Committee Reports

Opposition to Lowering JCOPE Monetary Disclosure Threshold – 2020 NYS Executive Budget


The Non-Profit Organizations Committee opposes legislation, proposed for inclusion in the Executive Budget, that would lower the monetary threshold for JCOPE disclosure to $500. JCOPE currently requires all individuals and organizations that spend $5,000 or more annually on lobbying activities to register and file reports with the agency.  Registered lobbyists are subject to extensive reporting requirements. For small, grassroots organizations, compliance would be onerous and potentially cost-prohibitive, effectively silencing their voices. Citing to a report by Lawyers Alliance for New York, the Committee explains that the $5,000 threshold already covers 98% of lobbying activities in the state, which calls into question the benefits of the proposed change. Filings would undoubtedly increase, but many highly active local organizations will dissuaded from engaging with their government.


Excluded from the final 2019-2020 NYS Budget



A.2010-A / S.1510-A (Budget Article VII) – Part R
Enacts into law major components of legislation necessary to implement good government and ethics reform budget for 2019-2020; to amend the legislative law, in relation to lowering the monetary disclosure threshold for lobbyists to report prior relationships with agencies or elected officials and to file statements of registration 


The Non-Profit Organizations Committee (“NPOC”), Family Court and Family Law Committee and Government Ethics and State Affairs Committee of the New York City Bar Association (“the Committees”) hereby express opposition to Part R of the Governor’s FY20 Good Government & Ethics Reform Article VII Legislation and urges that Part R be deleted from the bill. Part R requires organizations and people that spend just $500 in a calendar year on lobbying to register with the Joint Commission on Public Ethics (“JCOPE”).

The Committees understand the transparency goals underlying Part R, but we believe that the burdens imposed by Part R far exceed its negligible and perhaps illusory benefits. In particular, the Committees agree with the analysis presented in the separate opposition prepared by the Lawyer’ Alliance for New York and endorsed by many other organizations (attached hereto as Exhibit A) that, while this might increase the number of filings, it will effectively silence small grassroots groups while increasing the influence of big money in government. As described in the separate opposition, the current expenditure threshold of $5,000 captures all of the big money spenders and over 98% of all lobbying expenditures.

The NPOC is a diverse committee of the New York City Bar Association with approximately 40 members. Some NPOC members are law firm attorneys representing nonprofits, some are in house counsel for charitable organizations, and a few are academics. The committee’s members represent multi-million dollar institutions, as well as small charities, operating across the nonprofit sector. Some of these institutions have been serving New York for more than a century; others are in their infancy, taking their first steps to launch their charitable missions.  The Government Ethics and State Affairs Committee focuses on structural ethics issues and has spent considerable time over the past several years studying the efficacy of the current ethics enforcement structure which consists of the Joint Commission on Public Ethics (JCOPE) and the Legislative Ethics Commission (LEC), urging structural reform as well as a strenuous effort by JCOPE and the LEC to rise above the structural deficiencies. The Family Court and Family Law Committee addresses a broad range of substantive and procedural issues regarding Family Court and family law. The Committee includes many members who work for and/or with nonprofit, public interest and legal services organizations that understand the unique burdens that would be imposed by the proposed lowering of the monetary disclosure threshold for lobbyists.

All committee members present when voting at their respective February meetings were unanimous in their opposition to Part R.  Many were personally familiar with the requirements and intricacies of the JCOPE reporting system and recognized that Part R’s proposed reporting requirement would harm and silence many small organizations without any clear benefit in return.

For these reasons, we respectfully urge that Part R be deleted from this bill.

Non-Profit Organizations Committee
Jennifer Reynoso, Chair
Kevin Roe, Secretary 

Family Court and Family Law Committee
Glenn Metsch-Ampel, Chair

Government Ethics and State Affairs Committee
Jennifer Rodger, Chair

Reissued March 2019

**See pdf link at the top of this page for Joint Legislative Memorandum