Travel
?	Again, federal, STATE, and local exemption applies.
?	Again, others are held to certain standards:
?	Sponsored by non-lobbyists
?	Time limitations
?	Advance approval
?	Meeting purpose
IMPORTANT TO NOTE
?	Despite exemption, disclosure of the expense of gift, events, 
travel may, or may not,  be required in the LD-2 or the LD-203.
?	The LD-2 changed, and the LD-203 was established, in the 
Honest Leadership & Open Government Act of 2007 and took 
effect in 2008.
New LDA Requirements
?	Who files?
?	What are lobbying activities?
?	What is a lobbying contact?
?	Who are covered official?
?	Why does SUNY only file one report?
?	Why do we need to disclose information to you?
Calculating the Campus Expense
?	Any amounts paid the third parties retained for lobbying 
purposes
?	Any in-house expense associated with supporting campus 
lobbying activities.
?	IRS "gross-up" method
?	National associations*
LD-203
?	What is the difference between a contribution and an expense?
?	But you said we were "exempt"!
?	"Certification"
?	Official examples of reportable contributions
?	Ultimately, only three categories:  honorary expenses, meeting 
expenses, presidential library expenses



Pop Quiz
?	A SUNY campus with a listed lobbyist invites a member of 
congress to give the graduation address. Does the university 
report the Congresswoman's appearance on the its LD-203?  
?	NO

?	What if they decide to present her with an honorary degree or 
award?
?	YES, this would now need to be reported on the LD-203.


?	A listed lobbyist for a SUNY campus and a listed lobbyist for a 
private university invite congressional staff to a small Capitol 
Hill briefing on the Higher Education Act.  Can staff attend?  
Can food be served?  What type?
?	Yes, they may attend.
?	Yes, food may be served.
?	It must be "finger food".

?	A faculty researcher visits his grant officer at NIH to discuss an existing 
grant.  Is this a lobbying contact?  
?	No
?	He asks the grant officer about extending the grant.  Is this lobbying?
?	No
?	He goes to see a political appointee about extending the grant.   Is this a 
lobbying contact? 
?	Yes
?	Does it need to be reported in the LD-2?
?	No, not if he is not a listed lobbyist.

?	What if a covered official at the Department of Education is 
contacted by a senior SUNY administrator about HEA 
negotiated rulemaking.  Is this a lobbying contact?
?	Yes
?	Is it reported on SUNY's LD-2?
?	No
?	What if Liz Clark made the contact?
?	Yes, this needs to be reported.
Public Means Public:  LD-2

Public Means Public:  LD-203

Public Means Public:  FEC Contributions