Joint Commission on Public Ethics Information
The New York State Joint Commission on Public Ethics (JCOPE) was created out of the Public Integrity Reform Act (PIRA) of 2011, which became effective August 15, 2011. (Chapter 399 of the Laws of 2011) PIRA established JCOPE and expanded the existing functions of the former ethics body in New York, the Commission on Public Integrity. The JCOPE Commission oversees ethics within New York State Agencies, including SUNY. There are many compliance mandates associated with the PIRA law, and JCOPE is the body charged with overseeing the administration of those mandates.
JCOPE Applicable Laws and Regulations
Public Officers Law Section 73 - a(1)(c)(ii) states that each agency is required annually to prepare and submit a report to JCOPE that lists all persons employed or affiliated with the Agency in the preceding year who are reqiored to file an annual FDS.
DUE DATE: Feb. 28th or before of each year from the Ethics Officer
According to the Public Officers Law Section 73-a(1)(c)(iii), each agency is required to update and amend the FDS filer list with the name of the new FDS Filer within thirty days of the date of the person becoming an FDS Filer. The Ethics Officer is responsible for submitting such amendments to the FDS filer list within thirty dats of the date that the new officer or employee becomes an FDS filer.
Events that trigger amendments are:
DUE DATE: Ethics Officer must file amendment to the list within 30 days of the change
All covered agency employees who are 'FDS Filers' under the Public Officers Law Section 73 must file their financial disclosures to JCOPE by May 15th of each year, OR September 15th if they are a SUNY FACULTY member. The Ethics Officer is responsible for notifying the Agency Officers and employees of the requirement to file an FDS and to tame mandatory Ethics training.
WHO is required to file an FDS:
DUE DATE: Due May 15th of each year; Employees file directly with JCOPE
Mandated Ethics Training for FDS Filers: JCOPE's Comprehensive Ethics Training Course
(Note: NOTE: This training is separate from the ethics training mandated by Executive Order 3. That training is very limited in scope as to WHO must take the training. The JCOPE training has a wider scope, in that all FDS filers must take the training. Furthermore, the training FDS filers must receive is the one prepared directly by JCOPE.
According to Executive Law Sec. 94(10)(a) Individuals who were FDS filers on or before August 15, 2011 are required to complete the Comprehensive Ethics Training course by August 15, 2013. The Comprehensive Ethics Training course must be delivered LIVE and should take approximately 2 hours. The statute requires that the JCOPE presentation, which has been prepared by JCOPE, is delivered in whole and in the same form. NOTE: The JCOPE presentation is available here. This training course MUST be used in order to fully comply with this training requirement.
Each Agency also has a statutory requirement to TRACK and REPORT training on a yearly basis to JCOPE, to report to JCOPE which FDS filers have completed the training.
Live Synchronous Training, which is mandated by the law, has been defined by JCOPE as:
JCOPE Ethics Training Course Materials are available here.
After the completion of the Comprehensive Ethics Training Course (listed above), FDS Filers are required to complete an ethics seminar every THREE years. The Ethics Seminar is an update on any changes in applicable laws, regulations and policies. Each Agency also has a statutory requirement to TRACK and REPORT training on a yearly basis to JCOPE, to report to JCOPE which FDS filers have completed the training.
DUE DATE: Those individuals who were FDS filers on or before August 15, 2011, and completed the comprehensive ethics training, discussed above, by August 15, 2013, are required to complete the Ethics Seminar by August 15, 2016.
According to Title 19 NYCRR Part 930.5(c)(1), the Ethics Officer is responsible for notifying covered individuals of the requirement to report honoraria they received in the preceding year to the Ethics Officer on or before April 1 of EACH YEAR.
DUE DATE: April 1, annually: Agency employees must report honoraria they have received to the Ethics Officer.