As a result of broad ethics reform legislation enacted in 2011, the New York State Legislative Law mandates that the New York State Joint Commission on Public Ethics (JCOPE or the Commission) “provide an online ethics training course for individuals registered as lobbyists.” The law further requires that all lobbyists “complete such training course at least once in any three-year period during which he or she is registered.” The statute lists “ethics in the public officers law, the election law, the legislative law, summaries of advisory opinions,” and the rationale for those policies, as topics that are to be covered in the training.
On Sept. 26, 2014, JCOPE announced that the online training program is available, and that lobbyists must complete the training within the next three months – prior to the end of the year. The training course, called “Ethics for Lobbyists,” is presented as an online slideshow, wherein JCOPE summarizes some of the more important regulatory obligations for lobbyists and clients of lobbyists in New York State. The program should take most participants between 20-30 minutes to complete, and does not currently include any kind of examination. It is important, however, that the lobbyist completing the program follow the Commission’s explicit log-in information in order to obtain credit for the course. JCOPE has advised that the Commission’s staff “will monitor compliance with this mandated training on an ongoing basis.”
The Commission has explained that, due to the requirement that lobbyists complete the training once every three years, all lobbyists who were registered with the Commission during the 2011-2012 and 2013-2014 biannual reporting periods (including all individuals who were listed on an organization’s Registration Statement during these periods), must meet the December 31 deadline. Lobbyists who were only registered during 2013-2014 will have until the close of 2015 to complete the program. It appears that individuals who were previously registered lobbyists but have terminated their relationship and do not expect to engage in lobbying activity during 2015, also do not have to complete the training at this time.
It is important that all lobbyists comply with this simple, but mandatory, requirement. As always, Greenberg Traurig’s Government Law Compliance Practice is available to assist with questions regarding New York State’s lobbying, ethics, and election laws. GT has a broad range of experience in New York City and State, and provides advice to some of the world’s leading corporations, lobbying firms, public officials, candidates, advocacy organizations, and others who seek to navigate New York’s complex political law compliance requirements.