In 2013, six years after the last round of amendments to the New York City lobbying laws, the city enacted Local Law 129, resulting in some notable revisions to the Administrative Code’s regulation of lobbying. Among other things, the revised Administrative Code provisions broadened the application of the city’s lobbying law to capture certain activities that had previously not triggered an obligation to register as a lobbyist with the city clerk and file subsequent disclosure reports.
In October, the city clerk adopted revised rules that took effect on Nov. 4, 2015. The rules purport to “conform existing rules to the amendments enacted by Local Law 129 of 2013,” but there are aspects of the rules that represent a departure from prior practice and could require lobbyists and clients of lobbyists to change existing internal processes. It is imperative that all lobbyists, clients of lobbyists, and other individuals who interact with New York City government be aware of the new requirements and take steps to ensure continued compliance with the city clerk rules.
Complete Enrollment Within 10 Days or Be Prepared for Monetary Penalties
New York City’s Administrative Code provides that lobbyists who “reasonably anticipate combined reportable compensation and expenses in excess of” $5,000 must file statements of registration with the city clerk within 15 days. The Administrative Code further provides that “[b]efore a lobbyist files a statement of registration pursuant to paragraph one of this subdivision, the lobbyist and its client shall enroll in the electronic filing system.”
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